Annual
Report
2022
We are a community serving the communityMembers of the Irish Olympic Team and the Irish Paralympic Team pictured at the launch of Permanent TSB’s title sponsorship of Team Ireland for the 2024 Games in Paris. This document contains certain forward-looking statements with respect to Permanent
TSB Group Holdings plc’s (the ‘Group’) intentions, beliefs, current goals and expectations
concerning, among other things, the Group’s results of operations, financial condition,
performance, liquidity, prospects, growth, strategies, the banking industry and future
capital requirements. These forward looking statement often can be identified by the fact
that they do not relate only to historical or current facts.
Generally but not always words such as “expect”, “anticipate”, “intend”, “plan”, “estimate”,
“aim”, “forecast”, “project”, “target”, “goal”, “believe”, “may”, “could”, “will”, “seek”, “would”,
“should”, “continue”, “assume” and similar expressions (or their negative) identify certain
forward-looking statements but their absence does not mean that a statement is not
forward looking. The forward-looking statements in this document are based on numerous
assumptions regarding the Group’s present and future business strategies and the
environment in which the Group will operate in the future. Forward-looking statements
involve inherent known and unknown risks, uncertainties and contingencies because they
relate to events and depend on circumstances that may or may not occur in the future and
may cause the actual results, performance or achievements of the Group to be materially
different from those expressed or implied by such forward looking statements. Many of
these risks and uncertainties relate to factors that are beyond the Group’s ability to control
or estimate precisely, such as future global, national and regional economic conditions,
levels of market interest rates, credit or other risks of lending and investment activities,
competition and the behaviour of other market participants, the actions of regulators and
other factors such as changes in the political, social and regulatory framework in which
the Group operates or in economic or technological trends or conditions. Such risks and
uncertainties include, but are not limited to, those as set out in the Risk Management
Report. Material economic assumptions underlying the forward looking statements are
discussed further in Market Context.
Past performance should not be taken as an indication or guarantee of future results, and
no representation or warranty, express or implied, is made regarding future performance.
Nothing in this document should be considered to be a forecast of future profitability or
financial position and none of the information in this document is intended to be a profit
forecast or profit estimate.
The Group expressly disclaims any obligation or undertaking to release any updates
or revisions to these forward-looking statements to reflect any change in the Group’s
expectations with regard thereto or any change in events, assumptions, conditions or
circumstances on which any statement is based after the date of this document or to
update or to keep current any other information contained in this document. Accordingly,
undue reliance should not be placed on the forward looking statements, which speak only
as of the date of this document.
Investor and shareholder information and services including these Annual Reports, are
available on-line at www.permanenttsbgroup.ie.
Contents
Strategic Report
Financial Highlights
Non-Financial Highlights
Chairman’s Statement
Chief Executive Review
Market and Regulatory Context
Our Strategy, Business Model and Culture
Sustainability
Financial Review
Capital Management
Risk Management
Corporate Governance
Directors’ Report
Corporate Governance Statement
Director’s Report on Remuneration
Statement of Director’s Responsibilities
Consolidated Financial Statements
Independent Auditor’s Report
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
Company Financial Statements
Company Financial Statements
Notes to the Company Financial Statements
General Information
Alternative Performance Measures (unaudited)
Abbreviations
Definitions
2
3
4
6
9
11
21
45
57
60
89
96
142
147
148
158
164
263
266
270
277
278
1
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Financial Highlights
Financial Performance
Underlying profit/(loss) €m (a)
Underlying (loss)/profit €m (a)
Net Interest Margin % (b)
Net Interest Margin % (b)
Return/(loss) on Equity % (c)
Loss/return on Equity % (c)
2022
2021
2020
€45m
€17m
2022
2021
2020
(€109m)
1.54%
1.51%
1.73%
2022
2021
2020
0.55%
0.97%
(5.4)%
2022: €45m
Underlying profit increased due to higher
net interest income and an impairment
write-back offset by higher operational
expenses
2022: 1.54%
3bps higher due to reduction in negative
yields on excess liquidity and increased
yields on the Bank’s tracker mortgage
portfolio due to ECB interest rate increases,
offset by higher wholesale funding costs
2022: 0.55%
Decreased due to significant investment in
simplification of the bank
Transformation and simplification
Adjusted cost to income ratio (d)
Adjusted Cost to Income Ratio (d)
Customer deposits (e)
Customer deposits €m(e)
2022
2021
2020
84%
82%
75%
2022
2021
2020
€21.7bn
€19.1bn
€18.1bn
2022: 84%
Increased due to the acceleration of
investment in the digital transformation
programme and the effect of cost inflation
pressures
2022: €21.7bn
Increase in current account and retail
deposits in line with expected inflows as
a result of Retail Banks exiting the Irish
Banking market
Sustainability
CET Ratio (Transitional basis) (f)
CET Ratio (Transitional basis) (f)
NPL Ratio (g)
NPL Ratio (g)
Risk weighted assets (RWA) (h)
Risk weighted assets (R.W.A) (h)
2022
2021
2020
16.2%
2022
3.3%
16.9%
18.1%
2021
2020
5.5%
7.6%
2022
2021
2020
€10,627m
€8,600m
€8,480m
2022: 16.2%
Decrease is as a result of capital use
on new lending and the Ulster Bank
transaction.
2022: 3.3%
Decrease is due to the purchase of
performing Ulster Bank business assets
from Natwest Group along with NPL cures
being greater than new defaults.
2022: €10,627m
Increase is due to balance sheet growth
through new lending and the purchase of
the Ulster Bank business.
(a) Operating profit before exceptional and other non-recurring items. See table 8 on page 52 for a reconciliation of underlying profit to operating profit on an IFRS basis.
(b) Defined as net interest income (NII) divided by average interest-earning assets.
(c) Defined as profit for the year after tax (excluding exceptional and other non-recurring items) expressed as a percentage of total average equity.
(d) Defined as total operating expenses (excluding exceptional and other non-recurring items) divided by total operating income.
(e) Defined as the sum of current accounts, retail deposits and corporate deposits.
(f) Total common equity tier 1 (CET 1) capital on a transitional basis divided by total risk weighted assets (RWAs).
(g) Defined as non-performing loans (NPL) expressed as a percentage of the total gross loans of the bank.
(h) RWAs are the Group’s assets and off balance sheet exposures, weighted according to risk.
2
Permanent TSB Group Holdings plc - Annual Report 2022 Non-Financial Highlights
An increased focus on Sustainability and Climate Risk,
with the introduction of a Sustainability Strategy for
the Bank and the development of a Climate-Related and
Environmental Risk Action Plan
A CDP rating of C, indicating an awareness level
of engagement
83% reduction in scope 1 and 2 carbon emission
intensity last year (a cumulative reduction since 2009)
and committing to setting science-based carbon
emission reduction targets (SBTs) by 2024
Launching the Bank’s Green Mortgage, with c.€500
million in green lending drawn down during 2022*
113,000 new Current Accounts and 43,000 new Deposit
Accounts opened in 2022, with 47% of new Current
Account openings taking place through the Bank’s
award-winning Digital Current Account
A commitment to growing our branch footprint by 30%
to 98 locations nationwide
c.€600,000 donated in Irish community organisations in
2022, supporting local communities across the country
€250,000 donated to UNICEF Ireland and the Irish Red
Cross to support the Ukrainian relief efforts
Announcement of the Bank’s Title Sponsorship of the
Irish Olympic Team and the Irish Paralympic Team for
Paris 2024
80% Culture Index Score, +10% above our Culture Index
Target of 70%
89% of employees feel comfortable to be themselves at
work regardless of background or life experiences
42% Board Gender Composition and 38% of Senior
Leadership positions are filled by Women
A focus on €1 billion in SME lending over the next three
years
+10 Relationship Net Promotor Score (RNPS)**, placing
Permanent TSB in 3rd position among the retail banks in
Ireland
Our Commitment To Building A
Sustainable Business
Awards And
Recognitions In 2022
Ambitions For
2023 And Onwards
Our Purpose is to work hard
every day to build trust with
our customers – we are
a community serving the
community.
Our Sustainability Strategy
gives us an opportunity
to put our purpose into
action - enabling us to play
our part in addressing the
global climate crisis, elevate
our social impact, enhance
our culture and deliver
what matter most to our
customers and colleagues.
Ultimately, building a
sustainable organisation
that is fit for the future.
• Winner – Best Community or Charity
Engagement for the Permanent TSB
Community Fund, Bonkers National
Consumer Awards, 2022
• Winner – Best Current Account, Bonkers
National Consumer Awards, 2022
• Winner – Best Mortgage for First-Time
Buyers, Bonkers National Consumer
Awards, 2022
• Winner – Innovative Banking Product, FS
Awards, 2022
• Winner – Financial Services Loyalty
Programme of the Year, Irish Loyalty
Awards, 2022
• Winner – #1 for Social Media for a Financial
Organisation, Sockie Social Media Awards,
2022
• Winner – Best Procurement External
Collaboration Project, National
Procurement Awards, 2022
• Winner – Best Procurement
Transformation Project, National
Procurement Awards, 2022
• Winner – Best Flexible and Hybrid
Workplace, CIPD Awards, 2022
• Awarded the Investors in Diversity Silver
Accreditation
• Embedding our Sustainability Strategy
•
•
Increasing our focus on climate-related
and environmental risk management
Introducing a Sustainable Supplier
Charter
• Elevating our social impact through
partnerships and continuing to
support local communities through the
Permanent TSB Community Fund
• Partnering with small businesses
through our Business Banking Strategy
• Ensuring strong corporate governance,
compliance and fair business conduct
* A 5-Year Fixed Product available to all new and
existing home loan customers where their homes
have a confirmed or proposed Building Energy
Rating of A1 to B3.
** A Relationship Net Promoter Score (RNPS) is a
measure of customer advocacy towards a brand
and indicates the willingness of a customer to
recommend a company’s products or services to
others. The question asks customers how likely they
are to recommend their bank to friends or family on
the basis of their own experience. The range for the
scoring is -100 to +100.
3
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Chairman’s Statement
2022 was a year of significant progress for Permanent
TSB. The acquisition of certain elements of Ulster
Bank’s business combined with organic growth
fuelled transformational growth for the organisation.
We focused on welcoming tens of thousands of
new customers and further improving our customer
experience, as we worked towards our ambition of
becoming Ireland’s best personal and small business
bank
2022 was truly a transformational year
for Permanent TSB, as we began the
integration of the retail and SME businesses
we are acquiring from Ulster Bank.
There is a real sense of excitement across
the organisation as we welcome the new
customers and colleagues that are joining
us. The transaction is making us a bigger
bank and an even stronger competitor in the
market.
That means a bank with more customers.
One with a bigger branch footprint, which is
increasing by about 30% to become part of
an additional 25 communities throughout
Ireland – from Buncrana in Donegal to
Wilton in Cork, and from Westport in Mayo
to Blackrock in Dublin, a bank that’s a
greater competitive force. And, perhaps
most importantly of all, a bank with an
ambition that is stronger than ever to be
Ireland’s best personal and small business
bank.
Our annual report this year is being
presented against a backdrop of great
challenge. We are mindful of the immense
suffering that continues to be inflicted
on the people of Ukraine. Closer to home,
we are witnessing the effects of a major
economic shock triggered by disruption in
global energy markets.
This has resulted in severe cost of living
pressures and a greatly changed interest
rate environment that has brought to an end
the unprecedented era of historically low
interest rates.
The economic outlook is uncertain but
we are approaching the year ahead
with confidence. Confidence in the Irish
economy, which proved itself to be strong
in the face of the pandemic and which
continues to show evidence of great
4
resilience despite the challenges we have
seen over the past year.
But our confidence does not end there.
We also have great faith in our Bank
and in our colleagues. Throughout the
organisation we have the benefit of a team
of people of great skill, professionalism and
commitment. They bring these qualities
with them to their work every day, with the
overriding aim of serving our customers to
the very best of their ability and meeting
their financial needs.
The individual successes achieved every
day – in their dealings with our customers,
in their support work behind the scenes,
and in their efforts to constantly develop
new and better ways to do things – are
what makes the Bank successful of which
our people can be proud.
They have made it a commercial success,
winning new customers, developing
better customer offerings and increasing
market share. Moreover, they have made
it a financial success, building on the
profitability of 2021 to set us on a trajectory
of profitable growth.
Furthermore, they have made it a success
in the community, as we continue to embed
ourselves as a fundamental part of Irish
life. This objective of community service
is inspired by our unique roots going back
more than 200 years in the building society
and trustee savings bank movements.
Our commercial performance
We are reporting a very significant increase
in profitability for 2022, with our reported
pre-tax profit increasing from -€21 million
to €267 million, primarily driven by net gains
that are once-off in nature and which arise
from the Ulster Bank transaction.
Excluding exceptional and non-recurring
items, I am pleased to say that our
underlying profit increased from €17 million
in 2021 to €49 million in 2022, building
on the strong momentum we made in the
previous year. Underlying profit this year is
€45m.
This progress gives us an excellent platform
to build future growth. The Ulster Bank
transaction will give greater scale and I am
confident that we will see the economic and
strategic benefits of the transaction will
become clear as we proceed to integrate the
businesses.
We are encouraged by the opportunity that
we see in the Irish retail banking market at
present. The exit of Ulster Bank and KBC
from Ireland highlights that the need for
competition in retail and SME banking is
greater than it ever was.
We in Permanent TSB have a track record
in bringing new products, customer-friendly
offerings, and innovation to the market. We
expect to do more, not less, of this in the
years to come.
The Ulster Bank transaction enables us
to reach more customers around Ireland
and that is a testament to the strength
of our heritage and our determination to
provide customers with multiple ways to
do business with us, in person, by phone,
or through our award-winning digital
channels.
In the years in come, particularly in the retail
market, where we continue to grow market
share in new lending and in new current
accounts, as well as in the SME market,
where we aim to generate more than €1
billion in new lending over a three-year
period to the SMEs that are the lifeblood of
our economy.
Permanent TSB Group Holdings plc - Annual Report 2022 The Ulster Bank transaction will give us
valuable opportunities to strengthen our
existing customer relations and indeed
serve more retail and SME customers. It will
make us better equipped to target markets
in which Ulster Bank played a leading role
and where there is considerable scope for
Permanent TSB to scale up its presence
significantly.
Governance and management
As Chairman, one of my key responsibilities
is to ensure that our governance and
management structure is always aligned
with the needs of the organisation as they
evolve.
That requires close scrutiny of the way
the Board operates so that shareholders
and colleagues can have confidence that
the Board has access to the right blend
of skills and experience to challenge the
management team and to provide an
appropriate level of oversight.
I have also strived to continue the progress
we have been making in getting better
gender balance at Board level and in senior
management positions.
We are still some distance from where
we need to be in terms of seeing female
colleagues at senior levels. But I want to
assure all our shareholders, our colleagues
and those who may be considering
advancing their career with Permanent
TSB in the future, that we are committed
to continuing this progress as a matter of
upmost priority.
I was delighted that the Board was in a
position to welcome Nicola O’Brien as its
newest member in 2022, following her
appointment as Chief Financial Officer of
the Bank.
With regards to Gender Pay, our approach
is to ensure that that all employees,
regardless of gender, age or social or ethnic
background are remunerated fairly and
that no differentiation exists in the pay of
any individual as a result of any of those
factors. With a mean hourly remuneration
pay gap of 17.51% and a median of 10.54%
in 2022, there is more work to do in
developing and implementing effective
strategies that will eliminate this gap.
Outlook
This is my last Annual Report as Chairman
of the Bank, as my six year term comes to
an end in the coming weeks. I have really
enjoyed this role, have been fortunate to
have held it and take great pride in my
colleagues, present and past, who have
achieved so much in strengthening and
enhancing the Bank’s position over that
time.
They are good people who have made
the Bank a better provider of services
to our customers; a better place for our
colleagues to work and to develop their
careers; an organisation that operates
in a more sustainable, responsible way;
and a more attractive business in which
shareholders can entrust their capital.
They have made it a workplace with a
greater gender balance and a greater
awareness of the task that still lies ahead
of making the changes necessary to give
everyone the same career opportunities;
and one in which the diversity of our people
is enjoyed and applied for everyone’s
benefit.
I will be leaving Permanent TSB, satisfied
with its stability and prospects, using the
Ulster Bank transaction as a catalyst to
achieve even greater things.
Nicola is an excellent addition to both the
senior management and to the Board,
bringing an outstanding level of experience
and knowledge to her new position. With
her appointment to the Board, the number
of female members has risen to 40%,
representing a significant – but long overdue
– improvement.
I was astonished by the extraordinary
contribution made by our colleagues
in response to the challenges of the
pandemic. They looked out for each
other and looked out for their customers,
routinely going above and beyond the call
of duty because they felt that was the right
thing to do.
Diversity and Inclusion (D&I) remains a key
priority for Permanent TSB as it is a self-
evident enabler to building a responsible
and sustainable bank for the future. Since
the launch of our D&I Strategy in 2018, we
have made significant progress in fostering
and maintaining a diverse and inclusive, risk
integrated growth culture.
I am grateful to the Minister for Finance, his
predecessor, the Department of Finance
and the Central Bank of Ireland for the
support which they have given to the Bank.
I thank my fellow Board members and
the Bank’s management team for their
leadership, skill and dedication. Our Chief
Executive, Eamonn Crowley, has displayed
immense vision, authority and enthusiasm
for the Bank. He has successfully built on
the foundations of his predecessor, Jeremy
Masding. He has consistently impressed me
with his rigour, leadership skills and resolute
focus on making Permanent TSB a better
bank for our customers, our colleagues,
our communities, and of course you, our
shareholders.
And I want to give my successor, Julie O’Neill,
every good wish for her term as Chairperson.
I got to know Julie over a period of several
years when she previously served on the
Permanent TSB board and I can say without
equivocation that the Bank will benefit greatly
from her leadership. She brings a formidable
track record and extensive corporate
governance expertise to the position.
To have been part of this organisation for the
last six years has been an enormous honour
and privilege. It has reinforced my love of
Ireland and huge affection for its people.
I will continue to follow closely the fortunes
of Permanent TSB from the outside and wish
everyone in the Bank every success in their
professional and personal endeavours. It is an
institution that we can all be proud of and I am
in no doubt that its best days lie ahead.
Robert Elliott
Chairman
5
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Chief Executive Review
It is my honour to present the 2022 Annual Report for
Permanent TSB. It was a year of improved profitability,
market share gains in a highly competitive environment,
competing robustly and successfully, serving our
customers and the communities that we are a part of, and
delivering results that we can be proud of.
The environment in which the Bank operates changed
dramatically – but the Permanent TSB community has
responded to these changes in a way that we can all be
proud of.
Introduction
Our ambitions to acquire certain elements
of Ulster Bank’s retail, SME and asset
finance businesses in the Republic of
Ireland are no longer plans – they are now
a reality.
As we enter 2023, Permanent TSB is well
positioned to build on this transformational
acquisition with further growth, serving
more customers as we continue our work
towards becoming Ireland’s best personal
and small business bank.
We achieved so much in 2022. Our
colleagues who worked on executing
the Ulster Bank transaction delivered an
outstanding performance, successfully
migrating c. 56,000 residential mortgage
customers connected to c. 36,000 loans
totalling c. €5.2 billion from Ulster Bank
to Permanent TSB, with the remaining
customers scheduled to migrate in the first
half of 2023.
We opened over 113,000 new personal
current accounts, primarily driven by
former Ulster Bank customers in need of
a new provider who were attracted by our
award-winning digital current account
offering.
We made it easy for these customers to
join Permanent TSB with a combination
of an online account opening process, our
contact centres, pop-up branches, mobile
branches and putting Permanent TSB
people in Ulster Bank branches.
And in recent weeks we have continued
this excellent momentum with the
landmark transfer of c. 3,200 Micro-SME
loans totalling c. €165 million, and the
opening of 25 new branches throughout
Ireland that previously operated as Ulster
Bank branches, increasing our branch
footprint by 30%.
And we want to remind them that this
transaction was driven, above all else,
by meeting their needs. To each of these
customers I say today: we are honoured
to have your business, we want you to be
happy with the service we provide and
the products we offer, and we are ready
and willing to meet more of your financial
services needs.
Our welcome extends beyond these
customers to the over 300 new colleagues
that have joined us from Ulster Bank or
who will do so over the coming months.
To each of these new colleagues I say:
we need you to make this a success, we
want you to build on the great work you
have done for these customers in Ulster
Bank, and you will have our full support
in achieving the next stage of your career
ambitions with Permanent TSB.
The success of the integration programme
should not distract from our business
performance in 2022. At a time when the
organisation was preparing and executing
a major transaction, our colleagues
throughout the Bank never lost focus
on our purpose of building trust with our
customers every day.
That is a credit to them and they are a
credit to the Bank. That focus resulted in
an excellent performance for 2022, which
is detailed in this Annual Report.
I will address the details of our
performance now.
6
Business Performance Overview
Funding
Customer Accounts
At 31 December 2022, customer accounts
of €21.7 billion are €2.6 billion higher than
31 December 2021. Customer account
growth reflects expected inflows from
exiting banks. Retail deposit balances of
€11.6 billion have increased by 9% over the
course of 2022, while current accounts of
€9.0 billion have increased by 26%. The
Bank remains strongly funded by retail
deposits and current accounts, making
up 88% of the total funding profile and
reflecting a strong liquidity and lending
position.
Lending
Total new lending in the financial year
2022 amounted to €2.8 billion, an increase
of c.40% from 31 December 2021. The
increase largely reflects a strong increase
in mortgage lending relative to 2021, when
pandemic-related uncertainty caused a
fall-off in mortgage activity.
Mortgage lending in 2022 was €2.6 billion,
representing a 40% year on year increase
and significantly outperforming the wider
market, which grew by 34%. This resulted
in our mortgage drawdown market share
increasing from 17.8% in 2021 to 18.5% in
2022.
The mortgage market as a whole
rebounded strongly in 2022. Pent up
demand saw a surge in applications in late
2021 and this strong momentum continued
into 2022. Total mortgage drawdowns
from all mortgage providers increased
from €10.5 billion in 2021 to €14.1 billion in
2022. There were 30k housing completions
in 2022, a 47% increase year on year,
however demand continues to outweigh
supply.
Permanent TSB Group Holdings plc - Annual Report 2022 SME lending in 2022 was €150 million, a
53% increase compared with 2021. The
increase was largely driven by lending
through the Strategic Banking Corporation
of Ireland (SBCI) Future Growth Loan
Scheme that launched in late 2020 and the
Bank also participated in the SBCI Brexit
Impact Loan Scheme in 2022.
We recently announced ambitious plans to
scale up our SME lending, with the launch
of a new €1bn SME lending fund which we
aim to deploy over the next 3 years. The
Ulster Bank transaction will add significant
momentum to our SME growth plans by
adding Ulster’s asset finance and micro-
SME lending businesses to our organic
growth, increasing our business lending in
size by c. 200%.
The Group recorded gross new Term
lending of €96 million in 2022. This is a
3% increase compared to 2021, and digital
adoption continues to grow with 80% of
new term lending drawdowns taking place
via our direct channels.
Financial Performance Overview
The Bank reported a Profit Before Tax of
€267 million for 2022 (2021: Loss Before
Tax of €21 million) which includes the
Gain on Bargain Purchase and transaction
costs and other provisions of €239
million associated with the Ulster Bank
Transaction. The commencement of
ECB interest rate increases in July 2022
has contributed to Net Interest Income
increasing by 16% year-on-year, while
increased transactional activity from our
growing customer base resulted in Net
Fees & Commission income increasing to
€42m from €35m in 2021.
Operating Income
Net interest income (NII) of €362 million
has increased by 16% year on year and
our Net Interest Margin (NIM) increased
by 3bps to 1.54%. Net interest income
increased due to higher new lending, an
increase in ECB rates which impacted
tracker mortgages and increased income
as a result of the migration of the Ulster
Bank performing loans assets during Q4
2022. This is partially offset by increases in
other wholesale funding costs.
Net fees and commission income was
€42 million for 2022 compared to €35
million in 2021. The increase is mainly due
to increased transactional activity during
2022 from a growing customer base.
Net other income was €5 million for 2022
compared to €13 million in 2021.
use, reflecting the investment in the Bank’s
Digital Banking Programme.
Operating Expenses
Operating expenses excluding exceptional
and other non-recurring items of €395
million are higher than prior year, primarily
due to the acceleration of investment in
the Bank’s digital banking programme
and higher amortisation arising from the
significant expenditure on technology and
business programmes over the last number
of years.
Impairment
The Bank recorded an impairment write-
back on loans and advances to customers
of €31 million for 2022 (a net €20m
result post €11m capital deduction for
calendar provisioning), compared to a €1
million write-back for 2021. This reflects
the continued growth in house prices
whilst maintaining an appropriate level of
provisions in light of high levels of inflation.
Exceptional and other non-recurring
items
The total exceptional and non-recurring
items for 2022 are €222 million. This
consists of a gain on bargain purchase of
€362 million which is offset by €123 million
relating to costs and impairment charges
on the Ulster Bank transaction. Additional
costs of €13 million relates to restructuring
and other costs, and €4 million relating to
legacy legal cases.
NPLs
Non-performing loans (NPL) as a
percentage of gross loans were 3.3% at
31 December 2022, down from 5.5% at 31
December 2021. This is primarily as a result
of the addition of the performing Ulster
Bank loans during Q4 along with cures/
resolution offsetting any new defaults. .
Capital
The Common Equity Tier 1 (CET1) capital
ratio was 15.2% and 16.2%, on a Fully
Loaded and Transitional basis respectively.
This compares to the Bank’s reported CET1
ratio of 14.7% and 16.9% at 31 December
2021, on a Fully Loaded and Transitional
basis respectively.
The reduction in the transitional CET1 ratio
(-0.7%) in the year is primarily due to the
transitional phasing of the Group’s Deferred
Tax Asset balance and the prudential
phase-in of IFRS9 which was partially
offset by an increased capital add-back
related to intangible software assets in
Capital ratios remain above both
management and regulatory minima. The
Central Bank of Ireland (CBI) has provided
additional flexibility to Banks under their
supervision in the context of the pandemic
to support the sustainable provision of credit
to the economy.
Sustainability
The global climate crisis has elevated the
sustainability agenda not only in Ireland,
but around the world. We see it in the
continued shift in consumer trends and the
growing demand for sustainable products
and services. Indeed, c.20% of Permanent
TSB’s new lending in 2022 (c. €500 million
in value) relates to our Green Mortgage
product.
Now more than ever businesses, such as
Permanent TSB, have a significant role
to play in supporting our stakeholders
to navigate the green transition and
to embrace the opportunities that
sustainability brings.
However, sustainability is about more
than just being green. For us, it is about
doing everything we can to support our
customers, colleagues and communities,
while ensuring that we conduct and manage
all areas of our business in a responsible
way.
We have made progress – introducing
a Sustainability Strategy for the Bank
aligned to the Sustainable Development
Goals; ensuring strong governance and
establishing a Sustainability Committee;
increasing our focus on Climate Risk with
the development of a Climate-related and
Environmental Risk Implementation Plan;
disclosing our carbon impact across Scope
1, 2 and 3 and committing to setting science
based targets; launching the Bank’s Green
Mortgage with a suite of sustainable finance
products to follow; and, becoming a founding
member of the International Sustainable
Finance Centre of Excellence, a key output
of Ireland’s Sustainable Finance Roadmap.
We acknowledge however that there is
more to do, and through the delivery of our
Sustainability Strategy, we are focussed
on continuous improvement and further
integrating Sustainability into all areas of our
business, ultimately building a sustainable
organisation that is fit for the future.
7
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Chief Executive Review
(continued)
Cultural Evolution
The Bank’s ambition to be Ireland’s best
personal and small business Bank is only
possible if we create customer-centric,
inclusive and diverse, risk integrated,
growth culture, where our colleagues feel
engaged, valued and are given the support
that they need to be the best they can be.
We continue to evolve our culture with a
range of employee led initiatives including
investment in learning in development,
our employee resource groups as well
as evolved ways of working. In 2022,
Permanent TSB continued embedding our
Smarter Working Programme to enable
optionality and more flexible ways of
working for colleagues, while enhancing our
tools and encouraging the use of a broader
range of technology.
The range of Smarter Working Options
available to colleagues include: reduced
hours; job sharing; compressed hours;
sabbaticals and career breaks; and, home
working or working from an alternative
office location. In recognition of our
Smarter Working Programme, Permanent
TSB was proud to win the prestigious
CIPD Award for Best Flexible and Hybrid
Workplace during 2022.
We also continually look for areas in
which to improve our cultural evolution
through the Every Voice Counts Employee
Engagement Survey which is conducted
at regular intervals and is designed to
give our people an opportunity to provide
feedback on what is working well across
the organisation, while identifying areas for
improvement.
And of the work is showing up in the
positive response from colleagues with
Permanent TSB’s most recent Every Voice
Counts Survey results indicating a Culture
Index of 80%, +10% above our Culture
Index Target of 70%.
Permanent TSB is also actively involved
in improving culture across the banking
industry as a member of the Irish Banking
Culture Board (IBCB).
Digital Transformation
We have continued to make good progress
on our digital transformation journey
throughout 2022.
As part of our €150 million Digital
Investment programme, we engaged
Kyndral, the world’s largest IT
infrastructure services provider, to
8
advance our digital transformation with
an agile and secure environment that is
built for the future of banking. Supported
by cloud-based functionality, we can now
respond more quickly to changing market
developments and support the evolving
digital needs of its customers. This has
enabled us to launch more personalised
digital offerings, while maintaining strong
security and data protection that enhance
its operational resilience.
Amongst other digital banking
enhancements, over the past year we have
improved our Open24.ie online banking
service, offering customers a modern,
simpler, and quicker desktop experience;
we have enabled new customers to
complete credit card and/or overdraft
applications in minutes through our mobile
app; we have launched new customer-
centric digital mortgage application journey
that combines the best of technology with
a personal touch; and we have launched
a digital application process for new SME
customers to enable SMEs to complete the
majority of account opening requirements
online.
Most recently, we proudly launched the
Bank’s joint digital current account, making
it easy for new customers to open a joint
current account digitally via the Permanent
TSB mobile app.
Outlook
As we look ahead to 2023, I am mindful of
the challenging environment in which we
operate – not least the challenges posed to
our customers by cost-of-living increases
and an environment of higher interest
rates.
These are significant challenges that are
not to be dismissed lightly; however, we
want to reassure customers that we are
here for them and will work constructively
with them to help them through this
difficult phase.
We were proud of the role we played
in supporting customers through the
pandemic and we want customers to
know we continue to be in the business of
matching our words with our actions, with
the goal of earning and retaining their trust
in everything we do.
With the Ulster Bank transaction we are
becoming a bigger Bank and a greater
competitive force, but increased size
and scale will mean nothing if we do not
continue to get the basics right in our
dealings with our existing customers and
those who are new to the Bank.
That is why our priorities continue to be
working to increase the trust, advocacy
and loyalty of our customers; constantly
enhancing our digital capabilities;
strengthening our culture of growth that
is based on being open and inclusive;
making our business simpler, more
efficient and more effective; and always
striving for enhanced profitability based
on sustainable, responsible and ethical
business practices.
I want to echo the comments made by the
Chairman that recognise the enormous
contribution made by our colleagues in
delivering so much in 2022. I am impressed
every day by the quality of the people I am
proud to call my colleagues and I thank
them for the way they put our purpose and
our mission into action – in the way they
serve our customers, help each other, and
contribute so much to making the Bank a
better organisation.
I want to pay tribute to the Chairman as his
term comes to an end and thank him for
the enormous effort he has put in over the
past 6 years. He leaves Permanent TSB
as a much stronger, more inclusive and
more successful organisation. I also wish to
welcome our incoming Chairperson, Julie
O’Neill, who will bring her great experience
and her corporate governance and
leadership skills to the Bank.
I am confident that the strong momentum
that exists in the Bank, spurred on by the
benefits that the Ulster Bank transaction
brings, will continue to drive the Bank
forward and make it an even greater
competitive force.
Despite the challenges that exist, the Bank
is in an excellent position to thrive, for the
benefit of our customers, competition in
the market, the wider Irish economy, and
our shareholders.
Eamonn Crowley
Chief Executive
1 See table 8 on page 52 for a reconciliation of
underlying profit to operating loss on an IFRS basis.
Permanent TSB Group Holdings plc - Annual Report 2022 Market and Regulatory Context
Retail Banking Trends In Ireland 2022
Over the last year we have been working
hard on becoming a bank that brings
technology and people together to make
every day banking easy, and enable our
customers to do big things. As a bank,
we are focused on what’s next and
the opportunities that lie ahead. With
significant structural changes in the Irish
Banking market, Permanent TSB is one
of only three remaining full service retail
banks in Ireland and growing through the
acquisition of certain elements of Ulster
Bank’s retail, SME and Asset Finance
businesses. This provides the Bank greater
scale and enables us to provide stronger
competition in the market, with many more
personal and SME customers, a branch
presence in even more communities
nationwide and a significantly larger
platform for future growth.
To counter the effects of inflation,
the European Central Bank ended the
prolonged period of low interest rates in
2022. The ECB announced a 0.5% increase
in July, a further 0.75% in September,
0.75% in November and 0.5% in December
2022 in the main borrowing rate, marginal
lending rate and deposit rate. This series
of interest rate increases is the first of the
kind since 2011 and resulted in the main
borrowing rate increasing to 2.5%, the
interest rate on marginal lending increasing
to 2.75% and the deposit rate moving from
a negative position of -0.5% to 2% for the
first time since 2014.
The mortgage market continued its strong
growth in 2022. Based on the first 11
months of the year, we expect this data
to show that the 2022 mortgage market
reached €14bn by year-end. Mortgage
Pay-outs across the market are up c.+35%
year on year (YoY) with strong growth
observed across key customer segments.
Notably, there has been significant
growth within the switcher market, with
drawdowns up +116% YoY. This behaviour
has been driven by combination of two
factors: firstly, the impending exit of Ulster
Bank and KBC from the Irish mortgage
market; and, secondly, several ECB rate
increases since July 2022. The current
trend in pay-out growth is expected to
continue into the first half of 2023, driven
by growth in applications and approvals.
Market applications are up +7% YoY, while
market approvals are up +19%. However,
it is expected that the sharp growth will
be stemmed in the medium-term due to
ongoing challenges of the housing market
in Ireland. This, combined with ECB interest
rate increases is anticipated to impact
the level of growth across the mortgage
market.
Permanent TSB is making significant
progress on our digital banking journey
as our customers’ digital expectations
have continued to grow over the course
of 2022. We opened over 113,000 new
current accounts, a 218% increase on the
same period last year. 51% of new current
account openings are taking place through
the bank’s mobile app, as customer
adoption of digital channels increases.
We have also opened over 43,000 new
deposit accounts year-to-date, an increase
of c.87% YoY. Following on from being
awarded best current account by Bonkers.
ie earlier in the year, Permanent TSB also
won the Innovative Banking Product Award
for our digital current account opening
process at the 2022 FS Awards. Permanent
TSB’s innovative digital current account
opening process allows customers open
a current account in minutes via the
Permanent TSB app.
In addition, card payments have increased
21% YoY and mobile payments have
increased significantly to 38m in 2022,
185% higher than 2021.The use of digital
channels continues on the upward
trajectory with over 138m logins on our
Open 24 app where our customers can
complete applications for a Current
Account, Overdraft, Credit Card and Term
Loan. Our App has received over 216k in
customer product applications in 2022..
We continue to deliver directly to our
customers through a combination of Tech
& Touch sales and services through our
nationwide network covering 75 branches
(98 in January 2023), intermediary channel
and digital & voice channels. We continue
to evolve our channel mix by investing
in self-service digital channels while
maintaining the crucial role in-person
channels (branch & voice) plays in on-
boarding, lead generation & supporting
customers that fall off digital journeys. In
2022, we continued to update our digital
capabilities offering current accounts,
mortgages and business banking through
our voice and digital channels.
At Permanent TSB we are committed to
being open and inclusive and providing
the best experience to all of our valued
customers within our communities,
including customers that require additional
assistance. In response to new Assisted
Decision-Making (Capacity) Act (ADMA)
legislation, we have identified customer
needs, benchmarked against industry best
practices and delivered a robust Policy,
Framework and Customer Charter which
ensure we will best meet the needs of all of
our customers.
To conclude, while challenges will continue
to arise in the banking sector, our main
purpose and ambition is to continue to
work hard to build trust with our customers
and work towards a simplified, intuitive
customer experience.
SME Banking Trends In Ireland 2022
The Irish economy is recovering and while
it has been evident the significant impact
of the pandemic on businesses, many are
eager to plan ahead and take advantage
of the returning customer demand in
2022. Key sectors driving growth of new
lending in 2022 have been hospitality,
manufacturing, wholesale and retail. SMEs
are managing their business models well
through innovation and automation, they
are looking at sustainability as a means
to improve business performance. Key
developments in continued delivery of
growth in the sector include schemes
by the Strategic Banking Corporation of
Ireland (SBCI), the Future Growth Loan
Scheme (FGLS) and Brexit Impact Loan
Scheme (BILS) / Covid Loan Scheme
(CLS) schemes. The SBCI loan guarantee
schemes have been helpful in building the
bank’s name in SME market, driving growth
across all existing product ranges.
9
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Market and Regulatory Context
(continued)
Critical challenges being faced by many
SMEs are linked to the tight labour markets
and skills shortages, with 2.6m people
now employed the Irish economy is now
close to full employment. Inflation has
impacted our customers during 2022
and is expected impact 2023 albeit at
a lower level, with growth continuing to
be forecast for the Irish economy, ahead
of most other European economies.
The impact of interest rate hikes by the
ECB are of concern for SME’s seeking
to manage cashflow in 2023.The SME
economy also benefits from the level of
Foreign Direct Investment taking place
in Ireland with Multinational Companies
(MNCs) continuing to invest and grow their
footprint in the only “English speaking”
economy in the EU. Irish SMEs are a
vital piece of the value chains for those
MNC who choose Ireland to do business
in. The settling of recent unrest in the
UK political sphere has provided a more
stable environment should help ease some
pressure however the ongoing impact of
Brexit remains a challenge.
Covid support schemes from the Irish
government were of significant benefit to
SMEs and helped to support employment
across the economy while also assisting
in terms of cash flow management
through the crisis. The current energy
support scheme is a further assistance for
business owners as they seek to manage
the increased energy costs of doing
business in current climate. Permanent
TSB has continued to grow its business
lending activity through the period while
providing timely support to borrowers in
financial difficulty. The Bank increased its
new SME loan activity by 52% in 2022 vs
2021 and the business lending portfolio is
well spread across industry sectors with
continued investment in our capabilities.
During 2022 we continued to invest in our
Business Banking team and now have
an experienced team of specialists in
place to support the market and position
Permanent TSB as one of 3 Business
Banks in the market.
10
Permanent TSB Group Holdings plc - Annual Report 2022 Our Strategy, Business Model and Culture
Our Strategy
2023 represents a new chapter in Permanent TSB’s history, as we complete the acquisition of
€6.7bn of Ulster Bank assets, 25 new branches and welcome ~340 former Ulster Bank colleagues
into our team. Reflecting on three successful years of consolidation and growth, we move forward
with a renewed sense of purpose and determination to serve our new and existing customers and
the communities in which we are based nationwide.
Our Strategy 2020-2022
In 2020, a new Strategy was developed and implemented in Permanent TSB to provide a clear Purpose, Ambition and direction of travel
for the organisation.
Our Purpose
To work hard every day to build
trust with our customers – We are a
community serving the community
Our Ambition
To be Ireland’s Best Personal and Small
Business Bank
Our Values
Customer
Focus
United
Straight-
forward
Courageous
Open
Our Strategic
Pillars
Customer
Profitability
Digital
Simplification
Culture
Over this period (against the challenging backdrop of Covid-19, Brexit and consumer inflation) the Bank has continued to build on and
strengthen its position as a trustworthy, ambitious and reliable competitor in the Irish Retail & SME banking sectors.
Strategy Highlights 2020-22
Customer
Profitability
Digital
Simplification
Culture
• Growing our base to
1.2mn customers
• Major investment
in existing branch
network, and
acquisition of 25
former Ulster Bank
branches
• Award winning
Mortgage and
Current Account
propositions
• Agreement and
• New online banking
• Enterprise
commencement of
acquisition of €6.7bn
of Ulster Bank assets
• NPL ratio of 3.3%
• c.210% growth in
SME lending (FY
2020 vs FY 2022)
platform
• End to end digital
Current Account
• Online mortgage
customer application
journey supported by
CreditLogic
• Launch of Apple and
Google Pay
Transformation
programme, resulting
in savings of c.€18mn
• New Customer
Correspondence
Management
tool supporting
migration to digital
correspondence
• Over 1600
colleagues
participating in
the LIFT Ireland
‘Living As Leaders’
programme
• 68% of colleagues
availing of Smart
Working options
• Launch of
Sustainability
Strategy
As we look to the future with a refreshed set of Strategic Priorities, we reflect in more detail on some of our strategic achievements in
2022.
11
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Our Strategy, Business Model and Culture
(continued)
2022 Strategy Achievements – Customer
We build a deep understanding of our customers with defined strategies for key segments. We develop sustainable
propositions which meet our customers’ needs, supported by fair and transparent pricing. We continuously seek to reinforce
our position with our customers as a recognised and trustworthy brand.
113k
New Current Accounts, a 217% increase YoY
Green Mortgage Product Launched in April
2022, accounting for c.20% of total mortgage
drawdowns in 2022.
The first in a suite of sustainable products &
propositions
€2.6Bn Mortgage Drawdowns
(+40% YoY)
Participating Bank in the government-
backed ‘First Home Scheme’
A shared equity scheme aiming to bridge an
affordability gap by providing first time buyers
with part of the purchase price of their home,
in return for a minority equity stake
3-year, €1Bn loan fund for SMEs
Launched in January
Winner of ‘Best Mortgage for First-Time
Buyers’ and ‘Best Current Account’ awards
at the Bonkers.ie National Consumer Awards
2022
Online Switching Hub launched
to better support customers seeking a move
to Permanent TSB
2022 Strategy Achievements – Profitability
We manage our assets and sustainable capital base in a way which protects and generates value for the Bank and our
shareholders. We embed a cost-aware culture at all levels of the organisation, eliminating wastage where we see it.
Ulster Bank Transaction
Permanent TSB shareholders and the
Competition and Consumer Protection
Commission provide Approval for PTSB
acquisition of certain elements of the
Ulster Bank Retail, SME and Asset Finance
Business in the Republic of Ireland
Underlying Profit for the year of €45m,
increasing from €17m in 2021
Net Fees & Commission income of €42m,
a 20% increase YoY
€5.2Bn Mortgage Assets representing
56k residential mortgage customers,
successfully migrated from Ulster Bank to
PTSB in November
Winners of ‘Best Procurement External
Collaboration Project’ & ‘Best Procurement
Transformation Project’ awards
at the 2022 National Procurement Awards
NPL Ratio of 3.3% at YE 2022
Reduced from 5.5% versus the same period in
2021
12
Permanent TSB Group Holdings plc - Annual Report 2022 2022 Strategy Achievements – Digital
We provide capabilities and propositions for our customers which combine digital with a human touch. We have a robust
digital platform, and continue to focus on renovating and integrating existing systems. Enhanced analytical capabilities
support improved customer engagement and generate customer-focused insights.
New Scalable & Resilient Digital Servicing
Platform launched for customers
with corresponding Mobile Application to
follow in H1 2023
47% of new Current Accounts opened
Digitally, and 94% of Term Lending
Applications completed Digitally
SME Online Current Account application
introduced
c.683,000 active users of Open24 Web
and App, +20% on 2021
c.138 million logins on both Open24 Web and
App, +18% on 2021
‘Innovative Banking Product Award’ winner
for our Digital Current Account
at the 2022 FS Awards
2022 Strategy Achievements – Simplification
We drive end-to-end automation in order to: reduce manual risk; generate resource and capacity efficiencies; and, improve
overall customer and colleague experience. We continuously adapt and improve our internal processes and customer journeys.
1.4m fewer paper statements issued
annually with launch of e-Statements for
Credit Card customers
Launched a streamlined digital application
process for Credit Cards and Overdrafts
113% growth in Robotic Process
Automation outputs from existing
processes
Rollout and Embedding of a new internal
Change Management Model
c.30% efficiency improvement through
enhancements to formal switching process
2022 Strategy Achievements – Culture
We inspire a customer-centric, open, inclusive, risk integrated, growth culture, where diversity is encouraged and celebrated.
We empower all colleagues to develop as leaders, fostering a mind-set of in all teams. We recognise and embrace the role we
play in the community at accountability and risk awareness both a local and national level.
Announced Title Sponsorship of Team
Ireland for the 2024 Olympics and
Paralympics
Over 1300 Nominations received for our
Annual ‘Values In Practice’ (VIP) Awards
Winner of ‘Best Community or Charity
Engagement’ award for the PTSB
Community Fund at the Bonkers.ie National
Consumer Awards 2022
~110 former Ulster Bank colleagues joined
our team in Q4 with a further ~230 to follow
in H1 2023
Launch of Permanent TSB Archive and
heritage website to celebrate and reflect on
over 200 years of banking history in Ireland
68% of colleagues availing of Smarter
Working arrangements…
…Our approach was recognised at the 2022
CIPD HR Awards, with PTSB winning the
‘Best Hybrid and Flexible Workplace’ Award
13
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Our Strategy, Business Model and Culture
(continued)
Looking Ahead – Our Business Model and Strategy 2023-25
Permanent TSB is a full-service Retail and SME bank, operating in the Republic of Ireland. We
provide our customers with a digitally-led experience supported by a nationwide branch footprint,
helping our customers in person when they need our sales support. We offer the right products
and propositions, at the right price, with strong market share in our target segments.
2022 has been a transformational year for Permanent TSB, primarily due to the approval and
commencement of acquisition of certain elements of the Ulster Bank Retail, SME and Asset
Finance Business. The completion of the acquisition in 2023 will mark the beginning of a new
phase in the Bank’s 200+ year history in Ireland.
As a result of the acquisition, and to ensure that we embrace the opportunities afforded to us by
both our own organic growth success to date, as well as the broader exit of Ulster Bank and KBC
from the Irish Retail Banking sector, we refreshed our Strategic Priorities in Q4 2022. Our Purpose,
Ambition and Values remain unchanged.
Our Strategic Priorities 2023-25
Connected
Customer
Experience
Sustainable
Business
Growth
Secure &
Resilient
Foundations
Cultural
Evolution
Target Outcomes
• We have sustainable
business practices and are
committed to real reduction
of our carbon footprint.
• We accelerate and enhance
our customer propositions
through partnerships.
• Data is used to create
insights and to drive our
decision making.
• We deliver consistent returns
for our shareholders by
delivering an exceptional
customer experience.
Target Outcomes
• Our culture is open, diverse
& inclusive, risk integrated,
customer and growth
focused.
• Modern skillsets are forged
and developed internally.
•
We have a technology
enabled workplace which
helps colleagues better meet
the needs of customers.
Target Outcomes
• Our Customers are at the
heart of everything we do.
We offer them the products
and services they need,
when they need them.
• Our services are digitally
enabled with a human touch.
• We are recognised by our
customers as the best
Personal and Small Business
bank, as measured through
NPS and Trust scores.
Target Outcomes
• We have a robust, secure
and resilient operating
environment that protects
our customers and
colleagues.
• A Continuous improvement
and nimble approach to
change allows us to adapt
and learn.
•
Internal and customer
journey processes are
automated and simplified to
the benefit of customers and
colleagues.
14
Permanent TSB Group Holdings plc - Annual Report 2022 Our Culture – Bringing the Lived Experience to Life
We are building a Permanent TSB for
everyone – One PTSB.
At Permanent TSB, every action we take
matters in delivering for our customers and
our communities. Organisational culture
is the expression of our daily behaviour,
demonstrated through our actions and
our words. Regardless of the capacity
in which our colleagues work on behalf
of Permanent TSB, it is about how each
person shows up and commits, each day,
every day, irrespective of their role or
function.
Our culture is made up of our Purpose,
Ambition and Values. Our Values are
articulated through behaviour articles. Our
Values are lived through our behaviours
and the way colleagues work together, with
our customers and our community. It is
how we handle day-to-day operations, our
everyday communication and tasks that
create the PTSB atmosphere.
Our culture is dependent on the actions
of every single person in Permanent
TSB; from the senior team to our most
recent joiners. What we do – and how we
do it – really matters. Our actions make
us a sustainable organisation, safeguard
us for the future, and help develop and
maintain trust between each other and
with our customers. Culture does not stay
static; it evolves and it changes through
thousands of small daily interactions. It is
a living thing, and it is something for which
every single one of us at Permanent TSB is
accountable.
2022 represented a landmark moment
in the history of the Bank, as we started
to welcome hundreds of new colleagues
and thousands of new customers through
the acquisition of various elements of
Ulster Bank. From the outset, the cultural
migration strategy for this once in a
generation opportunity, was to integrate
our new colleagues into the Bank, and
create a ‘One PTSB’ ethos as we move
forward together to deliver on our Purpose
and Ambition. The overarching principle
of our approach was to, and will continue
to be, to live our Purpose, by working
hard every day to build trust with our
new colleagues and customers. The
design of our culture approach focused
on creating alignment and being open to
new ideas and ways of working; listening
to understand what differentiates and
unites us, and bringing the best elements
of both organisations, as we move forward
together.
Our culture is made up of many sub-
cultures; whether that be from our
heritage, various acquisitions and mergers,
geographies, or the different leadership
styles. We aspire for a consistent cultural
experience for all colleagues at Permanent
TSB. We want a culture that preserves
all the positive elements of our heritage,
whilst actively changing any poor habits
and behaviours that do not align to
our Values. We have been proactively
committed to improving our culture since
2015, and as we look forward, our goal
for culture remains to preserve those
positive aspects of the culture that makes
us unique, whilst altering any habits
and behaviours that impede both the
re-building of trust in the Bank and the
delivery of Purpose and Ambition.
Everything we are doing to improve
our culture comes down to one simple
goal – Creating Psychological Safety.
Psychological safety is a belief that
one will not be punished or humiliated
for speaking up with ideas, questions,
concerns or mistakes. By building a Bank
where you can be yourself, where you can
be at your best, where your contribution
is encouraged and valued, and where you
are welcomed, respected, recognised and
supported, we will consistently deliver
ethical decision making, fair customer
outcomes and risk integration and
management in everything that we do.
At the heart of our culture
is our Purpose and our
Values.
We are building a culture
of trust.
Our Purpose is to work hard every day to build trust with our customers, and this trust is earned
by how each of us live our Values each day, every day. The more we consistently live our Values
through our behaviours, the further we progress in building trust with our customers.
A culture where we work hard to live our Values every day through our actions and our words.
Trust is the foundation of all relationships. Real and genuine trust is the single most important
element of any relationship, personal or professional. It is our privilege to be the trusted custodian
of our customers’ financial wellbeing and our ability to demonstrate to our customers that we
consider their interests in all that we say and do is at the heart of our customer promise.
We want to make our
culture simple and clear to
understand.
We launched Our Culture Charter across the organisation as our guiding compass. It brings
together the core elements which make up our culture, what we want our culture to be, as well as
the 12 culture enablers which will support our journey.
We have distilled the message down to a single page so that regardless of function or role, every
colleague has the same understanding of our culture, and how they can help build a Permanent
TSB for everyone.
15
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Our Strategy, Business Model and Culture
(continued)
2022 Culture Reflection
We are building a responsible & sustainable business to deliver for our customers, colleagues & communities. We are committed to
building on the cultural improvements made and sustained, and to achieve our cultural ambition to have a customer-centric, open,
inclusive, risk integrated, growth culture characterised by integrity, innovation and accountability.
We are making improvements to our culture:
Our Purpose and Values continue to
resonate with colleagues
We have improved our culture Index
Gender Pay Gap
We have been awarded the Silver
accreditation from the Irish Centre
for Diversity.
• Over 90.5% of colleagues tell us that they understand our Purpose and Values.
•
It is 80% (+9%); however we have inconsistencies by function that must be
addressed (Source: Every Voice Counts 2022).
• Permanent TSB reported a Gender Pay Gap (GPG) of 17.5%, December 2022 (re.
June 2022 Data). Year-end Permanent TSB continues to make progress reporting
a 1% improvement in GPG to 16.5% (December2022). Permanent TSB has set out
a suite of initiatives to improve GPG, including an ambition to achieve 50:50 Male,
Female participation at Senior Leadership levels and above by 2025
• Building on our maturity status of Awareness in 2020 (assessed by an external
independent third party), we were awarded the Silver accreditation from the Irish
Centre for Diversity in 2022. We continue to make progress towards becoming a
more inclusive organisation with an ambition to achieve the highest standards of
accreditation "Gold Investors in Diversity" within the life of the DEI Strategy 23 - 25.
We have increased Trust in our Bank
• 81% of colleagues Trust PTSB to do the right thing (up 15%) (Source: Every Voice
Counts 2022).
• We won the CIPD Award for Best Flexible and Hybrid Workplace.
Our colleagues have told us that our
Purpose and Values resonate strongly with
them (90.5% of colleagues understand
our Purpose and Values [EVC 2022]).
Colleagues understand their role and want
to serve customers, and they believe that
the leadership team is moving the Bank in
the right direction.
Making Permanent TSB a Place for
Everyone
Living our Values builds trustworthiness,
honours our customer promise and
is central to how we will achieve our
Ambition to be Ireland’s best personal
and small business bank. We will enable
this by nurturing an open and welcoming
environment where colleagues can
safely be themselves, their best selves.
An environment where colleagues are
respected, heard, valued and recognised
for their contribution. A psychologically
safe environment, where colleagues
feel safe to speak freely without fear
of negative consequences and where
diverse thinking leads to constructive
debate. In building a culture of trust, we
will consistently deliver ethical decision
making, fair customer outcomes and
integrate risk management into everything
that we do.
16
Permanent TSB Group Holdings plc - Annual Report 2022 We want to create an open and inclusive environment where colleagues are able to relate to, and connect with, customers and each other
in a meaningful way, with innovation, responsiveness and reassurance at the core of our positive impact.
Purpose
To work hard every day to build trust with our customers - We are a community
serving the community.
Ambition
To be Ireland’s best Personal and Small Business Bank.
Our
Values
Lived Every Day through Our Behaviours
Customer Focus
We take due care and
consideration for our
customers always.
Courageous
We Speak Freely
without fear of negative
consequences &
welcome diverse
perspectives to mitigate
group think.
United
We reinforce
accountable
leadership through
our behaviour.
Open
We innovate and
continuously
improve.
Straightforward
We aim to get it right
first time every time.
We have continued to focus on improving our culture by embracing the enablers and being committed to identifying and over-coming the
blockers. Our dynamic culture diagnostic, enables us include transparent tracking, measurement and reporting of Engagement, Culture
and eNPS on a sustained basis as part of our Risk Appetite.
We have 12 cultural enablers
which help shape and guide
our cultural journey, and
include:
Living as Leaders - Join the
Conversation
2022 marked the third year of our
partnership with LIFT Ireland (Leading
Ireland’s Future Together). Our Living as
Leaders Programme is designed to support
colleagues in role-modelling our Values
through their actions and words aligned to
our Purpose and Values. Since we launched
the Living as Leaders Roundtables
in 2020, over 1600 colleagues have
participated. This programme isn’t about
titles or positions; it’s about embracing
a growth mind-set and being open to
improving how our colleagues do things
for themselves, each other, our customers
and our communities. We believe that
the consistent actions and behaviours of
everyone, every day is essential in creating
a better future for one another and for our
Bank. Our Living as Leaders Programme is
part of our culture enabling initiatives, and
is included in our Induction Programme for
all new joiners.
LIFT Ireland is a Not for Profit Organisation
with a vision to make Ireland a better
place to live by creating better leaders
across our society and in our communities.
LIFT’s philosophy aligns closely with that
of Permanent TSB’s, as they believe that
each of us is a potential leader; whether
that is within our families, our peer groups,
our schools, our sports teams or our
businesses. LIFT believe that by developing
personal leadership qualities within each
individual, we can develop a generation of
stronger and better leaders.
We are further expanding on our
partnership with LIFT Ireland to become
one of five sponsors of their ‘Changing
Futures for the Better – Schools Initiative’
for the next three years. LIFT are already
active in one third of Ireland’s secondary
schools (over 230) where students and
teachers have adopted the LIFT Ireland
Programme, and the programme will
see this presence grow to 700 schools
nationally (over 370,000 students across
Ireland every year).
“The standard and quality of
Leadership, true leadership
at every level, is fundamental
to navigating all of us and our
business to a better place.
Leadership isn’t about a title,
the level you are at, length of
service or the size of the office,
Leadership is the creation of
positive energy to bring about
an outcome that otherwise
would not have happened”.
Ger Mitchell
Chief Human Resources and Corporate
Development Director
“Permanent TSB has been a proud partner of LIFT Ireland since
2020. Trust is at the heart of our purpose, which is to work hard
every day to build trust with our customers. This trust is earned
by every decision and action we take. This is demonstrated
by how our colleagues live our Values each day, every day. We
believe that the more we consistently live our Values through
our behaviours, the further we will progress in building trust with
our customers as the Permanent TSB community serving the
community. Colleagues from every function, and all levels across
the Bank, participate in LIFT roundtables, reflecting on our
behaviour which help us to consistently role-model our Values
through our actions and words by living as leaders every day.”
Eamonn Crowley, CEO
17
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Our Strategy, Business Model and Culture
(continued)
to show their commitment to creating
psychological safety by encouraging a
mind-set shift from awareness to action
and personal accountability. As part of
our ongoing series of communications
surrounding Speak Freely and through
our Every Voice Counts – ‘Speak Freely’
Micropulse, colleagues had asked us to
provide examples of Speak Freely concerns
raised and the actions taken as a result.
In response, we developed a series of
illustrations based on actual Speak Freely
concerns which occurred in the past to
help explain how the concern was raised,
what happened and the ultimate result.
The spokesperson in this illustration is
Saoirse, meaning ‘freedom’ in Irish.
To continue our embedding plan in 2022 we
delivered a number of initiatives to further
educate, track and highlight examples of
speaking up, including:
• Training People Managers and Speak
Freely Champions on Speak Freely and
Protected Disclosure procedures, and
colleague conduct.
• Completion of Colleague Conduct
Training by all colleagues which included
further awareness and focus on Speak
Freely.
• Embedding of the Irish Banking Culture
Boards’ DECiDE Framework on ethical
decision making,
• Regular Reporting on Speak Freely
concerns to the Board, and
• Developing and sharing of Speak
Freely Management Information with
colleagues and acting on feedback from
the bank-wide Every Voce Counts and
‘Speak Freely’ Micro-Pulse survey and
subsequent focus groups.
Speak Freely – Change Behaviour By
Starting The Conversation.
Our goal is to evolve our culture to ensure
that our colleagues feel psychologically
safe and empowered to share their voice.
As an organisation, we are striving to
grow a Speak Freely environment where
it is safe and acceptable to raise genuine
concerns about practices, processes or
behaviours that do not meet our standards
or align with our Purpose. Our progress in
creating this culture is measured through
our Every Voice Counts (EVC) Survey
and our Micropulse survey which ask the
question “where I work, people can share
their opinion without fear of negative
consequences”, which showed a 9.3%
Year on Year increase in our EVC scoring to
76.4% and 11% increase in our Micropulse
scoring from 2021 to 2022. In addition we
monitor the usage of the Speak Freely
procedure and include this in our KRI
reporting, which particularly focuses on
a key indicator of trust – that colleagues
feel confident to raise concerns in a non-
anonymised manner.
Our Speak Freely Procedure protects
colleagues who wish to raise a concern or
to make a protected disclosure, relating
to actual or potential wrongdoing in the
workplace, and ensures that they can
do so without any fear of retribution or
penalisation. We have a number of different
channels through which a concern can be
raised. The Bank has in place procedures
to deal with any protected disclosures
that may arise as part of Speak Freely and
reports to the Executive Committee and
Board on a half yearly basis. In 2022 we
also updated our Speak Freely Procedure
and Protected Disclosures procedure to
ensure compliance with the new Protected
Disclosure (Amendment) Act 2022. Our
“Speak Freely Pledge” invites colleagues
18
Ways of Working (Hybrid Flexible
Working)
In 2020 the Bank introduced a Smarter
Working Programme to enable optionality
and to provide more flexible ways of
working for colleagues, while encouraging
the use of a broader range of technology at
all levels of the organisation.
Through our Flexible and Hybrid Working
programme, we sought to create a
reimagined, customer-centric Permanent
TSB work environment which fits our
strategic design criteria across the
areas of Organisational Design, Property,
Technology and New Ways of Working.
Our Smart Working Framework includes a
range of options available such as: reduced
hours; job sharing; compressed hours;
sabbaticals and career breaks; home
working or working from an alternative
office location.
Over 68% of colleagues have opted for
Smarter Working in the Bank. To support
smarter working, we have rolled out a
number of initiatives to enable adoption
including Infographics, Team Commitment
Charters, Collaboration Zones, Colleague
Kit Personas and Kits, new Ways of
Learning, a No Meeting Slot and Working
Abroad proposals.
Hybrid Workplace 2022
The Hybrid Workplace was agreed
as a consistent standard for roll-
out, with a strong commitment to
Flexible and Smarter Working
wherever possible
33
office buildings have
been transformed into
a flexible Hybrid
Workplace
11,,335599
flexible desks
setup for
colleagues to
use
880000
new end-user devices
(VDI & laptop) rolled
out to colleagues
3322
Meeting rooms
setup to cater for
Hybrid Meetings
11,,888855
colleagues now
using the Hybrid
Workplace
Hybrid Workplace Guidance and
Management Toolkit to People Managers
was released on Workvivo & Connect
We will continue to evolve and
improve our flexible offering to
create a modern workplace.
Permanent TSB Group Holdings plc - Annual Report 2022
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thank you every day. With over 1,300
nominations received, 2022 marked the
highest level of recognition to date since
the Value In Practice (VIPs) Annual Awards
were launched five years ago. Colleagues
from all across the organisation were
recognised by their peers under our five
‘Values’ categories, and the additional
categories of Community Impact Award
and Living as Leaders Award. There have
been 1,434 VIP Everyday’s sent in 2022,
which have been received by over 950
colleagues.
The Irish Banking Culture Board
(IBCB)
The IBCB is an independent industry
initiative, established in 2018 and funded
by the five retail banks in Ireland, with the
aim of rebuilding trust in the sector through
demonstrating a change in behaviour and
overall culture. As one of the five member
banks, Permanent TSB is committed to its
mission of re-building trust in the banking
sector by delivering a positive change in
behaviour and overall culture.
In 2022, the Bank has continued to support
the IBCB’s programme of work, including
colleague participation in focus groups for
the Pride in Banking Report. Permanent
TSB has further supported the roll-out
of the IBCB’s DECiDE (Ethical Decision
Making) framework, as part of our Code
of Ethics. The DECiDE framework acts as
a practical guide and tool for colleagues,
regardless of level, when making difficult
decisions on a day to day basis. We have
developed and launched a Permanent
TSB DECiDE video to support colleagues
in a better understanding of the DECiDE
framework and how it can be used to help
them navigate their way through difficult
decisions.
In September 2022, the IBCB launched the
Pride in Banking Report. Pride was raised
as a key area of focus following the 2021
IBCB éist staff survey, which highlighted
that staff have a lower sense of pride
working in banking (57% across the sector,
compared with PTSB which scored 68%),
when compared to the global financial
services benchmark (- 16% points). The
Pride in Banking report focused on staff’s
ability to feel ‘Proud to Work in Banking’
and found that bank staff must be able to
feel proud of the work that they do and of
their industry. The report also highlighted
that whilst it is important that the industry
is learning lessons from the mistakes of the
past, it is also crucial that there is a more
balanced discourse on an industry that has
changed significantly in recent years, and
which is integral to economic success.
Throughout 2022 we have continued to
evolve our Flexible & Hybrid Workplace
to a work environment that is fit for now,
and fit for the future, enabling improved
flexibility and choice for a great colleague
experience. There are three dimensions of
the Flexible & Hybrid Workplace that we
consider, cohesively integrate, coherently
communicate and consistently monitor
through adoption and embedding: Physical
Dimension [Where we work], Digital
Dimension [Tools for work] and Behavioural
Dimension [How we work].
Whilst we are enabling the Flexible &
Hybrid Workplace in 2022, this is only
the start of the journey for the Bank. The
Workplace Value Proposition demonstrates
the importance to the workforce, and the
Bank as a whole, in continuing to invest
in our flexible work environment, with
the aim that colleagues will have the
best experiences at work, and perform to
the best they can, both individually and
collectively as a team.
In recognition of our ‘Flexible & Hybrid
Workplace’ programme, Permanent
TSB won the prestigious CIPD Award for
Best Flexible and Hybrid Workplace in
2022. We have continued this journey of
empowerment and embedding of our ways
of working through ongoing education
and awareness through induction training,
people manager toolkits and Hybrid
workplace training.
As the world of work continues to evolve
and the pace and impact of digitisation
continues, we are placing our customers,
colleagues and communities at the centre
of our decision making to ensure that we
continue to build trust and make a positive
impact in their lives.
Values in Practice Awards
At Permanent TSB we are fostering a
culture of recognition, enabling colleagues
to recognise each other from across the
organisation who are living the Bank’s
Values and are making a positive impact
to our business, our customers and
our community. We have two different
‘Values In Practice’ or ‘VIP’ recognition
programmes available to celebrate the
great examples of colleagues living our
Values in work and in our communities;
1) Annual VIP Awards (which enables
colleagues to recognise the outstanding
contribution of individuals during a fixed
nomination period), and 2) VIP Every
Day Recognition (which is available all
year around enabling colleagues to say
19
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 over-coming blockers. In order for us to
have the culture we want, we need to build
it together, step by step, with Trust and
Psychological Safety at the core.
We are building a Permanent TSB for
everyone. One PTSB.
Our Strategy, Business Model and Culture
(continued)
• Risk Integration: Promoting risk culture
& integration to ensure fair customer
outcomes across the Bank, by providing
colleagues with the right supports and
tools, and incorporating risk integration
into all aspects of our behaviour and
actions.
• Strong Stakeholder Engagement:
Continuing proactive engagement
with all our stakeholders to align our
colleagues, customers and communities.
• Quality Communications (Internal):
Leveraging our new internal
communications platform, WorkVivo,
to connect with our colleagues on
key messages. We will continue to
embed Our Culture Charter across the
organisation to ensure consistency of
understanding and alignment on our
strategy.
• Reputation Management (External):
Proactively engaging and managing
our reputation in the market to build a
responsible and sustainable Bank for the
future.
• Brand: Achieving our ambition of
becoming Ireland’s best personal
and small business bank by having a
distinctive and relevant positioning in the
market.
• Culture Measurement: Leveraging our
culture diagnostic to deliver actionable
insights to support the delivery of our
Purpose and Ambition.
• Cultural Integration: Stimulating our
Culture with the best of all acquired
businesses “ways of doing things” in
evolving our culture to deliver on our
ambition.
Making a positive and lasting impact in
our customer’s lives has been at the core
of Permanent TSB throughout our over
200 year history. 2023 will mark another
milestone in our journey as we collectively
work hard every day to build trust with our
customers. To build trust we are committed
to being relevant and to demonstrate
significant cultural change for our
customers, colleagues and community.
We are making improvements to our
culture. We are doing a lot, and have more
to do to ensure that every colleague has a
consistent culture experience regardless
of their role, function, location or way of
working. We are committed to improving
our culture by embracing enablers &
Permanent TSB has led out on sharing of
best practice with other member banks
on initiatives including speaking up and
colleague recognition. We look forward to
continuing our work with the IBCB in 2023
and beyond, as we work hard to re-build
trust in the banking sector together.
Culture in 2023 and Beyond
We are committed to living our Values
every day, as they orient our behaviours
and guide our decision making. We will
continue our culture journey in 2023, to
support the delivery of our Purpose and our
Ambition by creating an Open, Inclusive,
Risk Integrated, Growth Culture, one that is
characterised by accountability, innovation
and integrity.
Our key activities to continue our culture
evolution will include:
• Living as Leaders: Partnering with LIFT
Ireland to continue the roll-out of our
Living as Leaders Programme to embed
our purpose, Values and Leaderships
Behaviours for all colleagues at
Permanent TSB.
• Speak Freely: Continuing to embed
communications, training and awareness
initiatives to create an environment
where colleagues feel psychologically
safe and empowered to share their voice
and have increased trust in the process.
• Diversity, Equity and Inclusion: Creating
a more inclusive Permanent TSB, and
continuing to nurture an environment
and culture where colleagues can
bring their best self to work, safe in the
knowledge that they are welcomed and
encouraged to share their voice and
views as we seek to progress to the
highest standards of accreditation with
the Irish Centre for Diversity within the
life of the Diversity, Equity and Inclusion
Strategy 23 - 25.
• Smart Working Framework: Embracing
a flexible and modern workplace of the
future, and continuing to assess and
evolve our colleague offering, to ensure
that they have the tools, technologies,
supports and flexibility for hybrid work.
• Wellbeing: Supporting our colleagues
in bringing their best selves to work,
improving the colleague experience and
creating a resilient workforce.
• Customer Focus: Building trust-based
relationships with customers with due
care and consideration always, and
making a difference in the lives of our
customers.
20
Permanent TSB Group Holdings plc - Annual Report 2022 Sustainability
Our Commitment To Building
A Sustainable Business
‘Sustainability is about more than just being green. For us, it is about doing everything
we can to support our customers, colleagues and communities, while ensuring that we
conduct and manage all areas of our business in a responsible way.’
Eamonn Crowley, Chief Executive
Our Impact In Action
A Board approved
Sustainability Strategy
aligned to the Sustainable
Development Goals
(SDGs)
Signature to the Task
Force on Climate-related
Financial Disclosures
(TCFD)
83% reduction in scope
1 and 2 carbon emission
intensity, a cumulative
reduction since 2009
c.€600,000 in financial
contributions to Irish
community organisations
in 2022
Accreditation to the
‘Business Working
Responsibly Mark’
A commitment to growing
our branch footprint
by 30% to 98 locations
nationwide
• An increased focus on Climate Risk Management
with the development of a Climate-Related and
Environmental Risk Action Plan
• Signature to the ‘Low Carbon Pledge’, committing to
setting science-based carbon emission reduction
targets (SBT’s) by 2024
• Disclosure of our carbon impact across Scope 1, 2 & 3
• Launch of the Bank’s Green Mortgage*, with c.€500
million in green lending drawn down during 2022
• A CDP rating of C, indicating an awareness level of
engagement
• Founding member of the International Sustainable
Finance Centre of Excellence
• A Sustainability Committee and a Permanent TSB
Green Team
• €250,000 donated to UNICEF Ireland and the Irish Red
Cross to support the Ukrainian relief efforts
• 7,000 financial reviews completed last year, supporting
customers in taking control of their financial future
• A partnership with DCU Access Programme
• A 6-year partnership with Social Entrepreneurs Ireland,
tackling some of Ireland’s most important social issues
• A 3-year partnership with Ó Cualann Cohousing
Alliance, supporting the development of affordable
housing schemes in communities across the country
• Announcement of the Bank’s Title Sponsorship of the
Irish Olympic Team and the Irish Paralympic Team for
Paris 2024
• Winner – Best Community or Charity Engagement
for the Permanent TSB Community Fund, Bonkers
National Consumer Awards, 2022
21
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Sustainability
(continued)
Our Impact In Action (continued)
42% Board Gender
Composition
38% of Senior Leadership
Positions are filled by Women
89% of employees feel
comfortable to be themselves
at work regardless of
background or life experiences
The first Irish Retail Bank
to be awarded the Guaranteed
Irish Symbol, recognising
our contribution to local
communities across the
country
€150 million investment in
technology infrastructure and
digital services over the last
number of years
• Winner – Best Flexible and Hybrid Workplace,
CIPD Awards, 2022
• 2.6 training days delivered per employee
last year, with more than c.458 employees
enrolled in banking education programming
Partnered with LIFT Ireland to deliver ‘Living
as Leaders’ to more than 1600 colleagues,
bringing our Values to life
• c.1,300 nominations to our Values In Practice
(VIP) Awards, the Bank’s colleague recognition
programme
• A Diversity and Inclusion Strategy supported
by 4 Employee Resource Groups – LiveWell,
PRISM, DiCE and Better Balance
• 80% Culture Index Score
• 16.5% Gender Pay Gap
• +10 Relationship Net Promoter Score**
(RNPS), placing Permanent TSB in third
position among the retail banks in Ireland
• A focus on €1 billion in SME lending over the
next three years
• Broadening our Business Banking offering
through partnerships with Bibby Financial
Services, the Strategic Banking Corporation of
Ireland, Digital Business Ireland and Worldpay
• €30 million committed to branch
refurbishments in our Retail Network, with
a further €25 million investment in the 25
branch locations that the Bank acquired as
part of the Ulster Bank transaction.
• A Digital Current Account and Digital
Mortgage Application Journey
• A focus on cyber security and data protection
with training delivered to all colleagues
* A 5-Year Fixed Product available to all new and existing home loan customers where their homes have a confirmed or proposed Building Energy Rating of A1 to B3.
** A Relationship Net Promoter Score (RNPS) is a measure of customer advocacy towards a brand and indicates the willingness of a customer to recommend a company’s
products or services to others. The question asks customers how likely they are to recommend their bank to friends or family on the basis of their own experience. The range
for the scoring is -100 to +100.
22
Permanent TSB Group Holdings plc - Annual Report 2022 Increasing Our Focus On
Sustainability
The global climate crisis has elevated the
sustainability agenda not only in Ireland,
but around the world. We see it in the
continued shift in consumer trends and the
growing demand for sustainable products
and services – not just in the financial
services industry, but more broadly across
other sectors. The conversation is only
getting started. Now more than ever
businesses, such as Permanent TSB, have
a significant role to play in supporting
our stakeholders to navigate the green
transition and to embrace the opportunities
that sustainability brings.
Our purpose is to work hard every day to
build trust with our customers – we are
a community serving the community.
Our Sustainability Strategy gives us an
opportunity to put our purpose into action
- enabling us to play our part in addressing
the global climate crisis, elevate our social
impact, enhance our culture, and deliver
what matter most to our customers
and colleagues. Ultimately, building a
sustainable organisation that is fit for the
future.
Sustainability is about more than just being
green. For us, it is about doing everything
we can to support our customers,
colleagues and communities, while
ensuring that we conduct and manage all
areas of our business in a responsible way.
both quantitative and qualitative tools and
was completed across the following three
phases:
Of course, we can only do that if we are
focused on the right things. As part of the
development of our Sustainability Strategy,
we engaged stakeholders to complete a
materiality assessment to support us in
identifying the Environmental, Social and
Governance (ESG) issues that are not only
material to our business, but important to
our stakeholders
Engaging with our Stakeholders
Through a Materiality Assessment
At Permanent TSB, we recognise that
building strong relationships with our
stakeholders, and ensuring that we engage
with them regularly, plays a fundamental
role in informing our Business Strategy. It
guides our reporting, allows us to identify
risk and emerging trends, while helping
us to prioritise investment and resourcing
- ultimately, enabling us to conduct and
manage all areas of our business in a more
sustainable way.
In 2021, we engaged our stakeholders
to conduct an exercise in materiality.
The assessment was undertaken by an
independent third party to ensure complete
confidentiality and impartiality. It used
Phase 1 – Conducting Desktop Research
And Developing A Survey
Phase 2 - Assessing Stakeholder
Engagement Needs
Phase 3 - Identifying Materiality
As part of the process, we worked with the
third party to compile a longlist of topics
that are material to our business. These
topics were comprehensive and wide
ranging.
Using the longlist of topics, our
stakeholders were asked for their
perspectives on what they felt were the
most important issues that the Bank
should be considering. Stakeholders were
also invited to put forward any topics that
may have not been represented on the list
in order for us to capture a holistic view.
c.200 of our stakeholders participated in
the materiality exercise.
Permanent TSB’s
Materiality Matrix
The findings of the materiality
assessment were consolidated
to form a materiality matrix,
with the position of material
issues being plotted relative
to the degree of stakeholder
importance and potential
business impact.
It is important to note, that
the 20 issues that were
deemed as being material
to our stakeholders, are also
considered as important areas
of focus for us at Permanent
TSB, regardless of their
position within the matrix.
As such, each material issue
has been given representation,
in one form or another, in our
overall Sustainability Strategy.
l
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Impact On Permanent TSB
Customer
Wellbeing &
Literacy
Accessibility
Of Products &
Services
Cyber Security
Corporate
Governance,
Compliance & Fair
Business Conduct
Climate Risk Management
Customer Trust
Digital Transformation
& Innovation
Community Investment
Social Issues
(Social & Affordable Housing)
High Quality Products
& Superior Customer
Experience
Carbon Footprint
Employee Development
Employee Wellbeing
Sustainable Products
& Services
Branch Presence
Sustainable Profitability
Sustainable Procurement
Supporting SMEs
Data Protection
Diversity & Inclusion
Environmental Impact
Social & Community Impact
Economic Impact
Purpose & Culture
23
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Sustainability
(continued)
Our Sustainability Strategy
The materiality assessment findings and associated stakeholder insight have played an important role in the development of an
overarching Sustainability Strategy for the organisation across 4 key areas.
Sustainability Strategy
4 Key Areas
Of Focus
We’re
Committed
To
Addressing
Climate Change
& Supporting The
Transition To A Low
Carbon Economy
• Managing Climate Risk
• Delivering sustainable
products and services
• Ensuring responsible
procurement practices
• Minimising our
carbon impact and
managing our wider
environmental
footprint
Elevating Our
Social Impact &
Connecting With
Local Communities
Enhancing Our
Culture & Investing
In Our People
• Maintaining our
branch presence
• Enabling accessibility
of our products and
services
• Encouraging customer
financial wellbeing and
literacy
•
Investing in local
community initiatives
• Encouraging the right
cultural behaviours
• Embedding our values
and creating a culture
of ‘Speaking Freely’
• Focusing on Diversity
•
and Inclusion
•
Investing in employee
learning and
development
Championing
Our Customers &
Creating A Bank
That Is Fit For The
Future
• Delivering high quality
products and a superior
customer experience
• Supporting our Business
Banking customers
Investing in digital
transformation and
innovation
• Ensuring cyber security
• Managing data protection
• Delivering long-term,
sustainable profitability
• Ensuring transparency
• Addressing social
• Fostering employee
through reporting
issues, such as social
and affordable housing
wellbeing
OUR STRATEGY IS UNDERPINNED BY
Living Our Purpose And Ensuring Strong Corporate Governance, Compliance And Fair Business Conduct
The 6 United Nations Sustainable Development Goals (SDGs) At The Core Of Our Strategy
The Sustainable Development Goals
The United Nation’s Sustainable Development Goals (SDGs) were launched in 2015 to provide a plan of action for people, planet and
prosperity. The 17 goals act as an urgent call for action for countries to work together to develop strategies to tackle some of the world’s
most critical issues.
While we recognise that we may contribute to all 17 SDGs in some way, the following 6 have been identified as being core to our Strategy.
Ensure inclusive and
equitable quality
education and promote
lifelong learning
opportunities for all
Achieve gender equality
and empower all women
and girls
Ensure inclusive and
sustainable economic
growth, employment and
decent work for all
Make cities and human
settlements inclusive,
safe, resilient and
sustainable
Reduce inequality in and
among countries
Take urgent action to
combat climate change
and its impacts
The following is a summary of progress made under each of the 4 pillars of the Bank’s Sustainability Strategy during 2022.
24
Permanent TSB Group Holdings plc - Annual Report 2022 Addressing Climate Change &
Supporting The Transition To A Low
Carbon Economy
Overview
The Bank recognises our environmental impact and is mindful
that making a positive contribution to the economy through
consideration of environmental issues across each channel
of our organisation is fundamental to running our business in
a responsible and sustainable way. In order to achieve this,
we are focussed on: managing climate risk; supporting the
transition to a low carbon economy; and, taking action to reduce
our own environmental footprint, while continuing to disclose
transparently.
Impact In Action:
An increased focus on
Sustainability and Climate
Risk, with the introduction of
a Sustainability Strategy for
the Bank and the development
of a Climate-Related and
Environmental Risk Action
Plan
A Sustainability Committee
and a Permanent TSB Green
Team
A CDP rating of C, indicating
an awareness level of
engagement
Committing to setting
science-based carbon
emission reduction targets
(SBTs) by 2024
83% reduction in Scope 1 and
2 carbon emission intensity,
a cumulative reduction since
2009)
Launching the Bank’s Green
Mortgage, with c.€500 million
in green lending drawn down
during 2022
International Sustainable Finance
Centre Of Excellence
In 2022, Permanent TSB was pleased to
announce our founding membership to the
International Sustainable Finance Centre
of Excellence, a key output of Ireland’s
Sustainable Finance Roadmap.
Headquartered in Dublin, the new
Centre will be focused on the practical
acceleration of the sustainable finance
agenda at a policy, regulatory and market
level.
Fully aligned with the ‘Ireland for Finance
Strategy’; the Irish Climate Action Plan;
and, the EU’s Renewed Sustainable
Finance Strategy it will lead on research,
talent development and leadership
activities to support the design and
implementation of innovative financial
solutions to facilitate the transition
to a net-zero economy in Ireland, and
internationally.
In addition, the Centre will play a critical
role in delivering the Sustainable Finance
Roadmap – which was co-created by
Sustainable Finance Ireland, the UN-
convened FC4S and Skillnet Ireland,
in collaboration with key stakeholders,
including Permanent TSB – and the Ireland
for Finance Strategy which aims to position
Ireland as a global centre of sustainable
finance by 2025.
We know that collaboration amongst the
financial services sector will be critical
for success, as we continue to navigate
this next, and very important chapter. The
Centre will provides an opportunity for
member organisations to work together
collaboratively to develop meaningful
solutions that will deliver a lasting impact.
Climate Risk
We are conscious of the effect that climate
change has on the Bank and view it as
manifesting itself in two ways, firstly,
through the operations of our business and
secondly the financial risk it brings to the
economy in the longer term.
Climate Risk is a key area of focus for
Permanent TSB and is an integral part
of the Bank’s Sustainability Strategy
under the ‘Addressing Climate Change &
Supporting the Transition to a Low Carbon
Economy’ Pillar.
We made good progress in 2022, including:
• Developing a Climate-Related and
Environmental Risk (CR&E) Action Plan;
• Establishing a Climate Risk Framework;
•
Introducing a Climate Risk Appetite
Qualitative Statement within the Risk
Appetite Statement;
• Developing a CR&E Risk Business
Environment Analysis Report;
• Completing a Climate Risk Stress Testing
analysis;
• Building CR&E Risk data requirements
and completing work to understand the
availability of data;
• Defining Climate Risk metrics to be
considered for development;
•
Integrating CR&E Risk into the Bank’s
Strategic Planning Process;
• Delivering CR&E Risk training to the
Board and Senior Leadership Team;
• Launching the Bank’s Green Mortgage
to support stakeholders in navigating the
green transition;
• Participating in CDP and achieving an C
rating; and,
• Measuring and disclosing our carbon
impact across Scope 1, 2 and 3.
Climate Change presents both risks and
opportunities to meet new customer needs
for Permanent TSB and we are preparing
for both with a dedicated programme
of work in place under our CR&E
Implementation Plan.
You can read more about our commitment
to Climate Risk on page 71.
25
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 We will continue to disclose our carbon emissions though our annual reporting process,
TCFD Report and as part of CDP each year.
Taxonomy Regulation
In accordance with Article 8 of the EU Taxonomy Regulation and the underlying
Disclosures Delegated Act, Permanent TSB is required to disclose the proportion of
taxonomy-eligible and taxonomy non-eligible activities related to the environmental
objectives of climate change adaptation and climate change mitigation for year-end 2022.
The Disclosures Delegated Act came into force on 1 January 2022. As the Bank continues
to develop an accurate classification of assets to adhere to this taxonomy and other
climate related disclosures, we have assumed that all covered assets are non-eligible for
the purposes of this disclosure. The percentage of eligible activities is therefore expected
to increase in future reporting periods.
Taxonomy Regulation – Mandatory reporting at 31 December 2022 in % Content of
Regulatory Metric:
As at 31 December 2022
1. Taxonomy-eligible
activities as a proportion
of total covered assets
%
0
2. Taxonomy non-eligible
activities as a proportion
of total covered assets
100
3. Exposures to
sovereigns as a
proportion of total
covered assets
4. Derivatives as a
proportion of total
covered assets
5. Exposures to
corporates not subject to
NFRD as a proportion of
total covered assets
6. Trading book as
a proportion of total
covered assets
7. On-demand interbank
exposures as a proportion
of total covered assets
23
0
12
0
0
Exposures in the on-demand interbank market divided by
total covered assets
Activities with Financial and Non-Financial
corporates subject to NFRD, households
and local governments covered by the EU
Taxonomy Climate Delegated Act divided by
total covered assets
Activities with Financial and Non-Financial
corporates subject to NFRD, households and
local governments not covered by the EU
Taxonomy Climate Delegated Act divided by
total covered assets
Exposures to sovereigns divided by total
covered assets. Sovereigns include
exposures to central governments, central
banks and supranational issuers
Derivatives in the non-trading portfolio
divided by total covered assets
Exposures to entities not obliged to report
under the NFRD divided by total covered
assets
Exposures in the trading book divided by
total covered assets
Exposures in the on-demand interbank
market divided by total covered assets
8. Total covered assets
(millions)
20,275
Total assets excluding exposures to
sovereigns and trading book
Sustainability
(continued)
The Task Force On Climate-Related
Financial Disclosures
The Task Force on Climate-Related
Financial Disclosures (TCFD) is a climate-
related financial disclosure framework
designed to promote more informed
investment, credit, and insurance
underwriting decisions and, in turn, enable
stakeholders to better understand the
concentrations of carbon-related assets
in the financial sector and the financial
system’s exposures to climate-related
risks.
The disclosure recommendations are
structured around four thematic areas
that represent core elements of how
an organisation operates including,
governance, strategy, risk management
and metrics and targets.
Permanent TSB is a proud member of the
global TCFD network. We are required to
report the TCFD disclosures in our annual
report under LR14.3.27 of the Listing
rules. We have elected to issue a separate
TCFD report later this year as it is our
first reporting period, meaning the TCFD
disclosures are not included within this
annual report.
Over the last number of months, the Bank
worked to complete a TCFD gap analysis
for the organisation, which has played a
significant role in guiding and informing
the disclosure. We will issue our first TCFD
Report to the market during the first half
of 2023 and plan to include it within our
Annual Report as part of future disclosure
cycles.
CDP
In 2022, we continued to further our to
environmental transparency by disclosing
the Permanent TSB’s environmental
impact through CDP, the non-profit that
runs the world’s leading environmental
disclosure platform.
We achieved a CDP rating of C during
the 2022 disclosure cycle, indicating
an awareness level of engagement.
The awareness score measures the
comprehensiveness of a company’s
evaluation of how environmental issues
intersect with its business, and how its
operations affect people and ecosystems.
By completing CDP’s annual request for
disclosure on climate change, the Bank
is demonstrating the transparency and
accountability vital to tracking progress
toward a thriving, sustainable future.
26
Permanent TSB Group Holdings plc - Annual Report 2022 Carbon Impact And The Transition To A Low Carbon Economy
Science Based Targets (SBTs)
In 2021, we deepened our commitment to long-term sustainability and committed to
new climate action goals by signing Phase 2 of the Low Carbon Pledge. The refreshed
Pledge focusses on setting carbon emissions reduction targets based on science by 2024
and will include measuring and reducing our entire carbon footprint in line with the Paris
Agreement and the latest Intergovernmental Panel on Climate Change’s (IPCC) findings.
The first step to setting SBTs is understanding our carbon footprint. During 2022, we
completed a comprehensive assessment of our emissions across scope 1, scope 2 and
each of the 15 categories found within scope 3, including the Bank’s financed emissions.
Our Carbon Footprint
A breakdown of our carbon impact across scope 1, 2 and 3 can be found below.
Emissions
Scope 1 emissions
Scope 2 emissions (market based)
Scope 3 emissions
Total scope 1, 2 and 3 emissions (using market based emissions factors)
Scope 3 emissions
Purchased goods and services
Capital goods
Fleet
Transport and distribution
Electricity transmissions and distribution losses
Water
Waste
Staff commuting and homeworking
Business travel
Investments (Mortgage portfolio)
Carbon intensity metrics
Scope 1 and 2 tCO2e per FTE
Investments tCO2e per €m
All data is for the full year to 31 December 2022
tCO2e
1,170
0
226,009
227,179
tCO2e
45,483
16,243
86
5,123
1,269
14
8
3,934
60
154,024
tCO2e
0.5
7.6
Scope 1 and 2
In 2018 the Bank signed the Low Carbon
Pledge, committing to reduce our scope 1
and 2 carbon emission intensity by 50%
by 2030. We reset our target during 2021,
aiming to reduce our scope 1 and 2 carbon
emission intensity by 60% by 2024.
We have made progress in reducing our
scope 1 and 2 carbon emission intensity
through the use of 100% renewable
electricity by our electricity providers,
efficiencies in energy use by the business
through initiatives aimed at reducing our
carbon footprint and the impacts of hybrid
working with 68% of our organisation now
availing of our smarter working options.
Using a market-based assessment of
electricity usage, these changes have
resulted in an estimated 83% cumulative
reduction in scope 1 and 2 carbon emission
intensity since 2009, our baseline year for
the Pledge.
Scope 3
During 2022, we completed a programme
of work to understand the material
emissions across our value chain. The
findings have enabled us to establish a new
carbon baseline for the organisation.
In order for us to understand our impact,
purchased goods and services and capital
goods emissions were based on applying
emissions factors to spend data, using
the UK Government’s 2019 Environmental
Reporting Guidelines for spend based
emissions. We recognise that the accuracy
of a spend based approach can vary, and
as such, are committed to improving the
accuracy of this figure through engaging
with our large suppliers to source accurate
data, where and when it may be available.
In relation to our investment-related
emissions, we limited our calculations to
the Bank’s mortgage portfolio1, given that
1. We used the Partnership for Carbon Accounting Financials Standard to estimate mortgage portfolio emissions
https://carbonaccountingfinancials.com/en/standard
it accounts for 98% of our Net Loan Book. In
order to do this, emissions associated with
properties were linked to the BER rating of
the property. The Bank has a high confidence
in the assigned BER for c.55% of properties.
For the remaining c.45% of properties, we
assigned a BER by extrapolating the same
distribution pattern as present in the high
confidence group. In addition, we estimated
emissions per property based on the
Sustainable Energy Authority of Ireland (SEAI)
published data from 2014 having applied
a corrective index. The approach reduced
emissions by 9% from 2014 levels, but
enabled us to account for the greening of the
grid over the period in question.
It is important to note that our scope 3
financed emissions intensity will increase
during 2023, as we consider the full-year
impact of the €6.7 billion Residential Portfolio
that the Bank acquired as part of the Ulster
Bank transaction in the Republic of Ireland.
In addition, 25 branch locations, the SME
Portfolio and the Asset Finance business
formed part of the wider acquisition, and will
also need to be considered.
Reducing emissions across scope 3 is a long-
term objective for the Bank that will require
us to not only measure and reduce our own
carbon footprint, but also work collaboratively
with our suppliers and customers to
encourage a transition towards a Net Zero
world.
As we look to 2023 and beyond, we are
focussed on:
• Using our carbon baseline to set SBTs
aligned to the Paris Agreement and IPCC
findings;
• Setting a Net Zero ambition over the longer
term;
• Developing a corresponding Carbon
Reduction Plan to help us to achieve our
targets; and,
• Continuing to find ways to improve the
quality of our data.
During the first half of 2023, we will issue
our first TCFD Report to the market, which
will include further detail on the calculation
assumptions associated with our emissions.
Energy Usage
At Permanent TSB, we know that the use
of energy is a significant contributor to our
emission intensity.
With this in mind, in 2022 we took additional
action to minimise the carbon impact of our
operations, including:
27
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Sustainability
(continued)
• Changing our energy provider and
selecting a supplier focussed on using
100% renewable energy;
• Approving a programme of work to
replace our suite of boilers, chillers and
associated pumps to new and more
energy efficient options;
• Engaging Kyndryl, a technology
infrastructure services provider, to
support us in migrating our data centre
to new and more efficient buildings.
The migration is expected to reach
completion during 2023 and will see the
Bank improve the net energy efficiency
of our data centres;
•
Implementing LED lighting across our
branch network as part of our ongoing
branch refurbishment process;
• Celebrating Earth Hour, raising
awareness and encouraging our
colleagues to reduce their energy
consumption both in the office and at
home; and,
•
Introducing colleague communication
and awareness campaigns focussed on
energy efficiency, led by the Permanent
TSB Green Team.
Waste Management
A large part of reducing our environmental
impact is minimising waste, with a target to
reduce our impact by 5% annually.
Permanent TSB’s waste management
supplier is committed to maintaining their
environmental ethos by ensuring that no
waste goes to landfill and that it is diverted
and recycled through multiple resources.
The Bank has in place recycling facilities
across all of our sites, including our head
office building, administration sites,
customer services centres as well as
recycling facilities in our branch network.
Actions taken to reduce our waste in 2022
include:
•
•
Introducing new recycling and waste
management stations across our Head
Office building. The implementation
included a multi-channel awareness
campaign for colleagues designed
to encourage a shift in mind-set and
behaviour aligned to our Sustainability
Strategy and waste management
objectives;
Introducing a market-leading Digital
Current Account, eliminating c.85 pages
of paper from our business for every
application that comes through the
online channel;
• Releasing a new Digital Mortgage
Journey, eliminating c.250 pages of
paper from our business for every
application that comes through the
online channel;
•
Implementing online applications
for Term Lending, Credit Cards and
Overdrafts;
• Continuing our focus on ‘Go Paperless’,
an initiative to encourage customers to
select the eStatement option in an effort
to manage paper consumption, limit
waste and further reduce the Bank’s
environmental footprint. More than
c.98,000 customer credit card accounts
were registered for eStatements during
2022, resulting in an on-going reduction
of paper by c.1.5 million pages of paper
annually;
• Ongoing integration of a new customer
correspondence management tool,
delivering a range of new functionality
to enable us to migrate our customer
correspondence to digital channels,
thereby allowing us to further reduce our
reliance on paper;
• Engaging shareholders to encourage
them to receive the Annual Report
by electronic means. The Bank has
c.130,000 shareholders. In 2022, we
issued c. 1,000units of the Annual Report
in hardcopy. The remaining copies were
issued in digital form, saving more than
16million pages of paper;
• Launching a ‘Think Before You Print
Campaign’ for colleagues to coincide
with returning to work following
Covid-19, aiming to save more than 7
million pages of paper;
• Celebrating Earth Day, raising awareness
and encouraging both our internal and
external stakeholders to reduce, reuse
and recycle, both in the office and at
home; and,
• Monitoring water consumption in all of
our branch and administrative sites.
Waste Generation
General Waste (Recovered = Incinerated)
Recycling Waste
Recycled Confidential Shred Waste
Recycled Used Cooking Oil
Recycled Grease
Recycled Lamps
*LED Lighting upgrade completed in 2020
** LED Lighting upgrade to a selection of branches in our retail network
2019
Tonnes
2020
Tonnes
2021
Tonnes
2022
Tonnes
138
86
280
1.8
2.9
0.4
86
40
218
1.0
2.8
12.55*
84
42
191
0.9
3.0
0.2
93
54
229
0.9
3.2
22.3**
28
Permanent TSB Group Holdings plc - Annual Report 2022
Sustainable Products And Services
The Bank recognises the role that business
will need to play in supporting the targets
set out in the Paris Agreement, including
the role that financial services will play in
supporting Ireland’s Climate Action Plan
and financing the private sector to navigate
the green transition.
Our customer research has indicated that
64% of consumers are actively taking
steps to be more sustainable, with 55%
stating that sustainability is important to
them when availing of a financial products
and services. Sustainable Finance is a
key area of focus within the Bank’s Board
approved Sustainability Strategy.
To support the above, in 2022 the Bank was
proud to introduce our Green Mortgage
to the market, a 5-Year fixed rate product
available to all new and existing home
loan customers where their homes have
a confirmed or proposed Building Energy
Rating of A1 to B3.
Since the launch of the Green Mortgage in
April, c.€500 million in green lending was
drawn down during 2022, accounting for
c.20% of Mortgage lending.
The Green Mortgage is envisaged to be
the first in a suite of Sustainable Finance
Product offerings for Permanent TSB, with
proposition development continuing on
future products for both the Retail and SME
sectors.
Strategic Banking Corporation of
Ireland’s Retrofit Loan Scheme
During 2022, the Bank completed the
Invitation for Pre-Qualification into the
Strategic Banking Corporation of Ireland’s
(SBCI) new Retrofit Loan Scheme aimed at
supporting consumers and small landlords
who wish to invest in the energy efficiency
of a residential property. The Invitation
for Pre-Qualification is the first stage in
a two-stage process to identify potential
On-Lenders interested in distributing the
Scheme.
Under Ireland’s Climate Action Plan, the
Irish State set a target to upgrade 500,000
homes to a Building Energy Rating B2 level
and the installation of 400,000 heat pumps
in existing premises to replace fossil fuel
heating systems.
• Embedding the Teagasc Signpost
Programme into our lending processes
for Agri; and,
•
Introducing specialised training to
support the Agri sector with the help of
Teagasc.
Permanent TSB is proud to work with the
Teagasc Signpost programme, a multi-
annual campaign to lead climate action by
all Irish farmers.
The programme aims to achieve early
progress in reducing gaseous emissions
from Irish agriculture and also improve
water quality, maintain (and in some cases)
improve biodiversity, reduce costs and
create more profitable and sustainable
farming enterprises.
There are two elements to the programme;
a network of Signpost Farms, including
beef farms, which will act as demonstration
farms for the programme and sites for
carbon sequestration measurements; and
the Signpost Advisory Campaign, which
engages with farmers and supports them
to move towards more sustainable farming
systems.
To meet these targets, there is a
requirement to develop a loan guarantee
scheme to provide a competitive funding
offer with State support to help increase
the volume of retrofit activity. The
guarantee-based product will offer both
a degree of risk-sharing to lenders, and
an additional leverage effect to mobilise
private capital, which means that the
funding is used in a more efficient way.
The Scheme of up to €600m will be
part-funded by the Department of the
Environment, Climate and Communication
and the EU Recovery and Resilience
Facility under Ireland’s National Recovery
and Resilience Plan, and will be backed
by a counter guarantee provided by the
European Investment Bank.
Teagasc Signpost Programme
Permanent TSB is focused on supporting
our Business and Agriculture (Agri)
customers in transition, with an added
layer of focus on customers who
need additional support to establish
infrastructure for new climate friendly
business models.
We are committed to:
• Developing lending products for
Business and Agri customers that
support sustainability goals and
objectives and work with the SBCI to
help develop market products to support;
• Partnering with agencies to provide
Business and Agri customers with
training, advice and tools to further their
understanding of sustainability;
29
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Sustainability
(continued)
Responsible Procurement
We continue to enhance our Procurement
and Sourcing Frameworks to ensure that
they support our sustainability goals
and objectives. Our Procurement Policy
sets out a framework for engaging with
our suppliers, including a commitment
to procure goods and services from
suppliers who can support the needs of
our business in a sustainable manner. It
sets out the ESG standards that we want
our suppliers to achieve and is supported
by our procurement processes, supplier
on boarding procedures and ongoing due
diligence practices including, adherence to
our Third Party Risk Management Policy
and Supplier Code of Conduct.
In addition we hold membership to the
Financial Supplier Qualification System
(FSQS), an online platform where suppliers
submit their compliance data and
information relating to their organisation,
allowing us to have a consistent view of our
suppliers to ensure they meet our minimum
standards.
We are focussed on minimising our
environmental impact from purchased
services, while also working alongside our
suppliers to find opportunities to procure
goods in a sustainable way.
Following a gap analysis completed during
2021, examples of actions taken during
2022 include:
• Developing a Sustainable Procurement
Framework and Sustainable Supplier
Charter;
•
Integrating and embedding sustainability
criteria further into our procurement
processes;
• Completing a gap analysis of our supply
chain in order to limit our exposure and
impact;
• Beginning to segment our suppliers
based on mission criticality and potential
risks to our service delivery; and,
• Assessing the carbon impact of our
supply chain and disclosing emission
intensity.
During 2022, Permanent TSB was proud
to win awards for Best Procurement
Transformation Project and Best
Procurement External Collaboration Project
at the National Procurement Awards,
recognising the progress that we have
made over the last year.
The Bank’s Procurement Policy is reviewed
annually, communicated as required and
made available to our colleagues on our
internal website.
Green Team
Permanent TSB has in place an employee
led Green Team, a cross functional working
group who together, work on green
initiatives and awareness campaigns that
support our green agenda.
With the support of the wider Sustainability
Committee, the team are focused on
environmental programming including:
energy efficiency and transition to a low
carbon economy; use of resources and
recycling; green procurement; biodiversity
and green space; volunteering initiatives
with an environmental impact; and,
communication and awareness.
Environmental Policy Statement
Permanent TSB’s Environmental
Policy Statement outlines the Bank's
commitment to environmental
sustainability through the ongoing
identification, management and
improved efficiency of those significant
environmental impacts associated with
our business activities, including: carbon
impact and contributing to a low carbon
economy; energy management; use of
natural resources; biodiversity; and, waste
management.
The Environmental Policy Statement
is reviewed annually as part of a senior
management review of all Sustainability
Programming. Progress against our
Strategy is reported upward to the Chief
Executive, Executive Committee and the
Nominations, Culture and Ethics Board
Committee on a quarterly basis.
30
Permanent TSB Group Holdings plc - Annual Report 2022 Elevating Our Social
Impact & Connecting
With Local Communities
Overview
With a presence in more than 100 retail and office locations
nationwide, Permanent TSB is a local community Bank whose
purpose is to work hard every day to build trust with our
customers. We are a community serving the community and
our commitment to maintaining our branch footprint, ensuring
the accessibility of our products and services and investing in
local communities across the country is a demonstration of that
purpose in action.
Impact In Action:
Growing our branch footprint
by 30% to 98 locations
nationwide
Announcement of the Bank’s
Title Sponsorship of the Irish
Olympic Team and the Irish
Paralympic Team for Paris
2024
c. €600,000 in financial
contributions to Irish
community organisations in
2022
c. €200,000 in charitable
giving through the Permanent
TSB Community Fund, which
included matched funding by
the Bank
c.€250,000 donated to
UNICEF Ireland and the Irish
Red Cross to support the
Ukrainian relief efforts
Winner – Best Community or
Charity Engagement for the
Permanent TSB Community
Fund, Bonkers National
Consumer Awards, 2022
Growing Our Branch Footprint
In 2022, we committed to growing our retail
footprint by an additional 30% through
the acquisition of 25 new branch locations
as part the Ulster Bank transaction in
the Republic of Ireland. The additional 25
branch locations are based in communities
where the Bank did not currently have a
presence and became part of Permanent
TSB’s property portfolio in early 2023,
bringing the Bank’s overall branch footprint
to 98 locations nationwide.
The Bank is committed to maintaining
our branch presence in communities
across Ireland. We recognise the
importance of continuing to invest in digital
transformation and innovation in order to
provide our customers with a seamless
digital experience online, but providing a
personal, in-person service will remain at
the heart of our customer service offering.
Encouraging Financial Wellbeing
At Permanent TSB, we recognise that we
have a responsibility to enable financial
wellbeing among our customers.
As part of our partnership with Irish Life,
all customers are offered a free financial
review, focused on supporting them in
making informed financial decisions. The
financial health check is undertaken by
Irish Life and was traditionally completed
by making an appointment at any of our
branch locations nationwide. In 2022 we
completed c.7000 financial reviews, both
in-person and through our digital channels,
to support customers in taking control of
their financial future.
Enabling Accessibility Of Our
Products And Services
Permanent TSB is committed to
understanding the needs of our customers
and to ensuring that the products and
services we provide allow all people,
including those who may be vulnerable or
underrepresented, equal opportunity to
access them.
To support the above, the Bank has in
place a set of Vulnerable Customer Guiding
Principles, to enable us to remove barriers,
meet the needs of customers who may
require additional support and care and
to provide guidance and support to our
colleagues.
Through our Vulnerable Customer
Programme, in 2022 we continued to
embed our programming, while also
introducing additional measures in order to
provide appropriate access and support to
our customers. Actions taken include
• Participating in the development of the
Banking and Payment Federation of
Ireland’s ‘A Guide to Moving Banks for
Customers in Vulnerable Circumstances’,
in order to support those most vulnerable
in moving their banking relationship
following as Ulster Bank and KBC exit the
Irish Market;
• Developing Permanent TSB’s Enhanced
Customer Support Policy and
Framework, which is due to launch in
2023;
• Mobilising an Enhanced Customer
Support Team within the Bank’s
Customer Contact Centre, with a
supporting dedicated phone line;
• Rolling out a Vulnerable Customer
Appointment Booking Service through
our Enhanced Customer Support Team;
•
Introducing a dedicated webpage for
customers requiring enhanced support,
outlining the services available and
providing detail in relation to how they
can be accessed;
• Providing Enhanced Customer Support
and Assisted Decision Making training
for colleagues across the Bank;
• Delivering comprehensive grief
training for our Bereavement Services
colleagues, leveraging the Bank’s
Employee Assistance Programme;
• Raising awareness of domestic and
financial abuse within a Women’s Aid
Training Pack which is available to both
our customer facing and non-customer
facing teams;
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(continued)
• Creating a dedicated webpage to support
customers affected by the humanitarian
crisis in Ukraine, which included a guide
available in both English and Ukrainian;
•
Introducing a dedicated phone line to
support our Ukrainian customers in
booking appointments; and,
• Refunding all transaction fees on SWIFT
payments to Ukraine and Moldova.
Permanent TSB ensures that accessibility
standards are embedded into our online
and mobile channels, as well as in the
development of its digital platforms. In our
retail network, our branches are designed
with accessibility in mind.
JAM Card
Permanent TSB is proud to support the
‘Just A Minute’ (JAM) Card initiative across
each of our retail locations nationwide.
JAM Card is a growing initiative that allows
customers with a learning difficulty, autism
or communication barrier tell others they
need ‘Just A Minute’ discreetly and easily
when in public settings like shops, public
transport or their local Permanent TSB
branch.
The JAM Card is a welcome addition to the
Bank’s growing supports for vulnerable
customers, allowing our customer facing
teams to give JAM Card users a bit of extra
support and time when conducting their
transaction.
Dublin City University Access
Scholarship Programme And Access
To The Workplace Programme
In 2022, Permanent TSB was proud to
continue our partnership with Dublin City
University’s (DCU) Access Scholarship
Programme, which provides funding
support that enables DCU to put students
through 3rd level education programming
and realise their full potential.
As part of the partnership, the Bank are
also actively involved in the DCU Access
to the Workplace Programme, providing
paid work placement opportunities
and professional career guidance and
support to talented students from
socioeconomically disadvantaged
backgrounds.
their degree endeavours. To complement
the above, Access to the Workplace
provides students with a range of personal,
financial and academic support to enable
students to thrive and excel in their studies
during their time at DCU.
Since its establishment in 2019, the
Programme has provided 245 summer
internships for DCU students with 82
partner companies. In addition, it has
received widespread recognition for its
excellence and innovation, winning the
prestigious international Times Higher
Education Widening Participation or
Outreach Initiative of the Year Award in
2022.
Title Sponsorship Of The Irish
Olympic Team And Irish Paralympic
Team
In March 2022, we were pleased to
announce our title sponsorship of Team
Ireland for the 2024 Games in Paris,
becoming the first-ever title sponsor to
partner with both the Irish Olympic Team
and the Irish Paralympic Team during
an Olympic and Paralympic cycle. The
announcement also marked the first time
that Paralympics Ireland has had a title
sponsor.
As Ireland’s leading personal and small
business Bank, we value ambition, courage
and excellence, three key factors in Irish
high-performance sport and are proud to
be able to support Irish athletes as they
compete on the world stage.
As part of the partnership, we are delighted
to be working alongside four world class
athletes who will act as ambassadors
for the Bank. These athletes include
Olympic Champion Boxer Kellie Harrington,
Olympic Badminton Player Nhat Nguyen,
Paralympic Champion Sprinter Jason
Smyth and Paralympic Powerlifter Britney
Arendse.
The Olympic Federation Of Ireland’s
Dare To Believe Schools Programme
In addition to our title sponsorship of
the Irish Olympic Team and the Irish
Paralympic Team, Permanent TSB is also
proud to be title sponsor of the Olympic
Federation of Ireland’s Dare to Believe
Schools Programme.
The Access to the Workplace Programme
was established in 2019, with the aim of
providing Access students high quality
internship opportunities within leading Irish
businesses, in order to support them in
gaining work experience that is related to
Dare to Believe was originally launched
in 2019 in order to bring the spirit of the
Olympic Games to the primary school
classroom and inspires young people
across Ireland to dare to believe in
32
themselves. Our community ethos is a
key differentiator for Permanent TSB
and like us, Dare to Believe is grounded in
communities across the country.
In 2022, we were pleased to be able to
support the Programme’s expansion into
secondary schools to help to further grow
its impact.
Over the last year, Dare to Believe reached
704 primary and secondary schools, with
the curriculum being delivered to more
than 49,000 students in communities
across the country.
Investing In Local Communities
Through The Permanent TSB
Community Fund
The Permanent TSB Community Fund
was established to support communities
by providing funding to community
organisations that are having a positive and
meaningful impact on the ground and who
are working hard to make a difference.
With more than 120,000 votes cast by
the Irish public through both our website
and mobile App, in 2022 the Bank was
proud to announce Ronald McDonald
House Charities Ireland, Aoibheann’s Pink
Tie, Cycle Against Suicide, The Down
Syndrome Centre Cork, Down Syndrome
Ireland and Western Alzheimer Foundation
as its Community Fund Partners for the
fundraising year.
Numerous fundraising events were
organised and managed by our colleagues
from around the Bank throughout the year
including: the Charity Table Quiz; Payroll
Giving Campaign; Christmas Mega Raffle;
and, the Dive For Donations – a fundraising
skydive which saw our colleagues jump
from a plane in support of our Community
Fund Partners .
All money raised during the year was
match funded by the Bank, for an overall
donation to our Community Fund Partners
of c.€200,000.
Since its establishment in 2020, the
Community Fund has contributed c.€1.5
million in funding to Irish community
organisations, supporting local
communities across the country.
In 2022, Permanent TSB was proud
to win a Bonkers National Consumer
Awards in the Best Community or Charity
Permanent TSB Group Holdings plc - Annual Report 2022 Engagement Category for the work of the
Permanent TSB Community Fund.
– a programme recognised as having the
potential to grow and scale its impact.
As part of the three-year partnership, the
Bank has provided €350,000 to Ó Cualann,
which is being used to fund the resources
required to accelerate its development
plans with the aim of building more than
1,800 houses across Ireland.
The Ó Cualann Cohousing Alliance was
founded in 2014 with the aim of providing
fully integrated, co-operative, affordable
housing in sustainable communities.
The agency is committed to a zero
carbon future and are involved in 3
post-occupancy energy use studies to
ensure that homeowners are using their A
-rated homes to the maximum potential.
The three schemes (Amber, Esher and
Autodan) are part of SEAI and Horizon
2020 research projects.
The Sustainability Team and the
Community Fund Committee manage
the engagement with our charity and
community partners and ensure that
effective governance is in place via
the implementation of comprehensive
partnership agreements. In addition, the
Bank has in place a Community Fund
Constitution, a document which governs
how we engage with charities and manage
relationships, and includes processes
for completing effective due diligence
at regular intervals. A Community Policy
and an Employee Volunteering Policy are
also in place to further guide and support
programming.
Progress against KPIs is reported
upward to the Chief Executive, Executive
Committee and the Nominations, Culture
and Ethics Board Committee on a quarterly
basis.
In addition, we were pleased to be
shortlisted for a Chambers Ireland
Sustainable Business Impact Award in the
Community Programme Category for the
Permanent TSB Community Fund, further
recognising the impact that the Fund is
having on communities across the country.
Supporting Social Issues Through
Our Partnership With Social
Entrepreneurs Ireland
In 2022, Permanent TSB entered into the
sixth year of our partnership with Social
Entrepreneurs Ireland (SEI), contributing
€85,000 financial support and also
implementing an extensive employee
engagement programme between SEI and
employees of the Bank.
Social Entrepreneurs take an
entrepreneurial approach to solving social
issues such as improved mental health and
wellbeing, social inequality, food waste,
climate action and everything in between.
Over the past 18 years, SEI has supported
more than 500 social entrepreneurs and
their programmes, invested €13 million in
social projects, and provided extensive pro-
bono expertise to entrepreneurs worth on
average €500,000 per year.
During 2022, the Bank continued to work
closely with SEI to deepen our partnership
by getting our colleagues involved in
SEI’s annual Awards review and selection
process, broadening our impact through
our title sponsorship of the Community
Programme and continuing to offer
pro-bono support and mentoring to the
SEI community of Alumni, whereby we
match the skills of our people with the
organisations that need them most.
Addressing Affordable Housing
Through Our Partnership with Ó
Cualann Cohousing Alliance
In 2022, Permanent TSB entered into
the third year of our partnership with Ó
Cualann Cohousing Alliance continuing to
support the agency’s work developing fully
integrated, co-operative and affordable
housing schemes in communities across
the country.
Ó Cualann is a member of the Social
Entrepreneurs Ireland Alumni Network
and is an SEI Impact Programme Awardee
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(continued)
Enhancing Our
Culture & Investing
In Our People
Overview
The Bank’s ambition to be Ireland’s best personal and small
business Bank is only possible if we create customer-centric,
inclusive and diverse, risk integrated, growth culture, where our
colleagues feel engaged, valued and are given the support that
they need to be the best they can be.
Impact In Action:
89% of employees
feel comfortable to be
themselves at work
regardless of background or
life experiences
80% Culture Index Score
38% of Senior Leadership
Positions are filled by Women
2.6% training days delivered
per employee in 2022, c.141
colleagues received an
Institute of Banking (IOB)
accreditation, with c.458
employees enrolled in banking
education programming
More than 1300 nominations
received to the ‘Values in
Practice’ (VIP) Awards, the
Bank’s colleague recognition
programme.
Winner of the CIPD Award
for Best Flexible and Hybrid
Workplace
Irish Banking Culture Board
Permanent TSB is an actively involved
in improving culture across the banking
industry as a member of the Irish Banking
Culture Board (IBCB). In 2018, the five Irish
Retail Banks came together to establish
the IBCB, aimed at rebuilding confidence in
the Irish banking sector.
The IBCB, which operates as an
independent body chaired by Justice
John Hedigan, helps to ensure the
industry is focused on fair outcomes for
our customers and employees, thereby
rebuilding a sustainable banking sector.
The Board includes representation from all
five of the Irish Retail Banks.
Throughout 2022, we continued our
contribution to and support of the IBCB and
its programme of work, including:
• Playing an active role in a number of
IBCB workshops focussed on addressing
key challenges across the sector;
• Participating in the IBCB Pride in
Banking Research Project to continue
to listen and act on feedback from our
colleagues on culture within the Bank,
and across the wider industry; and,
• Embedding the industry wide DECiDE
(Ethical Decision Making) Framework as
part of our Code of Ethics.
• For more on the progress made in our
cultural evolution during 2022, please
visit page 19.
34
Living As Leaders
We believe that the consistent actions
and behaviours of everyone, every day is
essential in creating a better future for one
another and for our Bank.
With that in mind, in 2022, Permanent TSB
were proud to partner with LIFT Ireland
(Leading Ireland’s Future Together) for the
third year to continue our Living as Leaders
Programme, which aims to promote and
encourage the right behaviours across all
levels within the organisation.
LIFT Ireland is a Not for Profit Organisation
with a vision to make Ireland a better place
to live by creating better leaders across
our society and in our communities. LIFT’s
philosophy aligns closely with that of
Permanent TSB’s, as they believe that each
of us is a potential leader; whether that is
within our families, our schools, our sports
teams or our businesses. LIFT believe that
by developing personal leadership qualities
within each individual, we can develop a
generation of stronger and better leaders.
During 2022, we were pleased to be
shortlisted for a CIPD Award in the
Sustainable Change Category for the Living
as Leaders Programme. More than 1600
colleagues have taken part in Living as
Leaders to date, with the programme set to
continue into 2023.
For more on Living as Leaders, please visit
page 17.
Ways Of Working (Hybrid Working)
In recent years, the Bank has embraced the
introduction of smarter and more flexible
ways of working for colleagues at all levels
of the organisation.
In 2022, Permanent TSB continued
embedding our Smarter Working
Programme to enable optionality and more
flexible ways of working for colleagues,
while enhancing our tools and encouraging
the use of a broader range of technology.
The range of Smarter Working Options
available to colleagues include: reduced
hours; job sharing; compressed hours;
sabbaticals and career breaks; and, home
working or working from an alternative
office location.
In recognition of our Smarter Working
Programme, Permanent TSB was proud to
win the prestigious CIPD Award for Best
Flexible and Hybrid Workplace during 2022.
Permanent TSB Group Holdings plc - Annual Report 2022 In 2023, we will continue to assess
and evolve our colleague offering, and
corresponding policies, supports and
technology, with a view to ensuring the
work environment is fit for the future,
enabling improved flexibility and choice for
a greater colleague experience.
Investing In Learning And
Development
Permanent TSB recognises that both
personal and professional training and
development of the workforce plays a
critical role in delivering on our purpose and
ambition.
For more on Ways of Working, please visit
page 18.
Listening To Employees And Acting
On Feedback
The Every Voice Counts Employee
Engagement Survey is conducted at
regular intervals and is designed to give
our people an opportunity to provide
feedback on what is working well across
the organisation, while identifying areas for
improvement.
Permanent TSB’s most recent Every Voice
Counts Survey results indicated a Culture
Index of 80%, +10% above our Culture
Index Target of 70%. A selection of our
survey results include:
• 4 out of 5 employees trust Permanent
TSB to do what is right;
• 3 out of 4 employees feel engaged in the
company;
• 4 out of 5 employees are proud to work
for Permanent TSB; and,
• 89% of employees feel comfortable to
be themselves at work regardless of
background or life experiences.
With a focus on continuous improvement,
Permanent TSB is focused on addressing
the feedback and will implement action
plans across the business during 2023.
The Bank recognises the importance of
checking in and staying connected with our
colleagues at regular intervals throughout
the year outside of our Every Voice Counts
cycle. With that in mind, in 2022 we
continued to deliver a series of micro-pulse
surveys to check in with our people and to
get insight into how we could assist them
further in their role.
With a clear focus on equipping our people
with the skills and behaviours necessary to
adapt and thrive in the changing financial
services landscape, the Bank provides
training, education and personal and
professional development opportunities
to our colleagues at all levels of the
organisation. Our people are supported
both financially and with study leave in
order to pursue professional qualifications
and to assist in their career development.
We are recognised as approved employers
by ACCA, Chartered Accountants Ireland
and CIMA and have been recognised at a
national level for excellence in learning and
development in financial services.
In 2022, we continued to support our
colleagues with a diverse catalogue
of training courses which offered the
opportunity to develop their skills across
a number of different areas including
Leadership and Personal and Professional
Development.
In addition, we were proud to participate
in Ignite, a new learning initiative in
partnership with the Institute of Banking
and Skillnet Ireland, to further support the
development of our people. Ignite offers
our colleagues the opportunity to assess
their existing skillset, while enabling them
to learn and adopt new skills that will be
critical to the future of banking.
High Performance Culture
The Bank’s Performance Management
Strategy is designed to cultivate a culture
where employees are valued, developed
and motivated to use their talent,
empowered to bring their best selves to
work and provided with regular coaching
and open two-way feedback. Performance
for each employee is evaluated under two
core principles which are equally weighted:
The micro-pulse surveys covered a number
of key themes including, Hybrid Working
and Speaking Freely. The findings enabled
us to evolve our action plans, ensuring that
we were focussed on the right things in
order to support our colleagues.
•
•
For more on Every Voice Counts, please
visit page 18.
‘What You Do’ in line with the Bank’s
Strategic Priorities; and,
‘How You Do It’ in line with the Bank’s
espoused Values and Culture.
The Bank has in place a set of core
competencies for all colleagues,
relevant to their role within the business.
These competencies are aligned to our
Organisational Values – Courageous,
United, Straightforward, Customer
Focused, and Open – and describe the
mind-set and behaviours required for
all colleagues within the Bank. The
competencies are an integral part of
our Career Development Framework,
supporting our colleagues’ development
and on the job career growth trajectory.
Permanent TSB has in place an online
performance management system,
Performance COMPASS, to encourage
quality conversations and to streamline
the completion of the performance
management process.
Pay And Reward
The Bank has a Pay and Reward Policy
which targets base pay to an acceptable
range around the market median. This
policy is reviewed on a regular basis,
including assessing the competitiveness
of total reward arrangements against
market norms and taking account of State
agreements.
The Bank is committed – to the extent
possible in the context of restrictions on
variable pay – to ensuring the ongoing
alignment of remuneration with our overall
business strategy and sustainability
objectives, by linking pay outcomes
directly to individual performance (what
our colleagues achieve but also the manner
in which they achieve it), and how their
contribution strengthens both our shared
culture and the long term sustainability of
our business.
Permanent TSB is cognisant of the extent
of the cost of living crisis and the impact
that increases in energy, food and fuel
prices are having for our colleagues and
their families.
To help to alleviate the pressure, during
2022 the Bank provided colleagues
€1,000 each in recognition of the current
pressures they face. The payment was
provided in the form of an One4All gift
voucher, with colleagues being encouraged
to use the voucher to support local
businesses and suppliers within their
community, where possible.
35
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Sustainability
(continued)
The benefit was a once off gesture to
colleagues from Level 2 to Level 5 inclusive
and aims to build on a number of initiatives
that were delivered to support colleagues,
including:
In 2018, we launched our Diversity and
Inclusion Strategy to support the above
ambition, with a vision to evolving our level
of maturity on the Ernst and Young (EY)
Global Maturity Model.
• A 6.5% 2-year pay deal for 2022 and
2023 inclusive;
•
Increased entry-level salaries;
• Enhanced employer pension contribution
rates; and,
• Extended paid maternity leave, the
introduction of a Wellbeing day, and
expansion of sick pay entitlements.
Values In Practice Awards
The Bank’s employee recognition
programme, the ‘Values in Practice’ or ‘VIP’
Awards, recognises employees from across
the organisation that are living the Bank’s
Values and are positively impacting the
business.
In 2022, more than 1,300 nominations were
received with representation from all parts
of the business. This marked the highest
level of colleague recognition since the
Awards were introduced five years ago.
In addition to our five ‘Values’ categories,
the Bank has two additional award
categories, the Community Impact
Award and the Living as Leaders Award,
recognising those who are having a positive
and meaningful impact on their local
communities, and those who consistently
live all five of our Values each and every
day.
In 2022, we continued to deliver our
‘VIP Every Day’ Programme, enabling
colleagues to recognise each other’s
outstanding contribution all year long, and
outside of our annual award cycle. Since
the launch of ‘VIP Every Day’ in May 2021,
more than 2,000 colleagues have been
recognised for their contribution.
Diversity, Equity, And Inclusion
Permanent TSB is an equal opportunities
employer committed to creating a
professional environment in which
our employees feel valued, included
and empowered to succeed in their
career, regardless of gender, age, sexual
orientation, race, religion, ability/disability,
background or life experiences.
We have made great progress and actions
we took in 2022 include:
• Continuing to include our signature in
‘Elevate’, Business in the Community
Ireland’s Inclusive Workplace Pledge;
• Embedding our Smarter Working
Framework with 68% of our colleagues
now availing of Smarter Working
Options;
• Participating in the Women in Finance
Charter, committing to achieve gender
balance at the leadership level by 2025;
• Launching the Better Balance Female
Mentoring Programme, providing
mentoring to 70 colleagues with support
from 17 mentees at Senior Leadership
level;
• Ongoing review of all internal training
material, ensuring consideration for
accessibility and representation;
•
Introducing a Faith Room, Wellbeing
Room and an All Gender Toilets facility in
our Head Office location;
• Embedding supports for parents through
1:1 coaching and group sessions with our
parental support partners;
• Promoting a culture of psychological
safety through Speak Freely, our channel
for encouraging colleagues to speak up
and raise a concern;
• Publishing our Gender Pay Gap for the
second year in a row and in advance of
the legislation;
• Being shortlisted for the Diversity,
Equality & Inclusion Award at the 2022
FS Awards; and,
• Receiving a Silver accreditation from the
Irish Centre for Diversity, recognising
the progress made across Diversity and
Inclusion.
In 2023, we will review and refresh our
Diversity and Inclusion Strategy based on
the principles of the Investors in Diversity
Gold Accreditation as we seek to progress
to the highest standards of accreditation
with the Irish Centre for Diversity within the
life of the Diversity, Equality and Inclusion
Strategy 2023-2025.
Employee Resource Groups
To support the delivery of the Diversity
and Inclusion Strategy, the Bank has in
place a number of Employee Resource
Groups (ERGs), whose aim is to enable
employees to join together based on
shared characteristics or life experiences.
The ERGs help diverse groups obtain a
collective voice within the organisation
and serve as an organised and established
platform that our people can utilise to
promote change.
There are currently four ERGs in place:
• PRISM – Our LGBTQ+ Network for
colleagues and allies. The Network
promotes and values individual
differences no matter how our people
identify;
• Better Balance – The Network aims to
be the catalyst for change in achieving
Gender Balance in Permanent TSB;
• LiveWell - LiveWell provides space,
connection and support for colleagues to
engage in areas of wellbeing important to
them regardless of location; and,
• DiCE (Diversity, Inclusion, Culture and
Ethnicity) – The Network promotes and
celebrates people of all races, ethnicities,
nationalities and cultural heritage.
The ERGs continue to champion the cause
of each group, promoting and encouraging
conversations with colleagues, while
celebrating key dates such as International
Women’s Day, International Men’s Day,
PRIDE, Diwali, National Coming Out Day
and Cultural Diversity Day, to name a few.
In addition, through the work of the ERGs
we have identified opportunities to improve
our brand visuals, address accessibility
issues and broaden our understanding
through introducing supports like our
LGBTQ+ terminology document.
The Elevate Inclusive Workplace
Pledge
In recent years, Permanent TSB has
added our signature to Business in the
Community Ireland’s ‘Elevate Pledge’,
committing to building inclusive
workplaces that are representative of all
members of our society.
36
Permanent TSB Group Holdings plc - Annual Report 2022 Workplaces have become more diverse,
incorporating a multiplicity of backgrounds,
experiences and identities. This has
brought huge benefits to Irish business.
Entitled ‘Why Care About Childcare?’, the event explored how Ireland can learn from other
countries to improve our childcare system and promote family-friendly work cultures. It
featured guest speakers from business, sport, politics, the media and the arts who shared
their experience and their vision of what childcare in Ireland should be.
However, diversity alone is not enough.
Workplace inclusion is about creating a
culture where everyone feels welcome,
has access to opportunities and is
supported to thrive. By signing the Pledge,
we are committing to building a truly
inclusive workplace, while supporting the
broader values of inclusion, equality and
opportunity in Irish society.
Gender Balance In The Workplace
Permanent TSB is a member of the 30%
Club, a group of c.200 Chairs and CEOs
committed to better gender balance at all
levels of their organisations. The Club’s
focus is on gaining visible and practical
support for gender balance from business
leaders in private, public, state, local and
multinational companies as well as other
interested groups.
The Bank is a member of Triple FS (Female
Fast Forward – FS Women in Leadership)
and has actively championed women
in leadership development through our
partnership with the Irish Management
Institute (IMI). In addition, the Bank has
in place an Early Career Development
Programme, supporting our female
colleagues who are only just beginning
their career.
Permanent TSB supports Better Balance
for Business, and played an active role
in the development of the Banking and
Payment Federation of Ireland’s (BPFI)
Women in Finance Charter.
The WorkEqual Campaign
To further support the work of our Diversity
and Inclusion Strategy, in 2022 Permanent
TSB entered into year three of our
partnership with the WorkEqual Campaign,
promoting gender equality in workplaces
across Ireland.
The WorkEqual campaign is NGO-led and
aims to both raise awareness of workplace
gender inequalities and related issues and
develop solutions to address them.
During November, WorkEqual delivered a
series of events in support of the above
ambition, culminating in their flagship
seminar which took place on Equal Pay
Day – the date on which women in Ireland
effectively stop earning, relative to men,
because of the gender pay gap.
There has never been a more important time for businesses across Ireland to focus
on addressing the barriers to women’s and men’s full and equal participation in the
workplace, taking direct and proactive steps to make this a reality across society.
This is the responsibility of every employer and we are proud to contribute to this national
effort, in partnership with the WorkEqual campaign.
Analysis of our workforce by gender and type of contract is as follows:
Total Headcount At Year End*
* excludes Non-Executive Directors (level 7)
Analysis By Type Of Contract
Permanent
Fixed Contract
2022
2,605
2020
2021
2022
90% 94% 89%
10%
6% 11%
Gender Analysis
Total*
2020
2021
2022
Male
Female
Male
Female
Male
Female
47% 53% 48% 52% 48% 52%
Senior Management**
63% 37% 64% 36% 62% 38%
Senior Management Direct
Reports***
-
-
-
-
52% 48%
Part-Time/Job Sharers
12% 88%
9%
91%
11% 89%
*Excludes Non-Executive Directors (level 7)
**Senior Management are Level 0, Level 1 and Level 2
***Senior Management Direct Reports are Level 3 and Level 4
Gender Pay Gap
We believe in being transparent about our
gender pay gap and the journey we are on.
As a purpose driven organisation, Diversity
and Inclusion is a core pillar of our culture.
For the third year in a row, we are proud
to publish our gender pay gap. This forms
part of our commitment to hold ourselves
accountable by tracking our progress
against our action plan which we put
in place as part of our Board approved
Diversity and Inclusion Strategy.
As at December 2022, the Bank’s gender
pay gap sits at 16.5%, down 1% from
our previously reported figure of 17.5%
in our published 2022 Gender Pay Gap
Report which was aligned to the legislative
snapshot date of June 2022.
A core principle of Permanent TSB’s
approach to Pay and Reward is ensuring
that that all employees, regardless of
gender, age or social or ethnic background,
are remunerated fairly and that no
differentiation exists in the pay of any
individual as a result of any of those
factors.
The Bank’s approach is founded on the
provision of equal pay for all for equal
work, or work of equal value as established
with reference to individual market
remuneration benchmarks determined
with reference to gender-neutral job
descriptions and role profiles and via the
use of salary ranges.
37
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 • Mobilising Wellbeing Month in
October, with a series of events and
communications dealing with topics
such as pension planning, bereavement,
meditation, budgeting and more; and,
• Rolling out the ‘At Your Own Pace
Race Series’ for a third year, a series
of virtual running events that engaged
our colleagues throughout Q4, while
raising money for our Community Fund
Partners.
The Bank has a safety statement
in place which documents how the
highest standards of Health and Safety
Management are maintained across the
organisation. The Safety Statement, and
associated policies and processes, have
been prepared in accordance with Section
20 of the Safety, Health and Welfare at
Work Act, 2005 (The Act). The Safety
Statement is reviewed on a regular basis
and is revised as necessary.
Representative Body Relationships
And Employee Consultation
Permanent TSB operates under an
established partnership model with our
formally recognised Representative Bodies
– Unite, Mandate and FSU.
Company representatives meet with the
internal committees and the full time
officials on a regular basis. This allows for
matters to be discussed in a structured
way and provides an opportunity to deal
with anything that may arise at inception,
greatly increasing the chances of internal
resolution.
All material organisational changes,
including changes to terms and conditions
of employment (to the extent they arise),
are discussed and negotiated in advance
with the Representative Bodies.
All employees receive regular updates on
organisational matters through a diverse
range of communication mechanisms.
Sustainability
(continued)
This approach supports our efforts -
through Recruitment, Selection, Talent
Development Strategies and HR Policies
and Processes - towards improving
our gender balance at all levels of the
organisation, with a particular focus on
improving the representation of female
colleagues at the Executive and Senior
Leadership levels.
We acknowledge that we have more to
do to close our gap and have a dedicated
action plan in place as part of our Board
approved Diversity and Inclusion Strategy.
Encouraging Employee Health, Safety
And Wellbeing
The wellbeing of our employees throughout
all stages of their career and personal
lives is of paramount importance to us.
As part of Permanent TSB’s investment
in employee wellbeing, we offer a range
of programmes and benefits to assist and
support our people.
As part of our Employee Proposition,
our people are provided with a range of
financial, physical and emotional health
and wellbeing programmes and benefits as
outlined:
The Bank has an Employee Health
Screening Programme that is made
available to all colleagues on an annualised
basis. We continued our commitment to
this programme by investing in an annual
free flu vaccination programme in order to
further safeguard the health, safety and
wellbeing of our people.
LiveWell – Our Employee Resource
Group On Wellbeing
The Bank has in place an Employee
Resource Group (ERG) called LiveWell that
includes representation from all areas of
the business. Together, LiveWell focus on
areas of employee wellbeing and support
in the delivery of programming for our
colleagues, including:
• Contributing to the Employee Resource
Group Page on Workvivo, our employee
communication application;
•
Introducing a ‘Get Ready, Get Set For
Life’ Campaign, supporting colleagues
with advice on Mortgages, banking
following a bereavement, Wills and
Pensions;
Wellbeing Offering
Financial
Pension Plan
Income Protection Benefit
Sick Pay Scheme
Staff Banking
Cycle To Work Scheme
Annual Travel Pass Scheme
Employee Discount Scheme
Holiday Fund
38
Physical/Emotional/Mental Health
Health Screening
Eye Testing
Employee Assistance Programme For
Colleagues And Their Spouse, Adult
Dependent Children And Dependent
Parents (Counselling Service)
Parental Supports (1:1 Career Coaching
For Parents And People Managers And
Supports For Parents And Carers Of
Toddlers To Teenagers)
Menopause Supports For Colleagues
And People Managers
Mental Health Training Addressing A
Variety Of Themes
A Range Of Health And Wellbeing
Related Information Sessions
Lifestyle/Wellbeing Workshops
Work Station Assessments (Both In
Office And At Home)
Education Support
Paid Maternity And Paternity Leave
MyLife App
Permanent TSB Group Holdings plc - Annual Report 2022 Championing Our
Customers & Creating
A Bank That Is Fit For The Future
Impact In Action:
Relationship Net Promoter Score
A customer brand tracking
survey carried out in
December 2022 indicated a
Relationship Net Promoter
Score* (RNPS) of +10,
maintaining our position
on last year and placing
Permanent TSB in 3rd position
among the retail banks in
Ireland
c.138 million logins on our
digital channels in 2022
113,000 new Current
Accounts and 43,000 new
Deposit Accounts opened
in 2022, a 47% and 85%
increase, respectively, on the
same period last year
47% of new Current Account
openings are now taking place
through the Bank’s award-
winning Digital Current
Account
Enabling customers to move
their banking relationship
through putting supports
in place to offer guidance,
convenience and support
Broadening our Business
Banking offering through
partnerships with Bibby
Financial Services, the
Strategic Banking Corporation
of Ireland, Digital Business
Ireland and Worldpay
* A Relationship Net Promoter Score (RNPS) is a
measure of customer advocacy towards a brand
and indicates the willingness of a customer to
recommend a company’s products or services to
others. The question asks customers how likely they
are to recommend their bank to friends or family on
the basis of their own experience. The range for the
scoring is -100 to +100.
Overview
Our ambition is to be Ireland’s best
personal and small business bank. Best
doesn’t necessarily mean the biggest, but
it does mean the being the best at what
we do for both our Personal and Business
Banking customers. We are committed
to understanding our customers and
delivering what matters most to them
through every stage of their financial
journey.
Delivering High Quality Products And
A Superior Customer Experience
Our purpose is to work hard every day to
build trust with our customers – we are
a community serving the community. In
order to deliver on our purpose, we are
focused on developing trusted banking
relationships with customers through:
listening to what they have to say;
developing products that matter most to
them; and, delivering a great customer
service experience, whether that be in
our network of branches, through our
customer service centres, online or via the
Permanent TSB App.
Examples of our commitment to delivering
high quality products and a superior
customer experience include: the ongoing
improvements delivered as a result of
our Voice of the Customer Programme;
the continued investment in digital
transformation and innovation; a range of
new supports to enable customers to move
their banking relationship to Permanent
TSB; and, broadening our service offering
for our Business Banking customers
through partnerships.
Listening To Our Customers And
Acting On Their Feedback
Permanent TSB has in place a customer
listening programme called Voice of the
Customer (VOC), designed to give our
customers a voice and create a channel for
two-way communication and feedback.
VOC enables us to collect customer
feedback from everyday interactions in our
Customer Contact Centres, Retail Network
and Digital channels in real time and turn
that insight into action.
The data received from the VOC surveys
provides the Bank with a valuable look
at what we are doing well, but more
importantly, highlights the areas of
opportunity available to improve both our
customer service offering and processes.
VOC feedback is reported weekly to key
stakeholders, including our customer
facing teams, Senior Leadership Team and
Executive Committee.
Investing In Digital Transformation
And Innovation
Our customers want the ability to interact
with us at a time and place that works for
them, and through the optimal channel.
In 2022, our customers continued to
engage with us through digital channels:
• c.683,000 active users of Open24 Web
and App, +20% on 2021
• c.138 million logins on both Open24 Web
and App, +18% on 2021
• 52,984 Digital Current Accounts opened
during 2022
• 94% of our Term Lending applications
are now being completed online
• 113 million contactless payments made
by Permanent TSB customers last year
Personal service will remain at the heart of
everything we do. However, as customer
needs have changed so profoundly, digital
is playing an ever increasing role in our
service offering.
Through our Digital Transformation
Programme, Permanent TSB has been
on a journey to transform our business,
committing €150 million in investment
in technology infrastructure and digital
services over the last number of years.
Significant progress was made during
2022 in enhancing our customers’ digital
offering. Actions taken include:
Digital Support For Our Customers
• Modernising our technology architecture,
delivering greater resilience and capacity
for future growth;
•
Introducing our new Open24.ie Online
Banking Platform, a new-look website
that provides customers with a simpler,
more modern experience, making
everyday banking easier through more
streamlined navigation;
39
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Sustainability
(continued)
• Further embedding our digital customer
journeys, such as our award winning
Digital Current Account and our Own
A Home Digital Mortgage Application
Journey;
•
Introducing joint applications for our
Digital Current Account;
• Enhancing our existing Digital Credit
Card and Overdraft customer journeys to
support new-to-Bank customers;
• Launching a new Digital Current Account
application process for Business
Banking customers; and,
• Leveraging Artificial Intelligence (AI)
technology within some of our key
customer journeys.
Digital Support Across Our
Workplace
• Continuing to retrofit our branches to
include the latest in digital technology,
enabling greater customer engagement;
• Continuing to enhance the technology
in our Contact Centres to better support
our customers;
• Ongoing introduction of digital workplace
technology to support our colleagues as
they continue to transition into our new
hybrid working model; and,
•
Introducing Workvivo, our new
application based colleague
communication tool, delivering more
targeted colleague communications and
encouraging two-way engagement.
These service offerings allow us to support
our customers further, allowing them to
bank in a way that is more convenient,
flexible and secure. We look forward to
building on this momentum with further
digital rollouts planned for the year ahead,
including: the introduction of the next
generation of our mobile app; and, the
implementation of digital supports for our
Business Banking customers.
Transforming Our Retail Network
At Permanent TSB, we believe that our
branches are a vital part of our business
model and that the key to safeguarding
their future is to make them efficient. For
us that’s about delivering the innovative
digital solutions that our customers are
asking for, while also providing that in-
person support.
Over the last number of years, Permanent
TSB has committed more than €30 million
40
in funding to transform our branches,
allowing us to better serve our customers
via a channel of their choosing.
Our refurbished branches now have
enhanced digital capabilities including,
digital marketing screens that reduce our
reliance on print marketing, iPads with
supporting phone lines into our customer
service centre, Open24, state of the art,
purpose-built customer meeting areas
and the latest ATM and SSBM technology
that allows us to accept cash and cheque
lodgements across many branches in our
network 24/7.
We remain committed to providing a
personal service for customers, and
combining that personal service with the
best that digital technology has to offer. We
look forward to building on this momentum
with further refurbishments planned,
including a €25 million investment in the 25
branch locations that the Bank acquired as
part of the Ulster Bank transaction in the
Republic of Ireland. All 25 branch locations
will maintain cash services, while being
upgraded to include the latest in digital
technology.
A Market-Leading Digital Current
Account
In 2021, the Bank launched a market-
leading, award winning Digital Current
Account offering to the market, which
facilitates a fast and easy account opening
process in minutes via the Permanent TSB
App. The release has proven successful,
with 47% of new Current Accounts being
opened via the App last year.
As well as being popular amongst our
customers, the introduction of the Digital
Current Account has also enabled the
Bank to reduce its environmental footprint.
Through the launch, we estimate that we
eliminate c.85 pages of paper from our
business for every application that comes
through the online channel. In addition to
the Digital Current Account, we have also
introduced online applications for Term
Lending, Credit Cards and Overdrafts,
further reducing our reliance on paper.
We are now in the early stages of release
for a new Digital Mortgage Journey, which
will see us eliminate c.250 pages of paper
for every digital application.
The Bank was proud to win Best Current
Account at the Bonkers National Consumer
Awards, as well as the Innovative Banking
Product Award at the FS Awards, for our
Digital Current Account opening process
during 2022.
Extending Our Award Winning
Cashback Mortgage
In 2022, the Bank was pleased to extend its
award winning 2% & 2% Mortgage until 31
March 2024.
Launched in 2017, the proposition
was the first of its kind in Ireland and
enables customers to get 2% cashback
at drawdown and 2% cashback on their
monthly repayments until 2027, when they
pay using their Explore Current Account.
Last year, the Bank was proud to be
awarded the Best First Time Buyer
Mortgage at the 2022 Bonkers.ie National
Consumer Awards for the proposition, for
the fourth year in a row.
Enabling Customers To Move Their
Banking Relationship
We recognise that moving to a new bank
is not easy. During 2022, Permanent
TSB put a number of supports in place to
offer guidance, convenience and support
to customers in moving their banking
relationship to us, following the exit of
Ulster Bank and KBC from the Irish Market.
The initiatives were delivered through a
multichannel approach across both our
digital channels and branch network, and
included the following:
• Encouraging the use of our award
winning Digital Current Account offering
which facilitates a fast and easy account
opening process;
• Opening a new Current Account
Switching Hub in at our location on St.
Stephen’s Green in Dublin to facilitate
appointments or walk-in customers who
wish to open a new Current Account;
Introducing mobile and pop-up locations
in communities across the country;
Increasing opening hours to include
Saturday in selected locations;
•
•
• Participating in Ulster Bank’s Provider
Presence initiative, enabling Permanent
TSB staff to work in more than 40 Ulster
Bank branches to facilitate customers of
that branch who need to switch;
Permanent TSB Group Holdings plc - Annual Report 2022 • Creating a dedicated webpage
(permanenttsb.ie/movingbankhub)
to provide step-by-step guidance to
customers looking to switch one or
multiple products to Permanent TSB;
•
Introducing a dedicated webpage
(permanenttsb.ie/inyourcommunity/)
to enable customers to learn where and
when to find their nearest Permanent
TSB Mobile Branch, Permanent TSB
team member in an Ulster Bank Branch
or Permanent TSB Digital On-Boarding
Stand to support them in moving their
banking relationship; and
• Releasing our multichannel Move
Better marketing campaign across TV,
Radio, Outdoor, Digital and Social Media
channels.
Programming has proven successful,
seeing the Bank open 113,000 new
Current Accounts and 43,000 new Deposit
Accounts, a 217% and 85% increase,
respectively, on the same period last year.
Supporting Our Business Banking
Customers
Permanent TSB’s Business Banking
Strategy is focused on partnering with
our Business customers, not just in terms
of supporting their banking needs, but
through acting as trusted advisers to help
them to manage and grow their business.
In 2022, we continued the expansion of
our business customer offering through
deepening our partnership with the
Strategic Banking Corporation of Ireland
(SBCI), committing €32 million in low-
cost loans under the Irish Government’s
Brexit Impact Loan Scheme for SMEs.
The additional funding brings our total
commitment to €82 million, to date.
Through the partnership, SMEs will benefit
from lower borrowing rates and more
attractive borrowing terms as the loans
will be 80% guaranteed by the SBCI, which
was set up by the Irish Government to
enhance access to low-cost finance for
SMEs through banks and other lenders.
The partnership has proven successful
with more than €37 million in funding
drawn down during 2022.
Additional actions taken to support our
Business Banking customers last year
include:
• Launching a new Digital Current Account
for Business Banking customers;
•
Introducing a new Regional Business
Banking Hub in our Patrick Street
location in Cork, enabling us to continue
to support our Business Banking
customers as they work to grow their
business;
• Continuing to collaborate with partners
to enable us to broaden our service
offering, including, Bibby Financial
Services for invoice finance and
Worldpay for merchant acquiring;
• Partnering with Sentenial to enhances
the Bank’s payment solutions;
• Renewing our partnership with Digital
Business Ireland (DBI) for an addition
two-year term, further supporting our
Business Banking customers to migrate
their business to online channels through
the supports offered by DBI;
• Announcing our title sponsorship of the
Digital Business Ireland National Digital
Awards for the third year in a row;
• Supporting the Small Firms Association
(SFA) National Business Manufacturing
Category Award, encouraging excellence,
achievement and innovation amongst
small businesses of all sectors;
• Training and upskilling provided to our
people, with a special focus on systems,
processes, targeted sector lending
and sustainability – which included the
delivery of a bespoke training program
in partnership with Teagasc to support
responsible lending activity within the
Agriculture sector; and,
• Ongoing recruitment of sector and
market expertise within our Business
Banking team.
In 2023, we are committed to going further,
with a dedicated programme of work
planned which will include a focus on digital
innovation and the introduction of new
products, propositions and services. This
will include the introduction of a new Asset
Finance Business as part the Ulster Bank
transaction in the Republic of Ireland.
Digital Business Ireland
In 2022, we were proud to announce
the renewal our partnership with Digital
Business Ireland (DBI), Ireland’s dedicated
e-business representative body, for an
additional two-year term.
Through the partnership, Permanent TSB
provides programme funding to support
Digital Business Ireland, as it continues to
work in tandem with its membership, to
help businesses grow, scale and digitally
transform, post-pandemic.
The ongoing collaboration between the
Bank and DBI will enable the agency to
further grow its extensive network of over
8000 members, providing an enhanced
suite of supports and opportunities.
These include its complimentary advisory
services, training events, and its annual
National Digital Awards programme, of
which Permanent TSB is the title sponsor.
Over the last year, we have built a strong
partnership with DBI delivering supports
for Irish Business, including:
• c.650 businesses received training on
digital strategy which helped them to
turbo-charge their online growth;
• 1000s of SMEs received advice and
support, through collaboration with
Digital Business Ireland affiliate
membership bodies;
• Supporting Digital Business Ireland to
deliver the inaugural Business Beyond
Borders, a one day conference and expo
for SMEs that wish to harness the power
of digital business; and,
• More than 400 businesses entered
the Digital Business Ireland National
Digital Awards, proudly supported by
Permanent TSB, with 21 winners and
runners-up spotlighted across three
categories; Website, Innovation and
People.
We look forward to building on this
momentum and continuing to support Irish
businesses to scale and grow.
41
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Sustainability
(continued)
Guaranteed Irish
In 2022, Permanent TSB was proud
to partner with Guaranteed Irish to
deliver the inaugural Guaranteed Irish
Business Awards, celebrating businesses
that support jobs, communities and
provenance, while contributing to Ireland,
its people, and its economy.
Since 1974, Guaranteed Irish has been
a business membership networking
champion in Ireland. Their network
consists of over 2000 member businesses,
employing over 120,000 people across
the country and generating an annual
combined Irish turnover of €13 billion.
Throughout our 200-year history, the
Bank has been committed to delivering
exceptional customer service and
connecting with local communities. In
2021, we were proud to be the first Retail
Bank to be awarded the Guaranteed Irish
Symbol for our contribution to communities
across the country.
We look forward to deepening our
partnership with Guaranteed Irish through
our support of the annual Business Awards,
recognising the outstanding contribution of
Irish business on a national scale.
Cyber Security
The Irish banking landscape is changing
rapidly and the Bank recognises the
fundamental role that we play in protecting
both our customers and our business from
online security threats.
Led by our Chief Technology Officer, our
Technology Team constantly monitor
cyber security threat levels, in addition to
completing horizon scanning. Based on
threat intelligence, the Bank prioritises
investment in cyber defences and
implements preventative measures
accordingly. Proactive planning, ongoing
vigilance and enhanced monitoring are key
to our approach to cyber safety within the
organisation.
In order to set out our commitments to
protect both customers and the Bank,
control requirements are defined within
Permanent TSB’s Information Security
Management System.
42
In addition, to support our workforce in
navigating the online world in a safe and
responsible way the Bank continues to
invest in learning and development, with
compulsory cyber security training and
awareness campaigns delivered to all
colleagues on an annual basis.
Data Protection
At Permanent TSB, building trust with
customers is at the heart of our purpose.
In today’s digital era, data protection threat
continues to evolve and as such, protecting
and safeguarding our customers’ and our
colleagues’ personal data remains one of
our key priorities.
Our day-to-day business activities require
the processing of personal data. While
Data Protection is a fundamental right
under the EU Charter of Fundamental
Rights, protected by both European
and Irish legislation of which the Bank
complies, Permanent TSB has its own Data
Protection Policy in place which sets out
our approach.
Complying with the requirements and
principles of the Policy is a condition of
employment for our people. The Bank
has in place procedures to deal with data
security breaches and reports regularly to
the Executive Committee and Board.
Implementing organisation-wide
programmes, raising awareness and
providing ongoing education and training
to our people are critical ways in which we
mitigate against data protection risk. Data
Protection training was delivered to all
colleagues last year.
Responsible Marketing And Research
All marketing and communications
activity in the Bank is guided by regulation,
including the Consumer Protection
Code 2012, the Advertising Standards
Association of Ireland (ASAI) Code 7th
Edition and, the values and operating
principles set by the Association of Irish
Market Research Organisations (AIMRO).
Living Our Purpose & Ensuring Strong
Corporate Governance
The Board of Directors approved the
Sustainability Strategy and ensures
Management have comprehensive plans
in place for achievement of the Bank’s
sustainability objectives. Permanent
TSB’s Chief Executive receives regular
updates regarding the implementation of
the Strategy, and progress against KPIs
is reported upward to both the Executive
Committee and the Nominations, Culture
and Ethics Board Committee on a quarterly
basis.
To support the above, the Bank has in
place a Sustainability Committee (SusCo)
which operates as a Sub-Committee of
the Executive Committee. The SusCo is
chaired by the Chief Human Resources
Officer and Corporate Development
Director and includes representation from
Executive Committee members and Senior
Leaders representing business units
across the organisation. The Committee
meets at regular intervals throughout the
year to review and direct the development
of programming, with a clear focus on the
Environmental, Social and Governance
(ESG) factors that are core to operating our
business in a responsible and sustainable
way.
A dedicated Sustainability Team is in
place to provide leadership and coordinate
enterprise-wide activity, with the support
of the SusCo.
For more on Governance, please refer to
the Directors’ Report on page 89.
Operating Responsibly
Permanent TSB is committed to operating
responsibly and conducting our business
to the highest ethical and professional
standards. We are similarly committed,
under our Sustainability Strategy, to
building trust and playing an active role in
communities across the country.
We are focussed on upholding the highest
standard of conduct and behaviour among
our people. This is not just a ‘nice-to-have’
– it is a commitment that underpins how
we work together, our relationship with
Permanent TSB Group Holdings plc - Annual Report 2022 society, and, most importantly, how we
build trust with our customers and play an
active role in the communities where we
live and work.
Colleague Conduct Policy
The Bank has in place a Colleague Conduct
Policy, an overarching framework which
includes the policies and procedures
that are integral to upholding high
standards of colleague conduct across
the organisation. The Policy sets out the
behaviours expected of our people, and
lays out the requirements for the effective
management of those behaviours within
the Bank to ensure that our customers and
colleagues are treated in the right way.
Permanent TSB has a zero tolerance
for inappropriate colleague conduct. A
colleague conduct paper is produced and
presented to the Board on a bi-annual
basis that gives qualitative and quantitative
updates on key colleague related policies
and procedures over the period, in line with
our Colleague Conduct Policy.
The Colleague Conduct Policy takes
into consideration a number of other
documents that encourage appropriate
colleague conduct and behaviour, including
our Code of Ethics and Speak Freely.
In addition, the Colleague Conduct Policy
gives consideration to our Dignity and
Respect Code and our Equality through
Diversity and Inclusion Charter, recognising
the responsibility we have to respect
and protect the human rights of every
individual that works for us.
Code Of Ethics
The Bank has in place a Code of Ethics that
provides a general framework for expected
behaviour and guides our workforce in
doing the right thing. It codifies how best
to interact with our stakeholders and
provides standards that colleagues must
follow in both their professional life, and
in conducting their own personal financial
affairs. It is there to protect us from
unacceptable behaviour and minimise
opportunities for misconduct.
Complying with the requirements and
principles of the code is a condition of
employment for our people. The Bank has
in place procedures to deal with breaches
of the Policy and reports to the Executive
Committee and Board on a half-yearly
basis.
The Board supports a zero risk appetite
for deliberate and/or repeated poor or
unfair customer outcomes (financial or
non-financial), or any market impact which
arises through inappropriate actions, or
inactions in the execution of our business.
Any instances of breaches are reported
throughout the year.
To further support the above, the Bank
introduced the industry wide DECiDE
(Ethical Decision Making) Framework. This
was incorporated into Ethics training which
was delivered virtually to all employees last
year.
The DECiDE Framework communicated
across all areas of the Bank and
included an interactive animation which
demonstrated to colleagues how the
Framework can be used within every day
decision making. At a more strategic level,
the Bank also introduced the ‘Yes Checks’,
which now form an integral part of decision
making within the Bank’s Committees.
Speak Freely
To support the cultural evolution of
Permanent TSB, the Bank has developed
an alternative approach to simplifying
and clarifying the channels by which
an employee can speak up and raise a
concern; namely, Speak Freely.
Speak Freely, and associated procedures,
protects employees who wish to make a
protected disclosure, relating to an actual
or potential wrongdoing in the workplace.
The Bank has in place procedures to deal
with any protected disclosures that may
arise as part of Speak Freely and reports to
the Executive Committee and Board on a
half-yearly basis.
You can read more about our commitment
to Speak Freely in 2022 on page 18.
Human Rights
Permanent TSB recognise our
responsibility to respect the human rights
of every individual. The Bank ensures the
protection of our colleagues’ human rights
through its Dignity and Respect Code and
Equality through Diversity and Inclusion
Charter. The Code and the Charter focus
on the prevention of discrimination, the
provision of equal opportunities and ensure
that employees are treated with dignity and
respect in the workplace.
We acknowledge our responsibility to
respect human rights as set out in the
International Bill of Human Rights and the
eight fundamental conventions on which
the United Nations Guiding Principles on
Business and Human Rights are based.
In order to mitigate against human rights
risk, or violations that may occur, the
Bank has comprehensive due diligence
procedures in place, which include: the
implementation of a Colleague Conduct
Policy that establishes the requirements
for the effective management of
appropriate behaviours within the Bank;
procedures for ensuring that we meet all
relevant human rights legislation in the
jurisdictions in which we operate; and, a
suite of reporting mechanisms through
our Speak Freely channels to support the
timely reporting of issues.
The Human Resources Team monitor
all nonadherences to the Code and the
Charter. Procedures are in place for dealing
with suspected human rights allegations
and reported instances are addressed on a
timely basis.
In addition, the Bank has in place additional
requirements set out in other policy
documents that help to encourage the
right behaviour, including: Conflict of
Interest; Anti-Money Laundering/Terrorist
Financing; Sanctions and, Anti-Bribery and
Corruption.
Conflict Of Interest
Conflict of Interest occurs when an
employee’s personal relationships,
participation in external activities or
interest in another venture influence or
could be perceived to influence a business
decision. Permanent TSB has in place
43
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 thereafter, conducting enhanced due
diligence reviews and undertaking PEPs
and Sanctions screening in accordance
with our Policies.
Policy Governance
Permanent TSB is committed to mitigating
the Environment, Social and Governance
(ESG) risks associated with its business
activities and complying with all laws and
regulations in the jurisdictions in which
it operates. We manage our ESG risk
through the effective implementation
of our Sustainability Strategy outlined
in this report and through the effective
application of policies and procedures that
are integral to operating our business in a
responsible way.
All policies that the Bank has in place to
protect our workforce meet the relevant
regulatory requirements, adhere to
Permanent TSB’s Document Management
Standards and Procedures Policy and are
reviewed and updated as appropriate, on
an annual basis.
Policies are monitored by their respective
policy owners, communicated as required
and made available to our colleagues on our
internal website.
Looking Ahead
As we look to grow our programming
through 2023 and beyond, our focus is on
long term sustainability, the role that the
Bank will play in tackling climate change
and supporting the transition to a low
carbon economy.
We are similarly conscious of the regulatory
landscape and the legislative changes that
shape non-financial reporting.
We will provide annual updates on our
sustainability programming through our
Non-Financial Report.
Sustainability
(continued)
a Conflict of Interest Policy to provide
guidance to employees and to ensure
that the Bank proactively manages both
personal and organisational Conflict of
Interest.
Every employee is responsible for
identifying, reporting and managing
Conflict of Interest and, in doing so, must
comply with the letter and spirit of the
Policy.
The Bank has in place procedures to deal
with Conflict of Interest that may arise.
The Human Resources Team monitors
adherence to this Policy and reports to the
Executive Committee and Board on a half
yearly-basis.
Financial Crime Compliance
Permanent TSB maintains an overarching
Financial Crime Compliance Framework,
which includes three supporting policy
documents relating to Money Laundering/
Terrorist Financing, Sanctions and Bribery
and Corruption Risk. The Framework and
related Policies set out how the business
adheres to all laws and regulations relating
to financial crime compliance and how
these risks are managed within the Bank.
An assessment of the specific Money
Laundering/Terrorist Financing and
Sanctions Risk faced by the Bank is
undertaken annually, and a review of the
Bribery and Corruption Risk relevant to the
Bank’s business is also completed on a
periodic basis. Financial crime compliance
training, which covers Money Laundering/
Terrorist Financing, Sanctions and Bribery
and Corruption Risk, is provided to all
employees each year, with tailored training
provided to the Board of Directors and
members of the Executive Committee.
Permanent TSB is committed to
managing and mitigating the financial
crime compliance risk associated with
its business activities and complying
with all applicable Money Laundering/
Terrorist Financing, Sanctions and Bribery
and Corruption laws and regulations in
the jurisdictions in which it operates. In
order to mitigate against any financial
crime compliance related risk that may
occur, the Bank has comprehensive due
diligence procedures in place, which
include requesting documents such as
proof of identity and proof of address
at account opening and at intervals
44
Permanent TSB Group Holdings plc - Annual Report 2022 Financial Review
The Group’s financial performance in 2022
has been shaped primarily by the Ulster
Bank Transaction, with the one off gain
significantly bolstering the Group’s capital
base. This has been offset by a significant
investment in managing the successful
execution and migration of the business
transfer during 2022, resulting in an overall
profit after tax for the year of €223m.
Overall operating income has increased
from the prior year. Rising ECB base rates
has eliminated the negative yield on the
Bank’s excess liquidity position and has
improved yields on the Bank’s tracker
mortgage book, resulting in higher net
interest income. The impact of global
inflationary pressures along with continued
investment in our people and our digital
offering has led to an increase in operating
costs.
The Group continued to manage its capital
and liquidity positions carefully during
2022, with an expected reduction in excess
liquidity occurring on completion of the
Ulster Bank Transaction in Quarter 4 2022.
The liquidity and capital positions of the
Group remain well above all minimum
regulatory requirements, with transitional
CET1 and total capital sitting at 16.2% and
22.3% respectively.
Asset quality has remained strong
during 2022. The addition of c.€5.2bn of
performing loans has brought the Group’s
NPL ratio to 3.3%. While the overall
improvement in risk profile of the book has
resulted in a write-back of impairment, the
Group continues to monitor and manage
carefully the impact of inflation on our
customers and any future expected credit
losses.
Overall, the outlook for the Banking sector
is positive. As we continue to integrate the
remaining elements of the Ulster Bank
Transaction, the Group expects to deliver
continued profitability in the medium term.
Ulster Bank Transaction
On 17 December 2021, the Bank entered
into a legally binding agreement with
NatWest Group Plc to acquire certain
elements of the Ulster Bank Retail, SME
and Asset Finance business in the Republic
of Ireland. On 7 November 2022, the
transaction was completed when €5.2bn of
the Retail business assets and significant
processes were acquired by the Bank
thereby legally binding the Bank to acquire
the remaining Retail, SME and Asset
Financing assets. The Bank incurred costs
of €97m on the transaction in 2022, of
which €92m are recognised as exceptional
costs in the income statement. This
transaction is referenced throughout the
book as the Ulster Bank transaction.
Basis of preparation
The financial review is prepared using
International Financial Reporting Standards
(IFRS) and non-IFRS measures to analyse
the Group’s financial performance for the
financial year ended 31 December 2022.
Non-IFRS measures are used by
Management to assess the financial
performance of the Group and to provide
insights into financial and operational
performance on a consistent basis
across various financial years. They also
provide details regarding the elements of
performance which the Group considers
important in its performance assessment
and which it can influence.
Non-IFRS measures are however not a
substitute for IFRS measures and IFRS
measures should be preferred over non-
IFRS measures where applicable.
The Group has a tightly drawn accounting
policy for exceptional items (see note 1)
and exceptional items are considered to
include:
• Profit/loss on disposal of businesses;
• Gain on bargain purchase in respect of
business combinations;
• Profit/loss on material deleveraging
prior to 31 December 2021, including any
increase in impairment arising solely due
to the sale of NPLs becoming part of the
Group’s recovery strategy;
• Material restructuring costs; and
• Material transaction, integration
and restructuring costs associated
with acquisitions (including potential
liquidations).
However, from time to time certain material
non-recurring items occur which do not
meet the definition of exceptional items as
set out in the accounting policy. To assist
the users of the financial statements and
to ensure consistency in reporting with
other financial institutions, these items
are disclosed separately from underlying
profit in the financial review. These items
are clearly identified as non-IFRS items
and reconciled back to the IFRS income
statement.
A reconciliation between the underlying
profit and operating profit on an IFRS basis
is set out on page 52.
Management has provided further
information on IFRS and non-IFRS
measures including their calculation in the
Alternative Performance Measures (APM)
section on pages 270 to 276.
45
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Financial Review
(continued)
Basis of calculation
Percentages presented throughout the financial review are calculated using absolute values and therefore the percentages may differ
from those calculated using rounded numbers.
Management performance summary consolidated income statement
Net interest income
Net fees and commissions income
Net other income
Total operating income (excl. exceptional items and other non-recurring items)
Total operating expenses (excl. exceptional items and other non-recurring items, bank
levy and other regulatory charges)*
Bank levy and other regulatory charges
Underlying profit before impairment**
Impairment write-back on loans and advances to customers
Underlying profit before exceptional and other non-recurring items
Exceptional items comprise:
Gain on bargain purchase
Costs incurred in relation to Ulster Bank transaction
Impairment write back arising from deleveraging of loans
Restructuring and other costs
Other non-recurring items comprise:
Impairment charge on Ulster Bank transaction
Impairment charge on deleveraging of loans post 2021
Other items relating to Ulster Bank transaction*
Charges in relation to legacy legal cases
Profit/(loss) before taxation
Taxation
Profit/(loss) for the year
* Expense offset by non-recurring income
** See table 8 on page 52 for a reconciliation of underlying profit to operating profit on an IFRS basis.
Year ended
Year ended
Table
31 December
2022
31 December
2021
€m
€m
1
3
4
5
6
7
7
362
42
5
409
(344)
(51)
14
31
45
265
362
(92)
8
(13)
(43)
(30)
(8)
(1)
(4)
267
(44)
223
313
35
13
361
(295)
(50)
16
1
17
(23)
-
(28)
19
(14)
(15)
-
-
-
(15)
(21)
1
(20)
46
Permanent TSB Group Holdings plc - Annual Report 2022
Management performance summary consolidated income statement - key highlights
• Total operating income (excl exceptional items) has increased by €48m during 2022 primarily due to:
- Net interest income increased by €49m (16%) during 2022 to €362m. The increase is mainly driven by the Bank’s excess liquidity
reserve no longer attracting negative yields in 2022, the impact of increases in ECB interest rates on tracker book mortgages and
increased income as a result of the migration of the Ulster Bank performing loan assets in the second half of the year. This is offset
by increases in wholesale funding costs.
- Net fees and commission income was €42m for the year ended 31 December 2022 compared to €35m at 31 December 2021. The
increase is mainly due to growth in customer numbers and an increase in transactional activity.
- Net other income was €5m for the year ended 31 December 2022 compared to €13m at 31 December 2021. Net other income
primarily comprises accounting gains generated from sales of properties which were transferred as part of a historic voluntary
surrender scheme.
• Operating expenses (excl. exceptional items and other non-recurring items, bank levy and other regulatory charges) are €344m
for the year ended 31 December 2022 compared to €295m at 31 December 2021. The increase is driven by significant investment in
digital and strategic projects in 2022, increased staff costs and increased amortisation of capitalised digital costs spent in previous
years.
• Underlying profit before impairment has decreased by €2m since 31 December 2021. This is due to an increase in total operating
expenses as investments in digital and strategic projects have increased.
•
Impairment write-back is €31m on loans and advances to customers for the year ended 31 December 2022, compared to a write-
back of €1m for the year ended 31 December 2021. This reflects the overall improvement in risk profile of the book whilst maintaining
an appropriate level of provisions in light of high levels of inflation within the current economic environment.
• Exceptional items of €265m for the year ended 31 December 2022 comprises €362m relating to the gain of bargain purchase offset
by €92m of costs – both of which are related to the Ulster Bank transaction, €8m relating to an impairment write-back arising from
deleveraging of loans and €13m in restructuring charges relating to the Group’s Enterprise Transformation Programme and costs
arising in respect of a previous disposal of a business.
• Other non-recurring items amount to a charge of €43m for the year ended 31 December 2022. They comprise €30m relating to the
day 1 impairment charge on Ulster Bank loans, €8m relating to an impairment charge arising from deleveraging of a loan portfolio
during 2022, €1m relating to other costs on the Ulster Bank transaction and €4m in provisions relating to legacy legal cases.
• Profit before tax of €267m for the year ended 31 December 2022 compared with a loss before tax of €21m for the year ended 31
December 2021. This is primarily due to the net impact of the Ulster Bank transaction and an improvement in net interest income.
Net interest income
Net interest margin
€362m
1.54%
Table 1: Net Interest Income
Interest income
Interest expense
Net interest income
Net interest margin (NIM)
Year ended
Year ended
31 December
2022
31 December
2021
€m
€m
417
(55)
362
1.54%
354
(41)
313
1.51%
Interest income
Interest income of €417m for the year ended 31 December 2022 increased by €63m (18%), compared to the prior year. This is mainly
driven by the following:
• organic growth of the performing loan book with higher new lending than redemptions and repayments;
•
increased income on loans linked to ECB marginal rate; and
• the migration of Ulster Bank performing mortgage loans in Q4 2022.
47
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Financial Review
(continued)
Interest expense
Interest expense increased by €14m to €55m for the year ended 31 December 2022, which reflects higher funding costs associated with
the increase in ECB interest rates during the year.
Table 2: Average balance sheet
Interest-earning assets
Loans and advances to customers
Debt securities and derivative assets
Loans and advances to banks
Total average interest-earning assets
Negative interest earning assets
Loans and advances to banks1
Total average negative interest earning assets
Interest earning assets
Interest-bearing liabilities
Customer accounts
Debt securities in issue
Lease liabilities
Subordinated liabilities
Deposits by banks2
Total average interest bearing liabilities
Negative interest earning liabilities
Deposits by banks
Total average negative interest earning liabilities
Interest-bearing liabilities
Total average equity attributable to owners
Net Interest Margin
Year ended 31 December 2022
Year ended 31 December 2021
Average
Balance
Interest
Average
Yield/Rate
Average
Balance
Interest
Average
Yield/Rate
€m
€m
%
€m
€m
%
15,099
2,849
5,521
23,469
-
-
23,469
20,171
628
29
252
1,377
22,457
-
22,457
1,885
1.54%
387
15
15
417
-
-
417
11
16
-
8
20
55
-
2.56%
0.53%
0.27%
1.79%
-
-
1.79%
0.05%
2.55%
-
3.17%
1.45%
0.24%
-
55
0.24%
14,258
2,533
-
16,791
3,940
3,940
20,731
18,606
705
31
155
346
7
-
353
(14)
(14)
339
14
8
-
5
2.43%
0.28%
-
2.10%
(0.36%)
(0.36%)
1.64%
0.08%
1.13%
-
3.23%
19,497
27
0.14%
(1)
(1)
26
(0.75%)
(0.75%)
0.13%
134
134
19,631
1,853
1.51%
* The above table is based on the average balances of assets and liabilities and will not agree to gross interest income and gross interest expense. The overall interest amount
will agree to NII.
1 Loans and advances to banks was a negative interest-earning asset for 2021 and an interest-earning asset for 2022 (on an overall yearly basis)
2 Deposits by banks was a negative interest earning liability for 2021 and an interest bearing liability for 2022 (on an overall yearly basis)
Net interest margin
NIM increased by 3bps to 1.54% for the year ended 31 December 2022 compared to 1.51%% for the prior year. The NIM of the Group has
grown due to an increase in interest rates along with an increase in new lending,
Interest income/average interest earning assets
•
Interest income on loans and advances to customers increased by €41m due balance sheet growth, the pass-through of ECB rate
increases to tracker mortgage customers and the addition of mortgages from Ulster Bank in Q4 2022.
Interest income on debt securities and derivative assets increased by €8m due to lower yielding debt securities being replaced by
higher yielding assets due to interest rate increases.
Interest income on loans and advances to banks increased by €29m due to ECB rate rises reversing negative yields on excess liquidity
held with the central bank during 2021. The average balance of loans and advances to banks increased by €1,581m during the year.
This balance consist of excess cash reserves with the CBI, and its movement is driven primarily by increase in customer deposits
along with proceeds from deleveraging activity.
•
•
48
Permanent TSB Group Holdings plc - Annual Report 2022
Interest expense/average interest bearing liabilities
•
Interest expense decreased in customer accounts despite the average balance increasing by €1,565m. This reduction is due to
changes in the customer product mix profile.
•
Interest expense on debt securities in issue increased by €8m during the year due to additional debt issuances being issued at higher
rates.
• The average balance of deposits by banks increase due to a change in funding mix resulting in high volumes of repurchase
agreements. The average balance of subordinated liabilities increased by €97m which has resulted in additional interest expense in
2022.
Average equity attributable to owners
The average equity attributable to owners increased in the year due to the issuance of AT1 securities and new shares as part of the
Ulster Bank transaction.
Net fees and
commissions income
€42m
Table 3: Net fees and commissions income
Retail banking and credit card fees
Brokerage and insurance commission
Other fees and commissions income
Fees and commission income
Fees and commission expense*
Net fees and commission income
Year ended
Year ended
31 December
2022
31 December
2021
€m
65
9
1
75
(33)
42
€m
52
11
1
64
(29)
35
* Fees and commission expenses primarily comprises retail banking and credit cards fees
Net fees and commission income was €42m for the year ended 31 December 2022 compared to €35m at 31 December 2021. The
increase is mainly due to growth in customer numbers and an increase in transactional activity.
Net other income
€5m
Table 4: Net other income
Other income
Net other income
Net other income was €5m for the year ended 31 December 2022 compared to €13m at 31 December 2021. This decrease reflects a
reduction in properties in possession sold during 2022 compared to the previous year.
Year ended
Year ended
31 December
2022
31 December
2021
€m
5
5
€m
13
13
49
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Financial Review
(continued)
Total operating
expenses (1)
€395m
Adjusted cost
income ratio
84%
(1) Excluding exceptional and other non-recurring items, bank levy and other regulatory charges.
Table 5: Total operating expenses
Staff costs
Wages and salaries including commission paid to sales staff
Social insurance
Pension costs
Total staff costs
Other general and administrative expenses
Administrative, staff and other expenses
Depreciation of property and equipment
Amortisation of intangible assets
Reversal of impairment on property and equipment
Total operating expenses (excluding exceptional and other non-recurring items, bank levy and
regulatory charges)
Bank levy
Other regulatory charges
Total operating expenses (excluding exceptional and other non-recurring items items)
Headline cost to income ratio*
Adjusted cost to income ratio**
Closing staff numbers***
Average staff numbers
Year ended
Year ended
31 December
2022
31 December
2021
€m
€m
124
15
13
152
141
293
21
31
(1)
344
22
29
395
96%
84%
2,614
2,422
115
14
13
142
106
248
21
26
-
295
22
28
345
96%
82%
2,236
2,286
*Defined as total operating expenses (excluding exceptional and other non-recurring items) divided by total operating income.
**Defined as total operating expenses (excluding exceptional, other non-recurring items, bank levy and regulatory charges) divided by total operating income.
***Closing staff numbers are calculated on a FTE basis.
Operating expenses
Staff costs
Total staff costs have increased by €10m (7%) from €142m for the year ended 31 December 2021 to €152m for the year ended 31
December 2022 primarily due to increases in average salaries as a result of a new pay deal with staff in 2022 and an increase in staff
numbers.
General and administrative expenses
General and administrative expenses increased by €35m for the year ended 31 December 2022 to €141m due to the acceleration of
investment in the digital transformation programme and the effect of cost inflation pressures.
Amortisation of intangible assets
The increase in the amortisation expense of €5m reflects increased capital spending in software development as a result of various
investments in digitisation projects over the prior and current years.
50
Permanent TSB Group Holdings plc - Annual Report 2022
Adjusted cost income ratio
Operating costs (excluding exceptional and other non-recurring items, bank levy and regulatory charges) of €344m and operating income
of €409m for the year ended 31 December 2022 led to an adjusted cost income ratio of 84% for 2022, compared to an adjusted cost
income ratio of 82% for the year ended 31 December 2021. The adjusted cost income ratio remained broadly consistent year on year.
Bank levy and other regulatory charges
Bank levy and other regulatory charges amounted to €51m for the year ended 31 December 2022. Other regulatory charges include
€19m for the Deposit Guarantee Scheme (DGS) (31 December 2021: €17m). The Single Resolution Fund (SRF) fee for the year ended 31
December 2022 was €5m (31 December 2021: €4m).
Impairment
€31m write-back
Table 6: Impairment
Total impairment write-back on loans and advances to customers
Year ended
Year ended
31 December
2022
31 December
2021
€m
31
€m
1
The impairment write-back is €31m on loans and advances to customers for the year ended 31 December 2022, compared to a write-
back of €1m for the year ended 31 December 2021. This reflects the overall improvement in risk profile of the book whilst maintaining a
prudent level of provisions in light of high levels of inflation within the current economic environment.
Exceptional and other
non-recurring items
€(222)m
Table 7: Exceptional and other non-recurring items
Exceptional items
Gain on bargain purchase
Costs incurred in relation to Ulster Bank transaction
Impairment write-back arising from deleveraging of loans
Restructuring and other costs
Other non-recurring items
Impairment charge on Ulster Bank transaction*
Impairment charge on deleveraging of loans post 2021*
Other items relating to Ulster Bank transaction**
Charges in relation to legacy legal cases***
Exceptional items and other non-recurring items
* included in IFRS impairment charge
** €5m costs are included in IFRS administrative, staff and other expenses offset by €4m in net other operating income
*** Included in IFRS administrative, staff and other expenses
Exceptional and other non-recurring items as viewed by Management for the year ended 31 December 2022 of a gain of €222m
comprise:
Year ended
Year ended
31 December
2022
31 December
2021
€m
€m
(362)
92
(8)
13
30
8
1
4
(222)
-
28
(19)
14
-
-
-
15
38
51
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Financial Review
(continued)
Exceptional items
Gain on bargain purchase
A gain on bargain purchase of €362m was recognised in exceptional items in respect of the Ulster Bank transaction, for further details
please refer to note 3 of the Financial Statements.
Costs incurred in relation to Ulster Bank transaction
Exceptional costs of €92m in relation to the Ulster Bank transaction.
Impairment arising from the deleveraging of loans
€8m was released in relation to loan transactions that the Group executed in prior years primarily comprising of a release of warranty
provisions.
Restructuring and other charges
Restructuring and other costs of €13m relate to additional costs incurred as a result of the phase 2 of the Group’s Enterprise
Transformation Programme which was originally announced in 2020 and costs arising in respect of a previous disposal of a business.
Advisory costs incurred in relation to Ulster Bank transaction
Costs of €92m in relation to the Ulster Bank transaction.
Other non-recurring items
Impairment charge on Ulster Bank transaction
Day 1 impairment charge of €30m on loans acquired from Ulster Bank.
Impairment charge on deleveraging of loans post 2021
€8m charge relates to the sale of the predominately performing buy-to-let portfolio Glenbeigh IV during 2022. Loan sales since 2021
are no longer classified as exceptional.
Other items relating to Ulster Bank transaction
Additional costs of €5m are offset by other income of €4m in relation to the forward derivative on this transaction.
Underlying profit in the management income statement is stated before exceptional items and other non-recurring items whereas
operating profit in the IFRS income statement is stated after these items.
Table 8: Reconciliation of underlying profit to operating profit on an IFRS basis
Operating profit/(loss) per IFRS income statement
Exceptional items
Non-IFRS adjustments
Other non-recurring items
Underlying profit before exceptional and other non-recurring items per management income
statement
Year ended
Year ended
31 December
2022
31 December
2021
€m
267
(265)
43
45
€m
(21)
23
15
17
Management’s definition of underlying profit excludes exceptional items and other items that Management view as non-recurring. In the current
year, Non-recurring items include the Day 1 ECL booked as part of the purchase of the Ulster Bank transaction and additional impairment
charges that are a result of deleveraging.
52
Permanent TSB Group Holdings plc - Annual Report 2022
Summary consolidated statement of financial position
Assets
Home loans
Buy-to-let
Total residential mortgages
Commercial mortgages
Consumer finance
Total loans and advances to customers (net of provisions)
Debt securities
Remaining asset balances
Total assets
Liabilities and equity
Current accounts
Retail deposits
Corporate and institutional deposits
Total customer accounts
Debt securities in issue
Remaining liabilities
Total liabilities
Total equity
Total equity and liabilities
Liquidity coverage ratio (1)
Net stable funding ratio (2)
Loan to deposit ratio (3)
Return on equity (4)
Table
31 December
2022
31 December
2021
€m
€m
9
11
12
13
14
15
18,370
657
19,027
199
367
19,593
3,177
3,163
25,933
8,983
11,589
1,158
21,730
658
1,147
23,535
2,398
25,933
178%
154%
90%
0.55%
12,456
1,325
13,781
143
332
14,256
2,494
5,485
22,235
7,104
10,637
1,348
19,089
524
833
20,446
1,789
22,235
274%
170%
75%
0.97%
(1) Calculated based on the Commission Delegated Regulation (EU) 2015/61.
(2) Defined as the ratio of available stable funding to required stable funding (Article 428b)
(3) Defined as the ratio of loans and advances to customers compared to customer accounts as presented in the statement of financial position.
(4) Defined as profit/(loss) for the year after tax (before exceptional and other non-recurring items) as a percentage of total average equity.
Summary consolidated statement of financial position - key highlights
• Loans and advances to customers (net of provisions) were €19,593m as at 31 December 2022, an increase of €5,337m from
€14,256m at 31 December 2021, which is mainly due to the migration of the retail mortgage portfolio from Ulster Bank.
• Remaining asset balances were €3,163m as at 31 December 2022, a decrease of €2,322m from €5,485m at 31 December 2021. This
is primarily due to a reduction in excess liquidity held with central banks which was utilised to fund the purchase the Ulster Bank book.
• Customer accounts were €21,730m at 31 December 2022, an increase of €2,641m from 31 December 2021. This is due to an increase
in customers driving an increase in current accounts and retail deposits.
• Remaining other liabilities increased by €314m primarily due to additional repurchase agreements compared to 2021.
• Total equity increased by €609m from €1,789m to €2,398m primarily due to an additional share issuance to NatWest Group plc on
the completion of the Ulster Bank transaction of €156m, and an additional AT1 issuance of €250m.
Table 9 (a): Summary of movement in loans and advances to customers
Gross loans and advances to customers 1 January
New lending*
Loans acquired**
Redemptions and repayments of existing loans
Write-offs and restructures
Net movement from non-performing and Other
Gross loans and advances to customers 31 December
* New lending during the year is stated net of repayments during the year.
** Net of repayments
31 December
2022
31 December
2021
€m
€m
14,745
2,697
5,063
(1,879)
(43)
(779)
19,804
14,855
1,956
-
(1,607)
(65)
(394)
14,745
53
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Financial Review
(continued)
Table 9(b): Composition of loans and advances to customers
Residential mortgages:
Home loans
Buy-to-let
Total residential mortgages
Commercial
Consumer finance
Total measured at amortised cost
Of which are reported as non-performing loans
Deferred fees, discounts and fair value adjustments
Provision for impairment losses
Total loans and advances to customers
Total loans and advances to
customers (net)
€19,593m
31 December
2022
31 December
2021
€m
€m
18,340
824
19,164
239
401
19,804
650
310
(521)
19,593
12,568
1,623
14,191
196
358
14,745
817
115
(604)
14,256
Total loans and advances to customers (after provisions for impairment) of €19,593m at 31 December 2022 increased by €5,337m when
compared to the year ended 31 December 2021. This increase is due to the migration of retail mortgages from Ulster Bank offset by
deleveraging.
Net new lending has increased by €741m at 31 December 2022 from €1,956m at 31 December 2021 to €2,697m, as a result of increased
mortgage lending in 2022.
Total new lending (gross)
€2,848m
Total new lending in the financial year 2022 amounted to €2,848m, an increase of 39% from 31 December 2021. The Group’s mortgage
lending in 2022 was €2,603m, representing a 40% year on year increase from 2021. The Group’s mortgage drawdown market share
is up from 17.8% in 2021 to 18.5% in 2022, indicating that the Group’s growth (+39.9%) out-stripped broader mortgage market growth
(+34.3%).
The Irish mortgage market re-bounded in 2022 after 2021 was impacted by the COVID-19 pandemic. Increased demand saw a surge in
applications in the market in late 2021 and momentum continued into 2022. Mortgage drawdowns in the market grew by 34% in 2022,
increasing from €10.5bn in 2021 to €14.1bn in 2022. Housing supply however continued to be impacted by the restrictions imposed to
halt the spread of COVID-19, particularly in H1 2022.
SME lending in 2022 was €150m, which is a 53% increase compared with 2021. The Group has continued to grow lending through the
Strategic Banking Corporation of Ireland (SBCI) with €34m issued during the year. The Group is participating in both the Future Growth
Loan Scheme, and the SBCI Brexit Impact Loan Scheme.
The Group recorded gross new term lending of €96m in 2022. This is a 3% increase compared to 2021.
54
Permanent TSB Group Holdings plc - Annual Report 2022
NPLs as a %
of gross loans
3.3%
NPLs
€650m
Table 10: NPLs
Home loans
Buy-to-let
Commercial
Consumer finance
Non-performing loans
NPLs as % of gross loans
Foreclosed assets*
Non-performing assets (NPAs) **
NPAs as % of gross loans
31 December
2022
31 December
2021
€m
342
270
23
15
650
3.3%
18
668
3.4%
€m
420
339
44
14
817
5.5%
28
845
5.7%
* Foreclosed assets are defined as assets held on the balance sheet which are obtained by taking possession of collateral or by calling on similar credit enhancements.
** Non-performing assets are defined as NPLs plus foreclosed assets.
Gross NPL’s reduced due to cures outstripping new defaults. NPL’s as a percentage of gross loans was 3.3% at 31 December 2022,
decreasing from 5.5% at 31 December 2021. This is driven primarily by the acquisition of the performing retail mortgage business from
Ulster Bank.
Debt securities
Table 11: Debt securities
Government bonds
Corporate bonds
Total debt securities
31 December
2022
31 December
2021
€m
3,128
49
3,177
€m
2,434
60
2,494
Debt securities of €3,177m as at 31 December 2022 increased by €683m. This was due to the purchase of new Irish, French, Italian and
EU bonds offset by maturities.
Remaining asset balances
Table 12: Remaining asset balances
Loans and advances to banks
Assets classified as held for sale
Other assets
Total
31 December
2022
31 December
2021
€m
2,123
18
1,022
3,163
€m
4,174
28
1,283
5,485
Loans and advances to banks decreased by €2,051m during 2022 primarily due to decreased balances held with the CBI. These funds
were utilised in the acquisition of the Ulster Bank assets.
Other assets primarily consist of deferred tax asset, property and equipment and prepayments and accrued income. The balance
decreased from 31 December 2021 as a result of Glenbeigh III settlement received in February 2022.
55
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Financial Review
(continued)
Liabilities
The Group continues to optimise its funding profile through capitalising on cost efficient sources of funding while ensuring appropriate
diversification in its funding base. The target growth in customer accounts reflects its core focus on liquidity management.
Customer accounts
€21,730m
Table 13: Customer accounts
Current accounts
Retail deposits
Total retail deposits (including current accounts)
Corporate deposits
Total customer deposits
Loan to deposit ratio*
31 December
2022
31 December
2021
€m
€m
8,983
11,589
20,572
1,158
21,730
90%
7,104
10,637
17,741
1,348
19,089
75%
*Defined as the ratio of loans and advances to customers compared to customer accounts as presented in the SOFP.
At 31 December 2022, customer accounts increased to €21,730m from €19,089m at 31 December 2021, mainly due to an increase in
balances held in current accounts reflecting expected inflows as a result of Retail Banks exiting the Irish deposit market, partially offset
by a decrease in corporate deposits.
The LDR has increased due to the increase in lending assets acquired as part of the Ulster Bank Transaction.
Debt securities in issue
€658m
Table 14: Debt securities in issue
Bonds and medium-term notes
Non-recourse funding
Debt securities in issue
31 December
2022
31 December
2021
€m
658
-
658
€m
352
172
524
Debt securities in issued increased by €134m since 31 December 2021, as the Group issued €300m of Senior Unsecured Medium Term
Notes in June 2022. This is offset by a decrease in non-recourse funding due to the early redemption of an external securitisation during
the year.
Remaining liabilities
Table 15: Remaining liability balances
Deposits by banks
Accruals
Current tax liability
Provisions
Other liabilities
Derivative liabilities
Subordinated liabilities
Total
31 December
2022
31 December
2021
€m
614
6
1
80
181
13
252
1,147
€m
347
8
1
55
170
-
252
833
The remaining liability balances increased by €314m in the year ended 31 December 2022 primarily due to additional repurchase
agreements.
56
Permanent TSB Group Holdings plc - Annual Report 2022 Capital Management
Capital management objectives and
policies
The objective of the Group’s capital
management policy is to ensure that the
Group has sufficient capital to cover the
risks of its business, support its strategy
and at all times to comply with prevailing
regulatory capital requirements. It seeks
to minimise refinancing risk by managing
the maturity profile of non-equity capital.
The capital adequacy requirements, set
by the Regulator, are used by the Group as
the basis for its capital management. The
Group seeks to maintain sufficient capital
to ensure that all regulatory requirements
are met.
Regulatory Framework
The Group’s regulatory requirements, more
commonly known as CRD IV, are contained
within EU Regulation 575/2013 (‘the
CRR’), which is directly applicable in all EU
countries and Directive 2013/36/EU (‘CRD
IV’) transposed into Irish law through S.I.
No. 158 of 2014, as well as various technical
standards and EBA guidelines. Under these
requirements, the Group’s total capital for
Pillar 1 must be adequate to cover its credit,
market and operational risks, including
capital buffers. The Group must also hold
sufficient capital to cover the additional
risks identified under the Pillar 2 process
including any add-on imposed on the
Group as part of the supervisory SREP
assessment.
Implementation of the CRD IV legislation
commenced on a phased basis from
1st January 2014. The CRD IV transition
rules resulted in a number of deductions
from CET 1 capital being introduced on
a phased basis, all of which are now fully
implemented, with the exception of the
DTA (dependent on future profitability)
deduction which, in the case of the
Group, is phased to 2024. The ratios
outlined in this section reflect the
Group’s interpretation of the CRD IV
rules as published on 27th June 2013 and
subsequent clarifications, including ECB
regulation 2016/445 on the exercise of
options and discretions.
Regulatory capital developments
In October 2021, the European Commission
published a legislative proposal, in the
form of amendments to the CRR and CRD,
to implement the final revisions to the
Basel Framework which, amongst other
things, will see changes to the Credit Risk
and Operational Risk frameworks. The
Commission expects that the new rules
will ensure that EU banks become more
resilient to potential future economic
shocks while contributing to Europe’s
recovery from the COVID-19 pandemic
and the transition to climate neutrality. The
final legislation is expected to be agreed
in early 2023 with an expected application
date of 1st January 2025.
In November 2022, the Governing Council
of the ECB released a statement on
macroprudential policies. The statement
emphasised the importance of building
macroprudential capital buffers to help
preserve and strengthen resilience in the
banking sector in the current challenging
macro-financial environment.
The Central Bank of Ireland review the
Countercyclical Buffer (“CCyB”) on a
quarterly basis. In November 2022, the
Central Bank of Ireland announced that
the CCyB rate will be increased from 0%
to 0.50% on 15 June 2023 and to 1.00% on
24 November 2023. The gradual build-up
of the CCyB is consistent with the Central
Bank’s objective of promoting resilience
in the banking sector, proportionate to the
risk environment, with a view to facilitating
a sustainable flow of credit to the economy
through the cycle.
The Group monitors these changes and
other emerging developments as they
relate to regulatory capital to ensure
compliance with all requirements when
applicable.
Regulatory capital requirements
The Group’s 2022 capital requirements
remain unchanged to the prior year.
The Group’s Common Equity Tier 1
(CET1) minimum requirement of 8.94%
is comprised of a Pillar 1 Requirement
of 4.5%, Pillar 2 Requirement of 1.94%,
Capital Conservation Buffer (“CCB”) of
2.5%. The Group’s Total Capital minimum
requirement of 13.95% consists of a Pillar 1
CRR requirement of 8%, P2R of 3.45% and
the CCB of 2.5%.
These requirements exclude Pillar 2
Guidance (P2G) which is not publicly
disclosed.
Capital ratios at 31 December 2022
At 31 December 2022, the regulatory
transitional CET1 was 16.2% (31 December
2021: 16.9%) and Total Capital ratio 22.3%
(31 December 2021: 21.8%), exceeding the
Group’s 2022 minimum requirements of
8.94% and 13.95% respectively.
The reduction in the transitional CET1
ratio (c. -70bps) in the year is primarily
due to transitional phasing of the IFRS9
prudential filter (c. -60bps), net loan book
growth (c. -100bps) , continued investment
in software assets (c. -40bps) and other
reserves movements (incl AT1 Distributions
and Calendar Provisioning) (c. -40bps).
This was partially offset by the receipt of
outstanding proceeds relating to a 2021
NPL disposal (c. +50bps), the disposal of
a cohort of capital intensive Buy-to-Let
mortgages (c. +90bps), the execution of
the Ulster Bank transaction (c. +40bps)
which included the migration of €5.2bn of
mortgages and a 16.7% NatWest Equity
Investment.
In October 2022 the Group successfully
issued an Additional Tier 1 (AT1) note of
€250m (€245m net of transaction costs)
increasing Tier1 and Total Capital ratios by
c. +280bps.
On a fully loaded basis, at December 2022,
the CET1 ratio was 15.2% (31 December
2021: 14.7%) and the Total Capital ratio was
21.3% (31 December 2021: 19.5%).
The December 2022 leverage ratio on a
transitional basis and fully loaded basis
amounted to 8.0% and 7.7% respectively
(31 December 2021: 7.1% and 6.3%). The
increase in the leverage ratio was primarily
due to an increase in Tier 1 capital primarily
driven by AT1 issuance and Day 1 capital
benefit on Ulster Bank transaction partially
offset by the acquired mortgages.
57
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Capital Management
(continued)
The following table outlines the Group’s regulatory (transitional) and fully loaded capital positions under CRDIV/CRR2.
Table 16: Regulatory capital
Capital Resources:
Common Equity Tier 1
Additional Tier 1
Tier 1 Capital
Tier 2 Capital
Total Capital
Risk Weighted Assets
Capital Ratios:
Common Equity Tier 1 Capital
Tier 1 Capital
Total Capital
Leverage Ratio*
31 December 2022
31 December 2021
Transitional
Fully Loaded
Transitional
Fully Loaded
€m
€m
€m
€m
1,718
369
2,087
282
2,369
1,616
369
1,985
282
2,267
1,457
123
1,580
290
1,870
1,265
123
1,388
290
1,678
10,627
10,627
8,600
8,603
16.2%
19.6%
22.3%
15.2%
18.7%
21.3%
16.9%
18.4%
21.8%
14.7%
16.1%
19.5%
8.0%
7.7%
7.1%
6.3%
* The leverage ratio is calculated by dividing Tier 1 Capital by gross balance sheet exposure (total assets and off-balance sheet exposures).
The following table sets out a reconciliation from the statutory shareholders' funds to the Group's regulatory CET1 Capital.
Table 17: CET1 Capital
Total Equity
Less: AT1 Capital
Adjusted Capital
Prudential Filters:
Intangibles
Deferred Tax
IFRS 9 (Transitional adjustment)*
Calendar Provisioning
AT1 Distribution Accrual
Others
Common Equity Tier 1
31 December 2022
31 December 2021
Transitional
Fully Loaded
Transitional
Fully Loaded
€m
€m
€m
€m
2,398
(369)
2,029
(86)
(247)
41
(11)
(7)
(1)
1,718
2,398
(369)
2,029
(86)
(309)
-
(11)
(7)
-
1,616
1,788
(123)
1,665
-
(53)
(249)
94
-
-
-
1,457
1,788
(123)
1,665
-
(53)
(347)
- -
-
-
(1)
1,265
* The CET1 transitional impact to the Group as a result of EU Regulation 2017/2395 mitigating the impact of the introduction of IFRS 9 own funds.
Transitional (regulatory) capital
The December 2022 transitional CET1 capital increased by (+€261m) to €1,718m (31 December 2021: €1,457m). This increase was
primarily due to the Day 1 Capital benefit of completing the Ulster Bank transaction including the NatWest equity investment partially
offset by the transitional phasing of the prudential filters.
58
Permanent TSB Group Holdings plc - Annual Report 2022
Fully loaded capital
The December 2022 fully loaded CET1 capital increased by (+€351m) to €1,616m (31 December 2021: €1,265m). This increase was
primarily due to the Day 1 Capital benefit of completing the Ulster Bank transaction including the NatWest equity investment.
Risk weighted assets (RWAs)
The following table sets out the Group’s risk weighted assets (RWAs) at 31 December 2022 and 31 December 2021.
Table 18: RWAs
RWAs
Credit risk
Counterparty credit risk*
Securitisation Risk
Operational risk
Other**
Total RWAs
31 December 2022
31 December 2021
Transitional
Fully Loaded
Transitional
Fully Loaded
€m
€m
€m
€m
8,742
177
11
700
997
10,627
8,742
177
11
700
997
10,627
6,823
380
12
639
746
8,600
6,823
380
12
639
749
8,603
* Counterparty credit risk includes Treasury, Repo & CVA RWAs
**Other consists primarily of Property and Equipment, Deferred Acquisition Costs and Prepayments
December 2022 Risk Weighted Assets (RWA) increased by €2,027m (on a transitional basis) to €10,627m (31 December 2021: €8,600m).
The increase is primarily driven by the migration of acquired mortgages (RWAs +€1.8bn) and net loan book growth in the year (RWAs
+€0.7bn) partially offset by the execution of a BTL loan disposal (RWAs of -€0.7bn).
59
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Risk Management
The information in Section 3.1, 3.2 and 3.3
on pages 77 to 88 in Risk Management
identified as audited (with the exception of
the boxed parts of these sections clearly
identified as unaudited), forms an integral
part of the audited financial statements
as described in the basis of preparation
on page 165. All other information in Risk
Management is additional information and
does not form part of the audited financial
statements.
1. Risk Management and Governance
The nature of risk taking is fundamental
to a financial institution’s business profile.
It follows that prudent risk management
forms an integral part of the Group’s
governance structure.
Within the boundaries of the Board-
approved Risk Appetite Statement (RAS),
the Group follows an integrated approach
to Risk Management, to ensure that all
risks faced by the Group are appropriately
identified and managed. This approach
ensures that robust mechanisms are in
place to protect and direct the Group in
recognising the economic substance of its
risk exposure.
The Group implements a Risk Management
process, which consists of the following
key aspects:
• Risk Identification;
• Risk Assessment and Measurement;
• Risk Mitigation and Control;
• Risk Monitoring and Testing; and
• Risk Reporting and Escalation.
Enterprise Risk Management
Framework
Within the Internal Control Framework
(ICF), the Enterprise Risk Management
Framework (ERMF) is the Group’s
overarching Risk Management Framework
articulating the management process
governing risks within the following key
risk categories: Capital Adequacy Risk;
Liquidity and Funding Risk; Market Risk;
Credit Risk; Business Risk; Operational
Risk; Information Technology (‘IT’) Risk;
Model Risk; Compliance Risk (including
AML); Conduct & Reputational Risk and
Climate Risk.
The ERMF outlines the Group-wide
approach to the identification; assessment
and measurement; mitigation and control;
monitoring and testing; and, reporting and
escalation of breaches across the outlined
risk categories. The Group manages,
mitigates, monitors and reports its risk
exposure through a set of risk management
processes, activities and tools.
The Board Risk and Compliance
Committee (BRCC) provides oversight and
advice to the Board on risk governance
and supports the Board in carrying out its
responsibilities for ensuring that risks are
properly identified, assessed, mitigated,
monitored and reported and that the
Group’s strategy is consistent with the
Group’s Risk Appetite.
Risk Appetite and Strategy
The Group’s RAS documents are owned
by the Board, supported by the Chief Risk
Officer (CRO), and describe the Group’s risk
appetite at the enterprise level. The RAS
serves as a boundary to business, support,
and control function leaders; enables a
consistent approach to risk management;
endorses risk discipline; and, integrates
risk management into decision making
at all levels of the organisation. The RAS
further ensures the Group’s risks are
communicated clearly and well understood
by both Senior Management and Group
employees so that risk management is
continually embedded into the Group’s
culture.
The structure of the RAS enables the Group
to maintain robust discussions of risk
taking and risk management and provides
a commonly understood baseline against
which management recommendations and
decisions can be debated and effectively
and credibly challenged.
The RAS is an articulation of how the
Group’s appetite for, and tolerance of, risk
will be expressed. This comes in the form
of qualitative statements about the nature
and type of risk that the Group will take
on, and quantitative limits and thresholds
that define the range of acceptable
risk. The RAS includes component risk
appetite statements for each of the
key risk categories. The RAS includes
qualitative statements of risk appetite for
each risk category as well as quantitative
measures which translate the qualitative
statements into actionable metrics
(RAS Metrics). There are also supporting
key risk indicators (“KRIs”) that can be
monitored and reported to ensure prompt
and proactive adherence with the Board-
approved risk appetite.
The Group has a straight forward business
model, with an exclusive focus in Ireland,
delivering Retail and SME banking with a
low risk appetite. In light of this, the risk
appetite is not decomposed into individual
business unit-specific statements of risk
appetite.
Risk Governance
The Group’s risk governance structure
establishes the authority, responsibility,
and accountability for risk management
across the Group and enables effective and
efficient monitoring, escalation, decision-
making, and oversight with respect to risks
by appropriate Board and management-
level governing bodies.
The responsibilities set out below relate to
risk management activities. Further roles
and responsibilities are documented in the
ICF, the Board Manual and the committees
‘Terms of Reference’.
The design of the Group’s risk governance
structure is informed by a set of risk
governance principles which are based on
relevant regulatory guidelines.
These principles include:
• Committee Structure: The number of
committees at Board and Management
levels reflects the nature and types
of risk faced by the Group. Criteria for
establishing risk sub-committees gives
due consideration to the purpose of the
committee; duration of the committee;
proposed membership; committee
reporting line and flight path for outputs
from the committee.
• Board Committees: Made up of Non-
Executive Directors (NEDs) whose role
is to support the Board in overseeing
risk management and overseeing and
challenging Senior Management’s
decisions.
• Management Committee: Bring
together Senior Managers in the
Group who individually and collectively
possess the requisite skills, expertise,
qualifications, knowledge and experience
to exercise sound, objective judgement,
commensurate with the risk profile of
the Group.
60
Permanent TSB Group Holdings plc - Annual Report 2022 •
Independence Safeguards: The risk governance structure features safeguards to protect the independence of key relationships
between the Senior Executives and the Board. In this respect The ExCo may not override or modify decisions of the Asset and
Liabilities Committee (ALCO), Group Risk Committee (GRC) or the Group Credit Committee (GCC), but may appeal decisions to the
Board (or relevant Board committee). Additionally, the CRO is assigned the right to refer/appeal planned management action agreed
by ExCo risk sub-committees, where the CRO considers such action to be inconsistent with adherence to the Board-approved risk
appetite.
• Flow of Risk Information: The risk governance structure establishes independent reporting lines which facilitate effective risk
oversight by the Board via the BRCC.
• Communication of Risk Information: Risk information is prioritised and presented in a concise, fully contextualised manner, to enable
robust challenge and informed decision-making throughout the risk governance structure.
• Appropriateness: The number of overall governance committees/fora in the Group, the length of time per meeting, the number of
meetings per year, and the number of meetings each Director/Executive attends is appropriate to the Group’s resources and business
model. This is reviewed on a regular basis and the feedback of the committee members sought.
The diagram below depicts the Group’s risk governance structure.
Risk Governance Structure
Board of Directors
Board Nominations, Culture
and Ethics Committee
Board Risk and Compliance
Committee (“BRCC”)
Board Audit
Committee (“BAC”)
Board Remuneration
Committee
Group Executive
Committee (“ExCo”)
Assets and Liability
Committee (“ALCO”)
Group Risk
Committee (“GRC”)
Sustainability
Committee
Customer
Committee
Operational Risk Management
Committee (“ORMC”)
Group Credit
Committee (“GCC”)
Board Level Committees
Management Level Committees
Key Risk Governance Roles and Responsibilities
Committee/Role
Key Responsibilities
Board
Responsible for the Group’s business
model and strategy, financial soundness,
key personnel decisions, internal
organisation, governance structure
and practices, risk management and
compliance obligations.
A key role of the Board is to ensure that risk and compliance are properly managed in the
business. Key risk responsibilities of the Board include, but are not limited to:
• Understanding the risks to which the Group is exposed and establishing a documented
Risk Appetite for the Group;
• Defining the strategy for the ongoing management of material risks; and
• Ensuring that there is a robust and effective ICF that includes well-functioning
independent internal risk management, compliance and internal audit functions as well
as an appropriate financial reporting and accounting framework.
61
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Risk Management
(continued)
Committee/Role
Key Responsibilities
The Committee supports the Board in carrying out its responsibilities of ensuring that
risks are properly identified, assessed, mitigated, monitored and reported, and that the
Group is operating in line with its approved Risk Appetite. Key activities of the BRCC
include, but are not limited to:
• Reviewing and making recommendations to the Board on the Group’s risk profile, both
current and emerging, encompassing all relevant risks categories as described in the
Risk Management Framework (ERMF);
• Reviewing and making recommendations to the Board in relation to the Group’s ERMF,
RAS and the Group Recovery and Resolution Plan;
• Monitoring and escalating positions outside Risk Appetite to the Board, within agreed
timeframes and approving and overseeing proposed Remediation Plans aimed at
restoring the Group’s risk profile to within the approved Risk Appetite;
• Reviewing and approving the key components of the Group’s Risk Management
Architecture and relevant supporting documents;
• Communicating all issues of material Group reputational and operational risk directly
to the Board;
• Reviewing and approving Credit Policy, Credit related strategy and any material
amendments to Credit Policy;
• Reviewing and making recommendations to the Board on the adequacy of capital and
liquidity in the context of the Group’s current and planned activities (via reviewing
relevant outputs from Internal Capital Adequacy Assessment Process (ICAAP) and
Internal Liquidity Adequacy Assessment Process (ILAAP), including in relation to
proposed mergers, acquisitions or disposals;
• Assess the impact of Climate Risk on the Bank’s overall Risk Profile; and
• Promoting a sound Risk Culture across the Group.
In the context of Risk Management, ExCo is primarily responsible for:
• The oversight of strategic risk associated with the development and execution of the
Group’s Strategic Portfolio and Financial Plans. The Group Risk Committee (GRC) is
a Committee of ExCo with delegated responsibility for Group-wide risk management
issues. The ExCo is the ultimate point of escalation for Group-wide specific issues
saved for those matters reserved for the Board or its Committees; and
• Ensuring that the operations, compliance and performance (through delivery of
the Strategic Portfolio and Medium Term Plan, as well as policies, practices and
decisions of the Group) are carried out appropriately, are correctly aligned to the Bank
Purpose and Ambition and the interests of its stakeholders (customer, colleagues and
shareholders) while operating within applicable regulatory and legal requirements.
Board Risk and Compliance Committee
(BRCC)
Oversees and provides guidance to the
Board on risk governance and strategy.
This guidance includes recommendations
to the Board on current and future risk
exposure, tolerance and appetite. The
committee oversees Management’s
implementation of risk strategy including
capital and liquidity strategy, the setting
of risk and compliance policies and the
embedding and maintenance throughout
the Group of a supportive culture in
relation to the management of risk and
compliance.
Executive Committee (ExCo)
ExCo is the Senior Management
Executive Committee for the Group, and
is the custodian of the Group’s collective
Strategic Portfolio, Medium Term Plan
and Risk Management Architecture as
developed through the annual Integrated
Planning Process (IPP).
ExCo is the accountable body for the
Group’s operations, compliance and
performance; defining the Group’s
organisational structure; ensuring the
adoption, application and maintenance
of all standards set by the Board; and a
forum for Group-wide colleagues and
other functional issues and ensuring that
a robust and resilient operating framework
exists within which the Group’s activities
are undertaken.
The committee is chaired by the
Chief Executive Officer (CEO) who is
accountable to the Board.
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Permanent TSB Group Holdings plc - Annual Report 2022 Committee/Role
Key Responsibilities
Assets and Liabilities Committee (ALCo)
ALCO reviews, and is responsible for
overseeing, all activities relating to Asset
& Liability Management (ALM), Treasury
and Market Risks (including Liquidity Risk,
Interest Rate Risk, Treasury Counterparty
risk and Foreign Exchange (FX) Risk), and
Capital Management. ALCO is the body
accountable for the evaluation of other
potential drivers of earnings volatility,
including, but not limited to, competitive
and external market pressures, and for
approving optimisation and hedging
strategies against those risks. ALCO is a
sub-committee of ExCo.
Group Risk Committee (GRC)
GRC is an ExCo sub-committee chaired by
the CRO, who has unfettered access to the
BRCC. It serves as a forum for Group-wide
risk management issues and maintains
oversight across all of the Bank’s key risk
categories, excluding those which fall
under the remit of the ALCO.
Customer Committee
Customer Committee is a sub-committee
of ExCo and is chaired by the Retail
Banking Director. The purpose of the
Committee is to support commercial
growth while ensuring that fair customer
outcomes remain at the forefront of
decision making, in the context of building
customer trust and executing a purpose-
led, customer growth strategy.
Key activities of the ALCO include, but are not limited to:
• Maintaining, monitoring and enforcing adherence to the Group’s Risk Management
Frameworks and Policies for all Liquidity, Market, and Capital related risks;
• Overseeing and monitoring the ALM, Treasury and Market and Capital risks to which
the Group is exposed and to consider and approve strategies to mitigate such risks;
• Maintaining and assessing the ALM, Treasury and Market and Capital Risk profiles
against set limits and propose remediation plans to restore Risk Appetite where
required;
• Monitoring the minimum capital requirements set by the Group’s Regulators, and
the Basel III minimum Solvency rules, as implemented by the CRD IV Directive and
Regulations;
• Approve Funds Transfer Pricing (FTP) methodology, and ensuring such process is
economically fair, transparent and incentivises appropriate behaviour in accordance
with FTP Policy; and
• Responsible for overseeing Resolution Planning activity which includes delivering
prescribed templates/annual submissions.
The GRC monitors and enforces adherence to the Group’s Risk Frameworks, Risk Policies
and Risk Limits. It is the guardian of the Group’s Risk Register and Risk Appetite and is
responsible for monitoring the total risk position of the Group.
Key activities of GRC include, but are not limited to:
• Measuring and monitoring the total risk position of the Group and maintaining a Risk
Register of Top and Emerging risks facing the Group, together with an assessment of
the probability and severity of those risks;
• Monitoring and reporting on regulatory developments and upstream/horizon risk in
relation to all relevant risk categories and communicating all material issues to the
BRCC or the Board as appropriate;
• Monitoring and assessing the Group’s risk profile and action trackers against risk
appetite and recommending remediation plans to restore risk appetite where required;
• Reporting any breaches of approved thresholds in accordance with agreed protocol;
• Recommending proposed changes to the Group’s risk appetite for Board approval; and
• Maintaining, monitoring and enforcing adherence to the ERMF, for all key risk
categories excluding those which fall directly under the remit of the ALCO.
To ensure that consideration of the customer is a key part of its decision making process,
the Committee allocates sufficient time to facilitate meaningful discussions of the
customer, with the aim of improving customer experience, delivering better outcomes
and enabling relationship growth.
It has a number of key remits, namely to:
• Prioritise opportunities, resources and capabilities in order to deliver sustainable
commercial growth;
• Provide guidance to Executive Management (including ExCo and ExCo sub-
committees) on business and commercial proposals which may have a material impact
on customers and on the endorsement of such proposals;
• Review and action, where required, customer performance indicators;
• Review relevant significant customer events, issues and complaints, when escalated
by relevant sub-committees and forums, in order to provide guidance on significant
issues/events, and in order to delegate appropriate action by relevant sub-committees;
• Review and action, where required, Conduct Risk indicators that exist within the Bank
against the Board-approved Conduct Risk Appetite and Principles; and
• Serve as the central oversight body for all significant customer matters ensuring fair
treatment of customers.
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(continued)
Committee/Role
Key Responsibilities
Sustainability Committee (SusCo)
Led by the Board, and on delegated
authority from the ExCo, the Sustainability
Committee is in place to provide
oversight of all activity relating to the
Environmental, Social and Governance
(ESG) factors that are core to operating
our business in a responsible and
sustainable way. SusCo is chaired by the
Corporate Development and HR Director
and includes representation from both
ExCo members, and Senior Leaders
representing business units across the
organisation.
Group Credit Committee (GCC)
GCC oversees and is accountable
for the execution and delivery of the
Group’s system of Portfolio Credit
Risk Management, encompassing the
identification, measurement, monitoring
and reporting of Portfolio Credit Risks.
GCC ensures that the appropriate
operating frameworks governing the
portfolio credit risk management
activities of the Group are approved and
are enforced. It operates as the forum
for Group-wide Portfolio Credit Risk
Management issues across the full Credit
Risk Management Lifecycle. GCC is a sub-
committee of GRC.
The Sustainability Committee is responsible for the delivery of Permanent TSB’s
Sustainability Strategy by ensuring that there is sufficient governance, oversight,
and challenge of activity across the key area of focus of the Bank’s Sustainability
Programme.
Key activities of SusCo include, but are not limited to:
• Supporting the execution of the Bank’s Sustainability Strategy by ensuring that there
is a comprehensive plan in place to deliver on strategy, objectives and sustainability
regulatory requirements, including reporting;
• Prioritising sustainability activity and ensuring that there is a focus on the ESG
initiatives that will drive change and deliver lasting impact for our customers,
colleagues, communities and environment;
• Assigning business owners to manage and deliver sustainability programming across
the material issues set out within the Sustainability Strategy;
• Developing Sustainability KPIs and implementing processes that enable the Bank to
effectively measure, manage and report progress against Sustainability objectives;
and
• Monitoring and reporting progress to the Board and Executive Committees at regular
intervals throughout the year.
The GCC is responsible for developing and implementing portfolio credit policy within
the Group. The policy addresses all material aspects of the full credit lifecycle, including
Credit Risk assessment and mitigation, collateral requirements, collections and
forbearance and the risk grading of individual credit exposures. Key activities of the GCC
include, but are not limited to:
Recommending the relevant portfolio credit risk elements of the Group’s RAS for
approval by the Board;
• Recommending approval following challenge of the proposed impairment charge and
approach to higher authorities (BRCC/BAC) for reporting periods;
• Monitoring adherence to the Group’s Credit Policy, including discretion limits and
structure for underwriting, scoring, collections, recoveries and provisioning within the
boundaries of the Group’s RAS (as approved by the Board);
• Monitoring the portfolio credit risks to which the Group is exposed;
• Maintaining and assessing the portfolio credit risk profile against set limits and
proposing remediation plans to restore risk appetite/limits where required;
• Reporting any breaches of approved limits in accordance with agreed protocol; and
• Acting as the gateway through which decisions required from higher authorities are
reviewed prior to submission (e.g. BRCC/Board) and they are the forum review of
Group-wide credit risk management issues.
64
Permanent TSB Group Holdings plc - Annual Report 2022 Committee/Role
Key Responsibilities
Operational Risk Management
Committee (ORMC)
ORMC is the body responsible for
supporting GRC in monitoring Operational
and IT Risks and overseeing risk
mitigation performance and prioritisation
related to the management and control of
these risks. ORMC is a sub-committee of
GRC.
The ORMC reviews and discusses the outputs and results of the Risk and Control
Self-Assessment (RCSA) Process, Operational Risk Event Reporting and various other
assessment, monitoring and testing activities to create awareness of commonly
experienced Operational and IT risk matters, to share learnings and to enhance the
control environment across the Group. The key responsibilities of the ORMC include, but
are not limited to:
• Oversee the implementation of the Bank’s Operational and IT Risk Management
Frameworks, including compliance with relevant Operational and IT risk policies and
procedures;
• Monitor the implementation of policies and ensure ongoing adherence through
operational controls;
• Review and approve Operational and IT policies, as agreed with the Chair of GRC, (via
delegated authority from GRC) and recommend approval of Operational and IT Risk
Frameworks to the GRC (and subsequently BRCC);
• Review and recommend approval of qualitative and quantitative Operational and IT risk
appetite metrics and limits / thresholds to the GRC; report any breaches in accordance
with agreed protocol and recommend remediation plans to restore Risk Appetite
regarding Operational & IT risk where required;
• Oversight of new or amended Third Party/Outsourcing relationships, new products,
and/or significant changes to existing products and Strategic Change that is
implemented across the bank and highlight any risks where required.
• Review and approve the top ten Operational and IT risks;
• Appraise significant Operational and IT risk events, identify and report on the
underlying root causes of these events, share lessons learned and ensure that
measures or controls have been put in place to mitigate the occurrence and severity of
any future risk events;
• Develop, review and recommend approval of scenarios relating to potential Operational
and IT risk events in order to inform the Group’s capital assessment processes (e.g.
ICAAP and Stress Testing) and submit these to the GRC for their review and approval;
• Promote a bank-wide culture of responsibility for Operational and IT risk, and customer
focus, across every member of staff;
• Oversight and assessment of the outputs from Customer Impacting Errors (CIE) and
Customer Complaints, including identification of any required reviews or negative
trends; and
• Facilitate the business updates in particular to Information Security and Data
Management and raise any risks as required.
Role of the CRO
The CRO has overall responsibility
for overseeing the development
and implementation of the Group’s
Risk function, including overseeing
development of the risk management
framework, supporting frameworks,
policies, processes, models and reports
and ensuring they are sufficiently robust
to support delivery of the Group’s strategic
objectives and all of its risk-taking
activities.
The CRO has independent oversight of
the Group’s risk management activities
across all key risk categories. The CRO is
responsible for independently assessing,
monitoring and reporting all material risks
to which the Group is, or may become,
exposed. The CRO is a member of the ExCo
and directly manages the Group’s Risk
function.
Group’s IPP, capital and liquidity planning
and the development and approval of new
products. Specifically, the CRO is tasked
with:
The CRO is accountable for developing and
maintaining the Group’s RAS, which the
CRO submits to GRC for recommendation
to BRCC, who in turn recommend approval
to the Board. The CRO is responsible for
translating the approved risk appetite into
risk limits which cascade throughout the
business. Together with Management, the
CRO is actively engaged in monitoring the
Group’s performance relative to risk limit
adherence and reporting this to the Board.
The CRO’s responsibilities also encompass
independent review and participation in the
• Providing second line of defence
assurance to the Board across all risk
categories;
• Providing independent advice to the
Board on all risk issues, including the risk
appetite and risk profile of the Group;
• Monitoring and enforcing Group-wide
adherence to frameworks, policies, and
procedures, with the aim of ensuring that
risk-taking is in line with Board approved
risk appetite;
• Monitoring material risks to which the
Group is, or may become, exposed,
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(continued)
and overseeing development of risk
mitigating responses as appropriate;
• Developing and submitting the
ICAAP, ILAAP, Recovery Planning and
Resolution Planning for Board approval;
and
• Developing and maintaining the Group’s
risk management organisation.
In connection with these responsibilities,
the CRO is assigned the right of appeal over
planned management action agreed by
ExCo Risk Sub-Committees (such as ALCO
and the GCC) when the CRO considers such
action to be inconsistent with adherence to
the Board approved risk appetite.
Three Lines of Defence
A ‘Three Lines of Defence’ model has been adopted by the Group as defined in the ICF for the effective oversight and management of
risks across the Group.
Line Of Defence
High-Level Roles And Responsibilities
First Line of Defence
First line functions and teams incur risks
as they undertake frontline commercial
and operational activities. They are
responsible for identifying, owning,
managing, monitoring and mitigating
these risks through the effective design
and operation of mitigating controls to
ensure compliance with internal and
external requirements.
Critically, the First Line of Defence
executes its business and operational
activities in a manner consistent with the
enterprise-wide appetite and managers
take risks appropriately.
Second Line of Defence
The Group Risk Function is an
independent Risk Management function,
under the direction of the CRO, and is the
key component of the Group’s Second
Line of Defence. The Group Risk Function
is responsible for ensuring that all risks
to which the Bank is, or may become,
exposed to are identified, assessed,
measured, monitored, mitigated, and
reported on by the relevant units in the
institution.
First Line – Business Units
• Embedding the ICF and its supporting frameworks (e.g., Enterprise Risk
Management Framework) and sound risk management practices into standard
operating practices, including by creating explicit links between maintaining and
delivering robust governance and risk and control processes to performance
management;
• Establishing appropriate governance structures to support the implementation of
the ICF and achieve the Bank’s strategic, business, operational, risk, and assurance
objectives;
• Complying in full and within the spirit and letter of relevant regulations and legal
obligations applicable to business and operational activities;
•
Identifying, assessing, measuring, monitoring, mitigating, reporting and owning
all risks associated with business and operational activities across the Bank’s risk
categories in a manner consistent with the Bank’s Enterprise Risk Management
Framework;
• Cultivating a strong risk culture that encourages prompt identification and
escalation of issues and fostering an environment of continuous improvement and
open engagement;
• Providing assurance to relevant governance bodies on the management of risk in
their functions and the effective operation and reporting of relevant controls; and,
• Ensuring fair customer outcomes in all aspects of the Bank’s operation and
decision-making.
Second Line – Group Risk Function
• Developing and monitoring the implementation of Enterprise Risk Management
Framework, enterprise-wide Risk Appetite Statement and risk policies, systems,
processes and procedures;
• Assessing First Line Of Defence adherence to the enterprise risk management
framework, risk appetite, and risk limits to determine whether first line of defence
units meet the standards for their risk management roles and responsibilities;
• Reviewing, assisting, and, as appropriate, challenging the first line of defence risk
management activities, and escalating issues if risk management concerns are not
adequately addressed by first line of defence;
• Establishing, maintaining, and delivering a program of monitoring, testing, and
selected validation;
• Cultivating a strong risk culture that encourages prompt identification and
escalation of issues and fostering an environment of continuous improvement and
open engagement; and
• Providing comprehensive and understandable information, independent of the First
Line of Defence, to relevant governance bodies – through ongoing risk management
committee updates – on the state of the Bank’s overall risk and control
environment and the effectiveness of risk management, including risk issues and
risk management deficiencies, and adherence to the Bank’s risk appetite, limits,
and enterprise risk management framework.
66
Permanent TSB Group Holdings plc - Annual Report 2022 Line Of Defence
High-Level Roles And Responsibilities
Third Line of Defence
Group Internal Audit (GIA) comprises
the Third Line of Defence. It plays a
critical role by providing independent
assurance to the Board over the adequacy,
effectiveness and sustainability of the
Group’s internal control, risk management
and governance systems and processes,
thereby supporting both the Board
and Senior Management in promoting
effective and sound risk management
and governance across the Group. All
activities undertaken within, and on
behalf of, the Group are within the scope
of GIA. This includes the activities of risk
and control functions established by the
Group. The Head of GIA reports directly to
the Chair of the Board Audit committee
(BAC), thus establishing and maintaining
independence of the function.
Third Line – Group Internal Audit
• Developing a risk-based annual audit plan: developed in the final quarter of
each year, this plan sets out the program of audit reviews to be undertaken in
the following year, and is based upon a GIA’s own risk assessment. This plan is
cognisant of the bank’s strategy and the risks both to this, and within this, strategy,
and aims to provide meaningful input to assist in its controlled and well-governed
execution. Accordingly, risk- based evaluation of the bank’s risk identification,
assessment and evaluation and risk management and mitigation approaches
fall within this remit, as do assessments of adherence to policies and procedures
(including methodologies and standards), along with the controls in place to ensure
regulatory compliance;
• Reporting on identified risk management, governance and control weaknesses: GIA
reports on all identified issues to both business owners and Senior Management,
and to the Board of Directors (via the Board Audit Committee);
• Monitoring and reporting on the disposition of agreed remediating actions: As
required under professional standards, GIA also monitors the status of all issues
and actions previously raised, and reports on the progress being made by business
units in implementing agreed action plans; and,
• Providing insight into risk, governance and control measures which may strengthen
the bank’s system of internal control in a carefully structured manner such that
GIAs independence is preserved.
2. Principal Risks and Uncertainties
Risk registers, containing details of
current and emerging risks, from each of
the Group Risk functions utilise the “top
down” and “bottom up” Risk Identification
/ RCSA processes and form the basis
of the Group’s ‘Top and Emerging Risks’
report. The ‘Top and Emerging Risks’
report is presented to Board, BRCC and
GRC and is used to ensure identification,
measurement, management and
monitoring of all material risks.
In addition to the Top & Emerging Risks
update, the Risk function has also focused
on reporting on ‘Horizon’ risks. The Horizon
Risk report looks out to 25 years to try and
identify long range risks e.g. Climate Risk.
This report is included in the CRO report
which is presented to the GRC, BRCC and
Board.
The management of the risks associated
with the Ulster Bank transaction is
embedded and monitored across the suite
of existing key risk categories.
The following describes the risk factors
that could have a material adverse
effect on the Group’s business, financial
condition, results of operations and
prospects for the next 12 months and
over the medium term. The risk factors
discussed below should not be regarded as
a complete and comprehensive statement
of all potential risks and uncertainties.
There may be risks and uncertainties of
which the Group is not aware or which the
Group does not consider significant, but
which may become significant.
The challenging conditions in global
markets arise due to factors including
the Ukraine-Russian war, high interest
rate environment, inflationary pressures,
COVID-19, the growing threat from cyber-
attacks and other unknown risks. As a
result the precise nature of all risks and
uncertainties that the Group faces cannot
be predicted as many of these are outside
of the Group’s control.
As at 31st December 2022, the Bank
considers there are four emerging risks.
The first three of these were present in
2021 and outlined in the Group’s Financial
Statements. The emerging risks are:
• New Digital Based Competition/Banks -
Developments in the FinTech space and
Open Banking mean there is increased
competition for new business and
challenge our ability to retain existing
customers. Our Digital Transformation
will help ensure that we maintain
pace in offering digital services to our
customers and enable us to compete and
leverage the same/similar data of other
institutions under Open Banking.
• Energy Supply Crisis - For the Bank,
the risk is there isn’t sufficient energy to
maintain a reliable and secure platform
at peak times or during periods of
disagreeable weather (such as low wind
generation). This may impact our ability
to open branches, repayment ability of
our SMEs, maintaining technology or
impacts on staff ability to work from
home.
• Geopolitical Crisis - Following the
invasion of Ukraine from Russian
in 2022, the possibility of further
aggression between NATO and non-
NATO has increased. With some
commentators suggesting Ukraine’s
willingness to join NATO as a main
reason for Russia’s illegal invasion,
the world/EU may see retaliation from
Russia as more countries (particularly
in the EU) have applied for NATO
membership. Some countries remain
loyal, or sympathetic to Russia, there is
an increased risk of conflict (economic
or physical) in the EU/ across the globe.
A conflict within the EU/EEA or across
the global would have severe negative
consequences for the Irish economy
and it’s industry, with a corresponding
profound effect on the Bank’s prospects.
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(continued)
• Macro-Economic – An additional
emerging risk for 2022, as more and
more EU countries and other key
economic areas face into slow or
reduced growth, is that Ireland may
also be faced with a possible lengthy
recession. It will not be a question of
‘if’ Ireland’s growth slows but rather
whether the magnitude of the reduction
would be such to induce a recessionary
impact and or of a longer duration. A
recession can have severely negative
impacts on the Bank as it can lead
to drastically reduced growth, higher
delinquency rates and higher loss rates.
Business Risk
Business Risk is defined as the risk that
volumes may decline, margins may shrink
or management costs may increase,
arising from an underperforming Business
model and/or failure in the Group’s
strategic ambitions.
From the Group’s perspective, Business
Risk is further divided into two sub-risk
categories, as follows:
• Business Model Risk, which is defined
as the risk that the Group does not
generate a short-term financial return
to meet resolution tests (‘viability’)
and/or is unable to deliver minimum
acceptable returns to its shareholders
(‘sustainability’).
• Strategic Risk, which is defined as
the risk that results from a failure to
prepare for, or respond to, changes in the
external environment or market (usually
linked to factors such as the activities
of competitors, changing customer
preferences, product obsolescence,
technology developments and regulatory
changes).
Business Model risk is typically assessed
over a one-year horizon, while strategic risk
generally relates to a longer timeframe and
pertains to volatilities in earnings arising
from a failure to develop and execute
an appropriate strategy. Business Units
are responsible for the delivery of their
business plans and management of such
factors as pricing, sales/lending volumes,
68
operating expenses and other variables
that may impact earnings volatility.
Pricing decisions, and changes thereto,
are reviewed and approved by the Bank’s
Assets and Liabilities Committee. The
development of new markets, products and
services and significant changes to existing
ones is addressed under the Group’s New
Product Approval process.
Business Unit strategy is developed within
the boundaries of the Group’s Strategy
as well as the Group’s Risk Appetite. The
Group reviews Business risk as part of the
risk identification process.
Economic Outlook & Growth
Introduction
2022 was defined by the re-emergence
of inflation and central bank efforts to
tame it. While prices were already rising
rapidly by the end of 2021, it became
clear that inflation would not be transitory
once Russia invaded Ukraine in February.
Central banks across the globe increased
interest rates aggressively in an effort
to bring inflation under control. It is
still unclear if these efforts have been
successful or if they will tip the global
economy into recession in 2023. Rising
prices and interest rates are squeezing
living standards.
Inflation Rates and Interest Rates
Starting in March 2022, the Federal
Reserve raised rates by 4% over the
rest of the year. The ECB followed in
July 2022, increasing rates by 2.5% over
the rest of the year and a further 1% in
the first quarter of 2023. The Federal
Reserve’s early interest rate increases
saw the dollar strengthen to $0.95/€ in
September, a 20-year high, compounding
the inflationary effects of increasing dollar-
denominated commodity prices in the
eurozone. However, once the ECB started
to raise interest rates, the dollar weakened,
finishing the year at $1.07/€.
The CSO reported that the Consumer Price
Index (CPI) rose by 8.2% in 2022 compared
with a rate of 5.5% a year earlier. It noted
that December 2022 was “the fifteenth
straight month where the annual increase
in the CPI has been at least 5.0%.” While
the December 2022 inflation rate was
down from 8.9% the previous month, this
was due to declining energy prices; the CPI
index excluding energy rose 0.6% on the
month and 5.8% on the year, far ahead of
the ECB target of 2%.
A mild European winter, an easing of supply
chain bottlenecks and the lifting of the
zero tolerance policy towards COVID in
China all helped to ease inflation towards
the end of 2022. While the Central Bank
worried that “persistently high inflation
rates internationally increase the risk that
inflation expectations could become de-
anchored”, it noted that “consumer price
increases, while still driven by energy, have
become more broadly-based.”
Davy forecasts Irish CPI inflation of 4.7% in
2023 while the ECB expects euro “inflation
will remain high in the short run but fall
sharply to 3.6% by the end of 2023. Fading
pressures from energy prices and other
costs, together with the ECB’s monetary
policy measures, should bring inflation
back to the 2% inflation target by the
second half of 2025.” The IMF expects
global inflation “to fall to 6.6% in 2023 and
4.3% in 2024, still above pre-pandemic
levels.”
Economic Outlook / Growth
The IMF projects that “global growth
will fall to 2.9% in 2023 but rise to 3.1%
in 2024 below the historical average of
3.8%” noting that “rising interest rates
and the war in Ukraine continue to weigh
on economic activity.” The ECB expects a
“short-lived and shallow recession in the
euro area” in early 2023. It expects GDP
growth “to slow down markedly, from
3.4% in 2022 to 0.5% in 2023, and then to
rebound to 1.9% in 2024.”
Having grown by 12.2% in 2022, Davy
expects GDP to grow by 6.9% in 2023
and 5% in 2024. It also expects consumer
spending to increase by 2.2% in 2023.
While noting that Irish GDP grew by 12.2%
in 2022, it highlights “the export sector and
multinational firms remaining buoyant”
while noting that “conditions were possibly
more difficult for indigenous firms,
especially those exposed to consumer
spending.” The Central Bank emphasised
the importance of external trade to
output growth noting the outsize role of
Permanent TSB Group Holdings plc - Annual Report 2022 pharmaceutical goods and ICT services.
The Central Bank forecasts that modified
domestic demand would grow by “2.3% in
2023 and 3.3% in 2024.”
The CSO highlighted the decline in the
standard of living from its “peak in the third
quarter of 2021 which was the highest
level in the 24-year series.” While the KBC
Bank consumer sentiment index in Ireland
increased to a seven-month high of 55.2
in January 2023, far above the 14-year
low of 42.1 recorded in September 2022,
it remained “far from the 85.6 average
recorded by the survey over the past 27
years.” The Purchasing Managers Index
declined to a low of 50.8 in November 2022
but has recovered somewhat since.
The ESRI expects the “pace of growth to
slow substantially in 2023 with the growing
likelihood of an international recession”.
It forecasts modified total domestic
demand to increase by 2.2% in 2023. It
stated: “Rising costs present challenges
to households, whose incomes are not
rising at the same pace as inflation” noting
that the “pace of growth in the domestic
economy has been slowing significantly
throughout” 2022. It concluded that “an
international recession coupled with the
persistence of cost of living pressures
means that the Irish economy in 2023 is
set to grow at a significantly reduced pace.”
Government Finances
The NTMA noted the improvement in
Ireland’s financial position: “Ireland ended
2022 in a strong fiscal position. After
posting a 2021 General Government
Balance (GGB) of -€7.1bn (-3.0% of GNI),
the GGB for 2022 is now estimated to be
a surplus of €5.2bn (2.0% of GNI). This
level of fiscal surplus will likely be one of
the best in Europe.” It emphasised the role
of corporate taxes, which increased by
48% to €22.6bn, in this result: “Revenue
strength is the sole driver of the sharp
swing into surplus.”
The Central Bank commented: “Favourable
debt dynamics are expected to lead to a
significant decline in the public debt ratio,
which nevertheless is expected to remain
at an elevated level.” It also noted that
“while market interest rates are rising, they
remain lower than the rates paid on the
majority of the government bonds that will
mature in the coming years. Furthermore,
the average rate on the entire debt stock
is expected to remain considerably lower
than GNI growth.”
While the Department of Finance notes
that the “debt level amount equates to
86% of GNI, 10% lower than pre-pandemic
levels”, it cautions that “at just over
€44,000 per person, Ireland has one the
highest per capita debt burdens in the
world.” It transferred €6n to the National
Reserve Fund “to prepare the public
finances for future challenges.” Davy
expects a budget surplus of €9bn (1.7%
of GDP) in 2023 rising to €10.7bn (1.9% of
GDP) in 2024.
The NTMA announced a funding range
between €7bn and €11bn for 2023
compared to an average of €19bn for
the period 2017-21. It stated: “Ireland’s
refinancing risk is low” as only a third of its
debt is set to mature in the next five years.
Ireland’s debt has an average maturity
of 10.9 years and the NTMA has a cash
balance of €23bn at the end of 2022. Fitch
and DBRS upgraded their rating for Ireland
to AA space and Moody’s upgraded its
rating to A1.
Employment
The CSO reported that average weekly
earnings rose 3.2% to €864.32 in the year
to Q3 2022. The Central Bank forecast that
inflation-adjusted household income would
rise by 1.1% in 2023 having fallen by 1.5%
in 2022.
The CSO also reported a vacancy rate of
1.5%, prompting Davy to note that “labour
shortages are now becoming apparent and
will constrain jobs growth.” The Central
Bank noted that “employment levels grew
by 8.8% annually in Q2 2022 to reach a
new peak of 2.55 million persons” and
forecasted employment would grow by
1.1% in 2023, down from 6.2% in 2022.
The ESRI suggested “the unemployment
rate is still set to continue to fall to a near
historical low of 4.3%.” It warned that
“downside risks to this outlook include
a slowdown in certain domestic sectors
as global activity slows.” Davy noted
that employment “is now 9% above
pre-pandemic levels (an extraordinary
performance)” but that “jobs growth now
looks to be slowing.” It noted, however,
that “accommodation and food service
employment is still 36,000 or 10% below
pre-pandemic levels.”
The CSO’s Population and Migration
Estimates data for the year to April 2022
“show that the overall population increased
by 88,800 persons to over 5.1 million.”
Davy commented: “Ireland’s labour market
performance has been helped by the 1.8%
growth in the population to 5.1m in 2022,
of which one-third (or 28,000) came from
the natural increase and two-thirds (or
61,000) from net migration. In addition, the
participation rate is now 65%, its highest
level in 15 years – with limited scope to rise
further.”
Banking
The Central Bank reported: “Over the
course of 2022, household deposit inflows
amounted €7.7bn, down from €11.5bn in
2021 and €13.9bn in 2020, leading to an
outstanding balance of €148.6 billion at
end-December.” It commented that “the
annual growth rate moderated to 5.4% in
December, and has now declined to Q2
2019 levels.” It noted that “interest rates
on household overnight deposits stood at
0.03% in December 2022” while rates on
term deposits rose to 0.63%. It highlighted
that the “weighted average interest rate
on new Irish mortgage agreements at end
December 2022 was 2.69%”, the third-
lowest in the euro area.
The Central Bank commented: “The share
of total assets accounted for by lower-
yielding securities such as government
bonds and central banks reserves has
increased, at the expense of lending to
households and businesses, with the
lending share in total assets declining from
73.4% to 44.3% between June 2019 and
June 2022. The smaller share of lending
to households and businesses has, in
conjunction with the expansion of retail
deposits, resulted in a sharp decline in the
loan-to-deposit ratio, which is now within
the bottom quartile among a sample of
European banks as at June 2022.”
It further noted: “As of 2022 H1, 49% of
outstanding mortgage lending at the main
retail banks had been issued since the
introduction of the mortgage measures.”
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It concluded: “Households’ resilience
to shocks has been bolstered by many
forces in the last decade: nominal income
growth, rapid growth in house prices
and housing equity, increases in savings
during the pandemic, falling aggregate
indebtedness, and prudent new lending
under the mortgage measures. These
factors suggest that broad-based financial
stability risks are contained for now, even
under further increases in interest rates
and weakness in the labour market.” It
cautioned that “banks’ own risk modelling
may struggle to measure forward-looking
credit risks that are specific to the nature
of the current high-inflation, high-rate
shock, which has not been experienced
by lenders for four decades,” noting
that the median mortgage borrower
would experience an increase of 12% in
their mortgage repayment as a result
of a 4% ECB rate increase. It noted that
“mortgage rate fixation in recent years
will insulate just over half of mortgagors
from the immediate effects of interest rate
increases, but many are exposed over the
medium-term.” Davy analysis concludes
that “debt service ratios on new mortgage
lending are unlikely to be stretched by ECB
rate hikes.”
BPFI reported “year-on-year drawdown
volumes rose by 21% to 52,634 while
values rose by 34.3% to almost €14.1
billion”, noting “these were the highest
levels since 2008.” However, €3.8bn of
this was re-mortgaging, up 135% (€2.2bn)
on the previous year. As Davy noted: “This
growth was comprised of a 10% growth in
the average mortgage loan to €283,000,
but only a 0.6% rise in lending volumes.”
Davy forecast that while “mortgage
lending will grow to €14.5bn in 2023”,
house purchase lending would “grow
from €10.2bn in 2022 to €11.5bn” as re-
mortgaging activity declined. “This implies
the stock of lending will grow by 1.6% to
€85bn.”
The Central Bank commented that “higher
interest rates are expected to be positive
for banks’ profitability.” It noted that non-
bank lenders had a 19.7% share of new
mortgage lending in 2022 H1, but cautioned
that such lending “poses risks of being
pro-cyclical as interest rates rise.” The
non-bank share of the mortgage market
has declined substantially since because of
the “more direct reliance of these entities
on non-deposit sources of funding.”
The Central Bank is continuing “the gradual
rebuilding of the Countercyclical Capital
Buffer (CCyB).” This will see the CCyB
rise from 0% at end-December 2022 to
0.5% on 15 June 2023 and to 1.0% on 24
November 2023. It commented: “This
marks a further step towards the 1.5%
target rate for the CCyB in periods when
cyclical risks are neither elevated nor
subdued.”
Housing
The supply challenge continued to
dominate the housing landscape in 2022.
“It will be difficult to achieve all the targets
regarding new housing output, residential
retrofitting, national infrastructure,
commercial real estate and other projects
(e.g. Mica redress) without scaling up
the level of persons employed in the
sector significantly”, the Central Bank
commented.
The Government progressed with demand-
side initiatives such as the Help-to-Buy
and First Home shared equity scheme.
The Central Bank revised its Mortgage
Measures Framework; effective 1 January
2023, the maximum loan-to-income
ratio for a first-time buyer increased to 4
times and the maximum loan-to-value for
second and subsequent buyers increased
to 90%. All these initiatives will increase
the amount mortgagors can borrow and
will thus contribute to hose price inflation.
“This may assist in increasing the output
from marginal sites but, ultimately,” Davy
notes, “the main logjams on increasing
output relate to supply-side issues.” It cites
the “planning system as an overwhelming
barrier to higher volume from homebuilders
and something that needs urgent action
from policymakers. Infrastructure and
service provision is also an area that
potentially requires action.”
The CSO reported that 30,000 new
dwellings were completed in 2022.
The NTMA notes that at over 70,000,
transactions are “now above pre-pandemic
levels” but that “housing starts show
supply chain issues and inflation has
started to weigh on development” citing
“increased material costs along with large
increases in labour costs.” Davy expects
27,500 housing completions in 2023 and
30,000 in 2024. It cautions that “the
pick-up in funding costs could well impede
apartment development, which has so far
been reliant on institutional investment
into the private rented sector. A process of
price discovery is now at play, with capital
values under pressure as residential yields
must adjust to the ECB’s tighter monetary
policy.” It noted the “more pernicious
viability challenge in the Build to Rent
sector, reliant on institutional investment.”
Apartments accounted for 31% of
completions in 2022.
BNP Paribas noted that the headline
seasonally adjusted Real Estate Ireland
Construction Index “dropped to 43.2 in
December, down from 46.8 in November
and below the 50.0 no-change mark for the
third month running. Panellists reported a
general market slowdown amid challenging
economic conditions.”
The CSO reported private rents increased
by 10.6% in 2022. At year-end 2022,
Daft noted that “each of the previous
ten quarters had brought a new all-time
high for the average market rent” but
commented that the 4.3% increase in Q3
2022 was “by some distance, the single
largest quarterly increase ever recorded in
the rental report in a series that goes back
to the start of 2006.” It explained: “What
has happened over the last 18 months
has been an extraordinary collapse in the
stock available to rent. In 2016, there were
about 75,000 homes put up for rent over
the course of the year. By early 2022, that
had fallen to less than 50,000 – and in the
last six months, it has fallen again to about
35,000.” The Central Bank commented:
“Private residential rents are approaching
a point of being 50% above their previous
peak (2008) level as the availability of
rental properties remains at historical
lows, due to the exit of many small-scale
landlords from the market and efforts to
house refugees fleeing the war in Ukraine.”
House Prices
The CSO reported that “the national
Residential Property Price Index (RPPI)
increased by 8.6% in the 12 months to
November 2022.” It noted that the national
index has now reached a value “which
is 3% above its highest level at the peak
of the property boom in April 2007” and
130% higher than its March 2013 trough.
However Daft noted that “average list
prices nationally fell by 0.4% in the final
quarter of 2022, the first time prices have
fallen since the onset of the COVID 19
pandemic.”
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Permanent TSB Group Holdings plc - Annual Report 2022 The Central Bank commented that “the
pace of growth in household incomes has
been considerably slower than that of both
house prices and rents since the financial
crisis, adding to housing affordability
pressures.” It continued: “Near-term
house price developments are subject
to heightened uncertainty and will be
determined by a range of factors. Rising
construction costs, population growth and
demographic changes, monetary policy
normalisation, declining real disposable
incomes, and recent changes to the
Central Bank’s mortgage measures are
some of the factors likely to have most
impact on the supply and demand of
housing and ultimately residential property
prices. There are signs, however, that the
pace of house price growth is starting to
moderate.” But it warns: “Supply shortages
remain in the residential real estate market
in Ireland, which could potentially be
exacerbated by a slowdown in construction
activity.”
Davy expects 4% house price inflation in
2023 and 5% in 2024. It notes: “The key
point is that because employment has
remained robust, there has not been any hit
to housing demand despite the uncertain
economic environment posed by events
in Ukraine, higher energy prices and CPI
inflation and European Central Bank (ECB)
rate hikes. However, even if mortgage
interest rates rise to 4%, debt service
ratios are unlikely to become stretched
and there will be only a limited headwind
to house prices. That said, the average
residential transaction in Q3 2022 was
€370,000, now 7.7x the average income of
€48,000. It is quite possible that a degree
of froth exists in the Irish housing market
that could continue to unwind in early 2023.
This is the highest house price-to-income
multiple since the 8.1x recorded in 2009,
albeit remaining well below Celtic Tiger era
peaks, and is now close to the UK multiple.”
Overall Position
The Central Bank comments: “Households
are facing a combined inflation and interest
rate shock, but enter it with strong balance
sheet resilience. Domestic retail banks
will be exposed to risks from distressed
borrowers, but have capital headroom
currently, and profitability prospects are
strong due to higher interest rates. Recent
strong fiscal returns are facilitating the
provision of support to households and
businesses affected by the energy shock.”
Davy notes the improving economic
backdrop: “Signs that CPI inflation has
peaked, falling energy prices, hopes that
the euro area may avoid recession and the
re-opening of the Chinese economy have
helped sentiment more broadly across
Europe. The improvement in Ireland is in
sync with the European Commission’s
measure of consumer confidence.” While
noting “a sustained contraction in activity”
early this year, BNP Paribas too strikes
a note of optimism: “Rates of reduction
for both output and new orders softened
notably and there was a fresh increase
in staffing numbers. Cost and supply
pressures displayed signs of easing.” But
he ESRI notes: “The impact of any global
downturn on the domestic economy will
crucially depend on how it impacts the ICT
and pharma sectors which have been the
main engine of growth for the traded sector
of the Irish economy.”
Climate Risk
PTSB is committed to the management of
Climate Risk, aided by regulatory guidance,
to play our part as corporate citizens.
Understanding of how best to respond to
climate change is continually evolving and
with this our knowledge of associated risks
continues to develop.
• The identification of climate risk factors
relevant to the Bank and their high-level
potential impacts
• The introduction of a suite of Climate
Risk metrics
• Development of an approach to measure
the impact Assessment of climate
risk (including data requirements and
identification of data proxies from
external sources) on the business model.
• Consideration of a Sustainability
exclusion category for our Credit Policy,
which will limit exposures to entities
which we believe cause irreversible
environmental and/or social harm to our
local communities and wider society;
and,
• Monitoring the regulatory landscape and
ensuring full alignment with it.
We are conscious of the effect that climate
change has on the Bank and view it as
manifesting itself in two ways, firstly,
through the operations of our business
and secondly the financial risk it brings
to the economy in the longer term.
Climate Change presents both risks and
opportunities to meet new customer needs
for Permanent TSB and we are preparing
for both.
Managing Climate Risk is a key area of
focus under the ‘Addressing Climate
Change and Supporting the Transition to a
Low Carbon Economy’ Pillar of the Bank’s
Sustainability Strategy.
Climate Risk is defined as the risk of
financial loss or an adverse outcome
arising from the consequences, likelihoods
and a lack of or inadequate responses to
the impacts of climate change.
To date further progress has been made in
the development of a definition of Climate
Risk for the Bank and added Climate Risk
as its own Risk Category within the Bank’s
Enterprise Risk Management Framework
in early 2022. The impact of Climate Risk
within each of the remaining Bank’s Risk
Categories is being considered as the
management of Climate Risk is further
embedded.
To support the measurement, management
and monitoring of Climate Risk in addition
to ensuring adherence to Regulations,
the Bank have developed a Sustainability
Implementation Plan which will introduce
more changes through the Bank as actions
are delivered. Some additional actions that
will be implemented as part of this plan
include:
There are two climate-related risks,
these are physical risk and transition risk.
Both risk types may impact the financial
services sector to varying degrees over the
short, medium and long term. The extent to
which the impact of physical and transition
risk might impact a financial services firm
will vary depending on the firm’s business
model, customer base, location as well
as the transition process to a low-carbon
economy.
Physical risk is the risk of economic
costs and financial losses resulting from
more extreme weather events brought
about by climate change. For a financial
institution, property values might be
impacted depending on property location,
for example, located in a low-lying coastal
areas.
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Transition risk is the risk of economic or
policy changes resulting from the transition
to a low-carbon economy. For example,
certain sectors might be more vulnerable
to transition risk as the economy and
customer demand alters during the
transition.
As climate risk continues to evolve the
effect of Physical and Transition risk on
the Bank will be considered against our
business model as part of the work to be
completed.
You can read more about our commitment
to Climate Risk on page 21.
Credit Risk
Credit Risk is defined as the risk of financial
loss due to the failure of a customer,
guarantor or counterparty, to meet their
financial obligations to the Bank as they
fall due.
The Group’s customer exposures are
originated and managed in Ireland. The
Group’s principal exposure is to residential
mortgages secured firstly by a first
legal charge on the property. Economic
uncertainty, as well as the socio-political
environment and inflation adversely impact
or cause further deterioration in the credit
quality of the Group’s loan portfolios. This
may give rise to increased difficulties
in relation to the recoverability of loans
or other amounts due from borrowers,
resulting in further increases in the Group’s
impaired loans and impairment provisions.
As losses from customer credit risk are the
principal financial risk to which the Group is
exposed more detailed analysis of the risks,
risk management policies and current
portfolio segmentation is provided in
section 3.1 of the Risk Management Report.
Capital Adequacy Risk
Capital Adequacy Risk is the risk that the
Group does not have sufficient capital to
cover the risks of its business, support
its strategy, and comply with regulatory
capital requirements at all times.
The Group’s business and financial
condition could be negatively affected if
the amount of its capital is insufficient due
to:
• Materially worse than expected financial
performance;
•
Increases in Risk Weighted Assets;
• Excessive growth in asset volumes;
• Changes in the prescribed regulatory
framework; or
• Sale of assets.
The core objective of the Group’s capital
management framework is to ensure
it complies with regulatory capital
requirements (Capital Requirements
Regulation (CRR and CRR2), Capital
Requirements Directive IV (CRD IV) and the
Banking Recovery and Resolution Directive
(BRRD)) and that it maintains sufficient
capital to cover its business risks and
strategy.
As outlined in the Group’s RAS, the
Group undertakes an ICAAP to ensure
that it is adequately capitalised against
the inherent risks to which its business
operations are exposed and to maintain
an appropriate level of capital to meet
the minimum regulatory and Supervisory
Review and Evaluation Process (SREP)
capital requirements. The ICAAP is subject
to review and evaluation by the CBI as part
of its Supervisory Review and Evaluation
Process (SREP).
The management of capital within the
Group is monitored by the BRCC, ExCo
and ALCO in accordance with the Board
approved framework.
While the key elements of the Basel III
requirements commenced in January
2014 and further rollout is expected to
continue on a phased basis until 2023, the
Group closely monitors other potentially
significant changes to the requirements
including measures which may result
in Basel IV regulations replacing or
supplementing Basel III.
Government Control and Intervention
In 2011, the Minister for Finance of
Ireland became the owner of 99% of
the issued ordinary shares of the Group
which reduced to c.75% following the
successful capital raise in 2015. The recent
completion of the first phase the Ulster
Bank transaction has further reduced the
Minister for Finance’s stake to c.62%.
The risk is that the Irish Government
through its direct shareholding of the
Group, uses its voting rights or intervenes
in the conduct and management of the
business in a way that may not be in
the best interests of the Group’s other
stakeholders.
The Minister for Finance and the Group
entered into a Relationship Framework
Agreement dated 23 April 2015. The
Framework Agreement provides that the
Minister will ensure that the investment
in the Group is managed on a commercial
basis and will engage with the Group,
including in respect of the manner in
which he exercises his voting rights,
in accordance with best institutional
shareholder practice in a manner
proportionate to the shareholding interest
of the State in the Group.
Current and future budgetary policy,
taxation, the insolvency regime and other
measures adopted by the State to deal
with the economic situation in Ireland may
have an adverse impact on the Group’s
customers’ ability to repay their loans, the
Group’s ability to repossess collateral and
its overall pricing policy.
Liquidity and Funding Risks
Liquidity Risk is the risk that the Group
has insufficient funds to meet its financial
obligations and regulatory requirements as
and when they arise either through inability
to access funding sources or monetise
liquid assets.
Funding Risk is the risk that the Group is
not able to achieve its target funding mix,
is too dependent on particular funding
instruments, funding sources (retail/
wholesale) or funding tenors, fails to meet
regulatory requirements and, in extremis,
is not able to access funding markets or
can only do so at excessive cost and/or
Liquidity Risk.
These risks are inherent in banking
operations and can be heightened by
other factors including changes in credit
ratings or market dislocation. The level of
Liquidity Risk further depends on the size
and quality of the Bank’s liquidity buffer,
the maturity profile of funding, as well as
broader market factors such as depositor
and investor sentiment/behaviour.
72
Permanent TSB Group Holdings plc - Annual Report 2022 It is likely that risks would be further
exacerbated in times of stress. Given the
nature of the Group’s retail focus which
stems from its business model, liquidity
and funding risk will arise naturally
due to the maturity transformation of
primarily short term contractual deposits,
albeit recognising their behavioural
stickiness, into longer term loans through
predominantly mortgage lending.
Market Risk
Market risk can be defined as the risk
of losses in on and off-balance sheet
positions arising from adverse movements
in market prices. Often market risk cannot
be fully eliminated through diversification,
though it can be hedged against.
From the Group’s perspective, Market
Risk consists of three components being
Interest Rate Risk, Credit Spread Risk and
FX Risk.
The Group’s RAS and the associated
Market Risk Framework set out the
Group’s approach to the management
of market risk, including the Group’s
approach to market risk identification,
assessment, measurement, monitoring,
mitigation and reporting. The Market Risk
Framework is approved by the BRCC on the
recommendation of the ALCO.
All market risks arising within the Group
are subject to strict internal controls and
reporting procedures and are monitored
by the ALCO, ExCo and BRCC on a regular
basis. Group Treasury is responsible for
the management of market risk exposures
on the balance sheet. Group Risk and GIA
provide further oversight and challenge
within the Market Risk Framework.
Model Risk
Model risk is defined by the Group as an
adverse outcome (incorrect or unintended
decision) that occurs as a direct result
of weaknesses or failures in the design,
implementation or use of a model. The
adverse consequences include financial
loss, poor business or strategic decision-
making, or damage to the Group’s
reputation.
In terms of risk appetite, the Group expects
that all material models function as
intended. The key factors which influence
model risk within PTSB include:
• Macroeconomic risk – the Group’s
suite of models is built on data that
spans the period immediately prior to
the Global Financial crisis through the
recent recovery. The degree to which the
impacts of a new economic downturn
will mirror the last is uncertain. The
degree of risk increases with the speed
and volatility of economic change;
• Regulatory change – the pace of
evolution of regulation and guidance
increases the burden of maintaining the
Group’s regulatory models;
• Competition for skills – significant
competition exists within the Irish
market for those with the experience
and expertise to build, implement and
interpret models; and
• Data – encouraging customers to share
their data, particularly in the area of
environment and sustainability is a
strategic area of focus for the Group in
enhancing model risk management.
Model risk is managed in accordance with
the Group’s Model Risk Framework. This
framework provides the foundation for
managing and mitigating model risk within
the Group. Accountability is cascaded from
the Board and senior management via the
Group RMF. This provides the basis for the
Group Model Governance Policy, which
defines the mandatory requirements for
models across the Group, including:
• the scope of models covered by the
policy, including model materiality;
• roles and responsibilities, including
ownership, independent oversight and
approval;
• key principles and controls regarding
data integrity, development, validation,
implementation, ongoing maintenance
and revalidation, monitoring, and the
process for non-compliance; and
• The model owner taking responsibility
for ensuring the fitness for purpose
of the models and rating systems,
supported and challenged by an
independent specialist function within
Risk that reports directly to the CRO.
The above ensures all models in scope
of policy, including those involved
in IFRS 9 and regulatory capital
calculation, are developed consistently
and are of sufficient quality to support
business decisions and meet regulatory
requirements.
The Group Model Governance Committee
(MGC), a sub-committee of the GRC is
the primary body for overseeing model
risk. The Group RAS requires that key
performance indicators are monitored
for every model to ensure they remain fit
for purpose or appropriate mitigation is in
place. Material model issues are reported
to Group and Board Risk Committees
monthly with more detailed papers as
necessary to focus on key issues.
Operational Risk and IT Risk
Operational Risk is defined as the risk of
loss or unplanned gains resulting from
inadequate or failed processes, people,
and systems or from external events. This
includes business continuity; outsourcing
and third party; business process; fraud;
legal; people; property; change and data
management risk.
IT Risk is defined as the risk of loss due to a
breach of confidentiality, failure of integrity
of systems and data, inappropriateness
or unavailability of systems and data or
inability to change information technology
(IT) within a reasonable time and with
reasonable costs when the environment or
business requirements change (i.e. agility).
Risks from both these risk categories are
inherently present in the Group’s business.
Any significant disruption to the Group’s
IT systems, including breaches of data
security or cyber security could harm the
Group’s reputation and adversely affect the
Group’s operations or financial condition
materially.
The Group has a low appetite for
Operational Risk and IT Risk and aims to
minimise the level of serious disruption
or loss caused by Operational or IT issues
to its customers, employees, brand and
reputation. The Group has no tolerance
for data or cyber security breaches
which may result in significant damage
to customer confidence and financial
stability. The Group has no appetite for
non-conformance with laws.
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The ORMC monitors the Operational and
IT Risks to which the Group is exposed
to and oversees risk mitigation including
performance and prioritisation related to
the management and control of these risks.
In fulfilling this role, The ORMC reviews
and discusses the outputs and results of
the Risk and Control Self-Assessment
(RCSA) Process, control testing and
Operational Risk Event Reporting and
various other assessment, monitoring and
testing activities to create awareness of
commonly experienced Operational and
IT risk matters, to share learnings and to
enhance the control environment across
the Group. Furthermore, the ORMC reviews
and monitors Operational and IT risk RAS,
the Operational and IT KRIs, emerging risks
and other relevant Operational and IT risk
metrics on an ongoing basis.
ORMC also monitors the oversight of new
or amended Third Party/Outsourcing
relationships, new products, and/or
significant changes to existing products
and Strategic Change that is implemented
across the bank and highlight any risks
where required.
The Second Line (2LOD) attend the
Governance forums of material change
projects, providing oversight and guidance
from a Change Risk perspective. 2LOD
oversee the appropriate management and
completion of key project components
such as Risk, Assumption, Issue and
Dependency Log (RAID Log), Project
Closure reports and monitor the progress
and completion of Business Readiness
procedures until project implementation.
Monthly reporting of the four Change
KRIs and formal quarterly review and
challenge of the monthly Change Updates
to the Executive Committee. Opine on the
content of key change artefacts in line with
the ECE project, including the enhanced
RAID Log, Project Closure Document,
Business Readiness Checklist and Project
Stage Gates. Rollout of the Change Risk
Oversight Policy and Material Change Risk
Assessment will further embed appropriate
change risk management practices across
the bank.
External Fraud is elevated with customers
of Financial Institutions being targeted
through fraudulent SMS messages,
phone calls and accessing fake websites.
Since 2020, there has been significant
increase in fake Permanent TSB websites
shut down. Also, PTSB along with other
74
Irish Issuers and as part of a Banking
& Payments Federation Ireland (BPFI)
initiative continue to contribute to the
Mobile Ecosystem Forum designed
to reduce the impact of Smishing on
customers.
While the PTSB cyber defences have
proven robust to-date, the external threat
environment is challenging and for this
reason cyber risk is considered to be
elevated. Continuous improvement in our
cyber defences is a strategic priority with
investment accordingly to enhance the
control environment.
In response to external events we are
focussed on;
• Enhancements to Vulnerability
Management and Penetration Testing;
•
Information Security Awareness
communications, including increased
Board and ExCo-level communications
and awareness;
• Enhanced monitoring for threats; and
•
Increased Information Security
Governance and associated reporting.
A new 2022-2024 Information and Cyber
Security Strategy was approved at
Board Risk and Compliance Committee
in February 2022. This is to drive further
improvements in the Bank’s cyber defence
and preparedness, along with associated
governance.
Operational & IT Risk continuously review
Group Technology IT incidents, including
cyber, and there were no breaches of
data security or cyber security that could
significantly harm the Group’s reputation
and adversely affect the Group’s operations
or financial condition materially.
Scenario testing is performed on an
annual basis, as outlined in the ERMF,
for critical processes including but not
limited to: Payments Systems Failure,
Information Security, Cyber Security,
Internal Fraud, Business Disruption and
IT Resilience to ensure existing processes
support timely recovery. Monitoring and
incident management processes are in
place to detect and recover from both
cyber-attacks and IT issues which may
affect the availability of critical IT systems.
Regular disaster recovery testing of
critical systems is conducted in order to
test IT resilience. Any changes made to
the Group’s IT systems or applications
are governed by a change management
process.
From a people perspective, Enterprise
Level programmes such as Hybrid
Workplace, Individual Accountability
Framework (IAF)/ Senior Executive
Accountability Regime (SEAR), Service
a Need (SAN), Sun etc. are designed
to ensure People Risk is an integral
consideration. The Change Risk Second
Line Oversight is being developed in line
with the formal Strategic Portfolio project
“Enterprise Change Enhancements” (ECE)
which has been established following a
Change Maturity Assessment undertaken
in 2021. This project will focus on change
governance enhancements, e.g. build-
out of Project Stage Gates with required
change artefacts, Change MI on supply,
demand and utilisation. The project has
already began to deliver and has mobilised
the following as examples;
• Prioritisation & Intervention (P&I) Forum,
• Management Deign Authority, (MDA
meeting)
The Group’s Operational Risk and IT Risk
Management Frameworks outline the
Group’s approach to managing Operational
and IT risks and are applicable Group
wide. The framework defines the roles
and responsibilities for the oversight of
Operational and IT risks, along with the
ownership and processes in place for the
identification, assessment, mitigation,
monitoring, testing and reporting of
Operational and IT risks in the Group.
An RCSA methodology is used to identify,
measure and control Operational Risk,
IT Risk, Compliance Risk, Conduct and
Reputational Risks across the Group
which aids the consistent approach to
risk management and aids the business
in their decision making process. It also
supports tracking of deficiencies related
to control design and control effectiveness
and any associated remediation plans. The
RCSA methodology outlines the actions,
procedures, roles and responsibilities
relating to the Group’s RCSA process.
We have enhanced our processes in
this area as we progress plans and
have implemented a new Governance
Permanent TSB Group Holdings plc - Annual Report 2022 Risk & Compliance (GRC) system for
the management of Operational and IT
risk. The RCSA methodology outlines
the actions, procedures, roles and
responsibilities relating to the Group’s
RCSA process.
The Group acts to mitigate potential risk
found in existing procedures through the
use of controls. A control is any process,
policy, device, practice or other action that
mitigate potential risks found in existing
procedures.
Internal controls are tested on a continual
basis to provide assurance on the design
effectiveness and operating effectiveness
of controls captured in the RCSA process.
This system of internal control is designed
to provide reasonable, but not absolute,
assurance against the risk of material
errors, fraud or losses occurring. Effective
controls will work to reduce the likelihood of
a risk occurring and/or the impact should
the risk materialise.
Independent risk based control assurance
reviews are also undertaken mainly in
relation to key processes to provide an
assessment of how effective associated
risks are controlled and managed.
Weakness in the Group’s internal control
system or breaches/alleged breaches
of laws or regulations could result
in increased regulatory supervision,
enforcement actions and other disciplinary
action, and could have a material adverse
impact on the Group’s results, financial
condition and prospects. To quantify the
potential impact of weaknesses in this
regard, and to strengthen the Group’s
system of internal controls through the
consideration of unexpected events,
scenario analysis and stress testing are
conducted on a regular basis.
A key objective of the Group’s Risk
Management approach is to create a
culture of risk awareness where all staff
have an understanding of Operational
and IT risk and the role they each play
in ensuring that any impacts/losses are
minimised.
Third Party Service Providers
The Group may engage the services of
third parties to support delivery of its
objectives or to complement its existing
processes. The risk associated with these
activities is categorised as ‘Outsourcing
and Third Party’ risk and is defined as
the current or prospective risk of loss
or reputational damage connected with
the engagement and management of
Third Parties contracted internally or
externally (for example, for the purposes of
customer engagement, data processing,
systems development, Cloud services or
Information & Communication Technology
(ICT) systems), including lack of third
party diversification, inadequate third
party business continuity plans or
insufficient monitoring and oversight of the
engagement.
The Group’s Third Party Risk Management
Policy sets out the minimum requirements
and roles and responsibilities necessary
to ensure consistent and continuous
management of Third Party and
Outsourcing risks across the Group,
as defined in the Group’s ERMF, and
Operational and IT Risk Management
Frameworks. The policy outlines the
processes and controls required for
identifying, assessing, mitigating and
managing third party risks.
Conduct and Reputational Risk
Conduct Risk is the risk that the conduct
of the Group towards customers or the
market leads to poor customer outcomes,
a failure to meet customers’ or regulators’
expectations, or breaches of regulatory
rules or laws.
Conduct Risk can occur in every aspect of
the Group’s activities, including through:
• The strategy of the Group and how it is
executed;
• The way the Group is run and managed;
• The existence of group think or localised
cultures;
• The lack of psychological safety for
staff in facilitating a robust speak freely
process;
• The design type and pricing of products/
services offered, the customers to whom
they are offered and the distribution
channels used;
• The way sales are made or transactions
are executed;
• The post-sales fulfilment process
throughout the life of the product;
• The management of different customer
cohorts recognising that some
customers may require additional
assistance at a point in time or on a
permanent basis; and
•
Interactions with customers throughout
the lifetime of the relationship, including
when customers make complaints
either directly or through the Financial
Services and Pensions Ombudsman or
where customer-impacting errors occur.
See note 32 and note 43 to the financial
statements for further information on
legacy legal cases.
The Group recognises that the
management and mitigation of Conduct
Risk is fundamental and intrinsically linked
to the achievement of our purpose ‘To
work hard every day to build trust with
our customers - we are a community
serving the community’. It recognises that
Conduct Risk can occur in every aspect of
the Group’s activities and is committed to
continuing to achieve best practice in this
area.
The Group’s Senior Management are
responsible for the identification and
management of Conduct Risk in their
business areas and for ensuring fair
customer outcomes, and the Regulatory
Compliance and Conduct Risk function
is responsible for second line Conduct
Risk oversight. The Group is guided by a
Conduct Risk Management Framework,
including a Board-approved Risk Appetite
and Conduct Risk Principles. Its purpose
is to help ensure that the Group achieves
its strategic objectives by acting honestly,
fairly and professionally in the best
interests of its customers and the integrity
of the market, and acts with due skill, care
and diligence. In doing so, the Group is
placing the achievement of fair outcomes
for its customers at the heart of its
strategy, governance and operations.
Board and Senior Management have
ensured that there is regular reporting of
metrics and Key Risk Indicators against the
75
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Risk Management
(continued)
Conduct Risk Appetite as well as events
that could affect or have already impacted
on customers. The primary governance
body responsible for Conduct issues is the
Customer Committee (a sub-committee
of ExCo).
Reputational Risk is the risk of brand
damage and/or financial loss arising from a
failure to meet stakeholders’ expectations
of the Group or the failure of organisational
structure and governance arrangements
within the Group to embed desired
behaviours and culture. The reputation
of PTSB is founded on trust from its
employees, customers, shareholders,
regulators and from the public in general.
Isolated events can undermine that
trust and negatively impact the Group’s
reputation. Negative public opinion
can result from the actual or perceived
manner in which the Group conducts
its business activities, from the Group’s
financial performance, the level of direct
and indirect Government support or actual
or perceived practices in the banking and
financial industry. It is often observed that
reputational risk is in fact a consequence
of other risks. Negative public opinion
may adversely affect the Group’s ability to
keep and attract customers which in turn
may adversely affect the Group’s financial
condition and operations. The Group
cannot be sure that it will be successful
in avoiding damage to its business from
reputational risk.
Compliance Risk
Compliance risk is the risk of material
financial loss or liability, legal or regulatory
sanctions, or brand damage arising from
the failure to comply with, or adequately
plan for, changes to official sector policy,
laws, regulations, major industry standards,
compliance policies and procedures, or
expectations of customers and other
stakeholders.
As a financial services firm, the Group is
subject to extensive and comprehensive
legislation and regulation by a number of
regulatory authorities. The Group is classed
as a Less Significant Institution (LSI) and
is directly supervised by the Central Bank
of Ireland, as the National Competent
Authority.
The Board is responsible for overseeing
the management of compliance risk, with
senior management having a primary
76
responsibility to effectively manage
compliance with applicable laws and
regulations and for ensuring that the
Group has and effectively employs the
resources, procedures, systems and
controls, including monitoring, necessary
to ensure compliance with all existing and
forthcoming legislation.
The Regulatory Compliance and Conduct
Risk function is responsible for second line
oversight, including the updating of the
Regulatory Compliance Framework. This
Framework supports the Group to achieve
its strategic priorities while managing
regulatory compliance risks within the
Board-approved Regulatory Compliance
risk appetite. In addition, it sets out how
the Group manages current and emerging
regulatory compliance risk, details the
key principles, objectives, and primary
components of the Group’s approach to
regulatory compliance risk management,
and sets out regulatory compliance risk
management responsibilities across the
three lines of defence model.
risks the Group is or might be exposed
to, and internal control mechanisms,
including sound administrative and
accounting procedures and effective
control and safeguard arrangements for
information processing systems;
• The possibility of mis-selling financial
products or the mishandling of
complaints related to the sale of such
products by or attributed to an employee
of the Group, including as a result of
having sales practices, complaints
procedures and/or reward structures in
place that are determined to have been
inappropriate or the risk that previous
practices are deemed inappropriate
when assessed against current
standards;
• Breaching laws and requirements
relating to data protection, the detection
and prevention of money laundering,
terrorist financing, sanctions, bribery,
corruption and other financial crime; and
• Non-compliance with legislation relating
to unfair or required contractual terms or
disclosures.
The Group is exposed to many forms of risk
in connection with compliance with such
laws and regulations, including, but not
limited to:
Regulatory Developments
The level of regulatory change remains
high and continues to be an area of focus.
• The risk that changes to the laws and
regulations under which the Group
operates will materially impact on the
Group’s liquidity, capital, profitability,
product range, distribution channels or
markets;
• The risk that the Group is unable to
respond to the scale of regulatory
change and implement all required
changes in full or on time, or the
challenge of meeting regulatory changes
will impact the Group’s abilities to
undertake other strategic initiatives;
• The level of costs associated with the
regulatory overhead including, but not
limited to, the industry funding levy,
funding the resolution fund established
under the Single Resolution Mechanism
or levies in respect of applicable
compensation schemes (including the
Investor Compensation Scheme and the
Deposit Guarantee Scheme (DGS));
• Non-compliance with organisational
requirements, such as the requirement
to have robust governance
arrangements, effective processes to
identify, manage, monitor and report the
Sustainable Finance continues to be a key
priority for Governments and regulators.
The EU Action Plan on Sustainable Finance
and the EU Green Deal, set out the EU’s
strategy to integrate ESG considerations
into its financial policy framework
and mobilise finance for sustainable
growth. A key part of the strategy is the
EU Sustainable Finance Disclosures
Regulation (SFDR) and accompanying
RTS, which requires enhanced disclosure
in a consistent manner of ESG factors
into decision making processes and
customer documentation for sustainable
investments. The Corporate Sustainability
Reporting Directive (CSRD) which
introduces more detailed reporting
requirements on companies in respect
of the impact of their activities on the
environment has been finalised, and
European Sustainability Reporting
Standards (ESRS) which are linked to the
Directive are being developed.
Legislative progress continues on the
finalisation of the Basel III reforms,
which are aimed at enhancing prudential
regulatory standards, supervision and
risk management of banks. In line with
Permanent TSB Group Holdings plc - Annual Report 2022 the objectives of the EU Digital Finance
Strategy, the European Commission
(EC) has finalised the Digital Operational
Resilience Act (DORA) which will apply
from January 2025. Also as part of this
strategy the EC has recently introduced
draft legislation aimed at increasing the
availability and use of Instant Payments
in Euro. A directive which amends the
Consumer Credit Directive is due to be
finalised by the EC in 2023.
The EC’s package of legislative proposals
designed to strengthen the EU’s anti-
money laundering and countering the
financing of terrorism (AML/CFT) rules
continue to be progressed. With the
continued conflict in Ukraine and other
geo-political developments, it is anticipated
that the EU sanctions regime will continue
to evolve in 2023 with further restrictive
measures likely to be implemented
including additional financial sanctions
against individuals/entities along with
further restrictive measures on trade
and certain financial transactions being
introduced.
The Irish Government has published the
Central Bank (Individual Accountability
Framework) Bill to introduce an Individual
Accountability Regime for Banks and other
regulated entities, via a Senior Executive
Accountability Regime (SEAR).The Bill
is currently making its way through the
legislative process. The SEAR will also
include Conduct Standards for Staff and
enhancements to both the Fitness and
Probity and the Administrative Sanctions
Regimes. Following the enactment of the
legislation the Central Bank will undertake
a consultation process.
In light of the significant changes in the
retail banking landscape in Ireland the
Irish Government undertook a Retail
Banking Review. This Review issued
34 recommendations impacting the
Department of Finance, the Central Bank
and the sector itself.
The Central Bank has commenced a review
of the Consumer Protection Code (CPC).
A Discussion Paper has issued and it is
expected to be followed by a Consultation
Paper containing draft requirements in late
2023.
Regulators continue to emphasise the
importance of culture, conduct risk,
diversity practices, financial literacy,
operational and IT resilience, cyber
security, financial crime, digitalisation and
climate risk.
Group Risks
The Board has overall responsibility for
the establishment and oversight of the
GRMF. The Board has established the
BRCC, which is responsible for oversight
and advice on risk governance, the current
risk exposures of the Group and future risk
strategy, including strategy for capital and
liquidity management and the embedding
and maintenance of a supportive culture
in relation to the management of risk
throughout the Group. The BRCC, in turn,
delegates responsibility for the monitoring
and management of specific risks to
committees accountable to it such as the
GRC, GCC and the ALCO.
The BAC, consisting of members of
the Board, oversees how Management
monitors compliance with the Group’s
risk management policies and procedures
and reviews the adequacy of the Risk
Management Framework in relation to the
risks faced by the Group in consultation
with the BRCC. The BAC is assisted in
its oversight role by GIA. GIA undertakes
both routine and ad hoc reviews of risk
management controls and procedures, the
results of which are reported to the BAC.
In line with IFRS 7, the following risks to
which the Group is exposed are discussed
in detail below:
• Credit Risk;
• Liquidity Risk; and
• Market Risk (including foreign currency
exchange risk, credit spread risk and
interest rate risk).
The key financial risks arise in the
underlying subsidiary companies of
Permanent TSB Group Holdings plc
(PTSBGH). All of the Directors of PTSBGH
are also Directors of the Board of
Permanent TSB plc (PTSB).
3.1 Customer Credit Risk - Audited
Definition of Customer Credit Risk
Customer credit risk is defined as the
risk of financial loss due to the failure of
a customer, guarantor or counterparty, to
meet their financial obligations to the Bank
as they fall due. This risk includes but is not
limited to default risk, concentration risk,
migration risk, collateral risk and climate
risk.
Default Risk
Credit Default Risk is the risk that a
customer will not be able to meet the
required payments on their debt obligation
to the Bank when they become due. An
increase in the risk of default may be as
a result of one or a number of factors
including, but not limited to:
• Deterioration observed in an individual
borrower’s capacity to meet payments
as they become due;
• Deterioration observed or expected
in macroeconomic or general market
conditions;
• Regulatory change; and
• Environmental factors that impact on the
credit quality of the counterparty.
Concentration Risk
Concentration Risk is the risk of excessive
credit concentration to an individual,
counterparty, group of connected
counterparties, industry sector, geographic
area, type of collateral or product type
leading to above normal losses.
Migration Risk
Migration Risk is the risk for loss due to
a ratings (internal/external) downgrade
which indicates a change in the credit
quality of an exposure.
Collateral Risk
Collateral Risk is the potential risk of loss
arising from a change in the security value
or enforceability due to errors in nature,
quantity or pricing of the collateral.
Climate Risk
Climate Risk is the risk of declines in
the value of the Bank’s collateral on
customer loans due to the impacts from
climate change, and the imposition of
increased capital requirements if the
Bank’s borrowers do not comply with the
Stakeholder, Regulatory and Legislative
expectations to contribute to the transition
to a low carbon economy.
77
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Credit Risk Management
The Group’s credit risk management
approach is focused on detailed credit
assessment at underwriting together with
early borrower engagement where there
are signs of pre-arrears or delinquency
with a view to taking remedial action to
prevent the loan becoming defaulted.
Where a borrower is in pre-arrears, arrears
or default the Group will consider offering
treatments/options which apply to the
borrower’s circumstance cognisant of
affordability and sustainability.
The Group’s system of Portfolio Credit Risk
Management incorporates the following
key components:
• Credit policy;
• Lending authorisation;
• Credit risk mitigation;
• Credit risk monitoring;
• Arrears management and forbearance;
and
• Credit risk measurement.
Credit Policy
To aid in the management of credit risk, the
Group has put in place credit policies which
set out the core values and principles
governing the provision and management
of credit. These policies take account of
the Group’s RAS, applicable sectorial credit
limits, the Group’s historical experience
and resultant loan losses, the markets
in which the business units operate and
the products which the Group provides.
Each staff member involved in assessing
or managing credit has a responsibility
to ensure compliance with these policies
and effective procedures are in place to
manage the control and monitoring of
exceptions to policy.
Lending Authorisation
The Group’s credit risk management
systems operate through a hierarchy
of lending authorities. Exposures above
certain predetermined levels require
approval by the GCC or the Board. Below
the GCC level, a tiered level of discretion
applies with individual discretion levels
set to reflect the relevant staff members’
level of seniority, expertise and experience
and the Group’s operational needs. All
mortgage lending is currently approved
by experienced credit risk professionals
assisted by scoring models. For Group
unsecured personal lending portfolios,
scoring models and automated processes
are utilised to support the credit decision
process for those segments that present
a lower credit risk. Exposures that present
a higher credit risk, but remain within Risk
Appetite are manually reviewed prior to
approval.
Credit Risk Mitigation
The granting of a loan in the first
instance is always assessed based on
the borrower’s repayment capacity and
proven ability. Credit risk mitigation forms
a key supplementary element of the credit
granting process. Credit risk mitigation
includes the requirement to obtain
collateral, depending on the nature of the
product, as set out in the Group’s policies
and procedures. The Group takes collateral
as a secondary source, which can be called
upon if the borrower is unable or unwilling
to service and repay the debt as originally
assessed. At portfolio level, credit risk is
assessed in relation to name, sector and
geographic concentration.
Collateral
The nature and level of collateral
required depends on a number of factors
including, but not limited to, the amount
of the exposure, the type of facility made
available, the term of the facility, the
amount of the borrower’s own cash input
and an evaluation of the level of risk or
probability of default (PD).
Various types of collateral are accepted,
including property, securities, cash and
guarantees etc., grouped broadly as
follows:
• real estate;
• financial collateral (lien over deposits,
shares, etc.); and
• other collateral (guarantees etc.).
Risk Management
(continued)
Climate related risk modelling capabilities
are still evolving and in it’s infancy.
However, the Bank currently has low
exposure to SME lending when considering
high risk sector exposure to Climate Risk,
with the majority of the Bank’s portfolio
comprising Residential mortgages.
Lending officers do consider Climate and
Sustainability Risks on each SME lending
application, and assessment criteria
for new Residential property lending
incorporate an evaluation of potential
physical risks including flood, subsidence,
coastal and environmental risks as part of
the valuation process. Lending should not
proceed where the Valuer identifies risks
at individual property level which might
potentially restrict the customer’s ability to
obtain home insurance.
Governance
Credit Risk Appetite defines the Group’s
tolerance for risk and its willingness
to grant credit based on product type,
customer type, collateral concerns and
various other risk factors. The Board is
ultimately responsible for the governance
of credit risk across the Group, setting
the Risk Appetite and ensuring that there
are appropriate processes, systems and
reporting lines in place to monitor and
manage risks against the appetite.
The BRCC, a sub-committee of the Board
provides oversight to the Board on the
setting and monitoring of the Risk Appetite
and risk governance. The Group Credit
Risk Management Framework specifies
those Credit policies that require approval
by the BRCC. Under the Group Credit
Risk Management Framework the BRCC
may also delegate to the GRC, who in turn
delegates to the GCC, the authority to
approve certain Credit policies, subject to
these policies remaining within specified
policy boundaries. Any amendment to
policy which results in a policy breaching
these boundaries requires the BRCC’s
approval.
The GCC is responsible for the execution
and delivery of the Group’s system of
Portfolio Credit Risk Management. The
Board has granted authority to the BRCC
to approve a delegated framework of
lending authority within which the GCC and
Customer Credit function operate.
78
Permanent TSB Group Holdings plc - Annual Report 2022 Valuation Methodologies
The valuation methodologies for the Group’s key portfolios of collateral held are adjusted for costs to sell, as appropriate:
Residential property valuations are based on the CSO Residential Property Price Index (RPPI) or on a recent valuation from a professional
valuer. In respect of residential property securing performing loan exposures of greater than €0.5m, the Group policy is to ensure an
independent valuation is updated within the last 3 years. For residential property securing NPL exposures of greater than €0.3m, the
Group policy is to ensure an independent valuation is updated within the last year.
Commercial property valuations are based on opinions from professional valuers, the Investment Property Database Index, local
knowledge of the properties, benchmarking similar properties and other industry-wide available information, including estimated yields
discount rates. In respect of commercial property securing performing loan exposures of greater than €0.5m, the Group policy is to
ensure an independent valuation is updated within the last 3 years. For commercial property securing NPL exposures of greater than
€0.3m, the Group policy is to ensure an independent valuation is updated within the last year.
The valuation methodologies outlined above are determined as close to the statement of financial position date as is feasible and are
therefore considered by the Group to reflect its best estimate of current values of collateral held.
The Group’s requirements in respect of collateral in relation to (i) completion; (ii) taking of security; (iii) valuation; and (iv) ongoing
management are set out in credit policies.
The following table details the loan balance distribution by indexed Loan to value (LTV) band for the Group’s residential mortgage
portfolio (home loan and buy-to-let).
Residential Mortgage Exposures by Indexed LTV
31 December 2022
Less than 70%
71% to 90%
91% to 100%
Subtotal
Greater than 100%
Subtotal
Total Residential Mortgages
Commercial
Consumer Finance
Total loans and advances to customers
Deferred fees, discounts and fair value adjustment
Gross loans and advances to customers
31 December 2021
Less than 70%
71% to 90%
91% to 100%
Subtotal
Greater than 100%
Subtotal
Total Residential Mortgages
Commercial
Consumer Finance
Total loans and advances to customers
Deferred fees, discounts and fair value adjustment
Gross loans and advances to customers
Home loans
Buy-to-let
€m
15,602
2,499
103
18,204
136
136
18,340
€m
414
197
61
672
152
152
824
Home loans
Buy-to-let
€m
€m
9,048
3,146
157
12,351
217
217
12,568
778
333
182
1,293
330
330
1,623
Total
€m
16,016
2,696
164
18,876
288
288
19,164
239
401
19,804
310
20,114
Total
€m
9,826
3,479
339
13,644
547
547
14,191
196
358
14,745
115
14,860
79
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Risk Management
(continued)
Credit Risk Monitoring
Credit Risk Appetite Metrics and Limits
are designed to align with the strategic
objectives of the Group to maintain stable
earnings growth, stakeholder confidence
and capital adequacy. This is achieved
through setting concentration limits for
higher risk product segments, ensuring
new business meets pricing hurdle rates
and through monitoring default rates and
losses. Limits are also set in the context of
the peer group, regulatory and economic
landscape, to ensure the Group does not
become an outlier in the market. Monthly
updates are presented to the GCC and the
BRCC which include an overview, trends,
limit categories and detail on mitigation
plans proposed where a particular
parameter is close or at its limit.
Credit Risk Appetite is considered an
integral part of the annual planning/
budget process and reviewed at various
checkpoints in the year to ensure the
appetite is being met and is not expected to
be breached during the budget time frame.
Arrears Management and Forbearance
Forbearance occurs when a borrower
is granted a temporary or permanent
concession or agreed change to a loan
(“forbearance measure”), for reasons
relating to the actual or apparent financial
stress or distress of that borrower.
Forbearance has not occurred where the
concession or agreed change to a loan
does not arise from actual or apparent
financial distress.
The Group is committed to supporting
customers that are experiencing financial
difficulty and seeks to work with those
customers to find a sustainable solution
through proactive arrears management
and forbearance. Group credit policy
and procedures are designed to comply
with the requirements of the CBI Code of
Conduct on Mortgage Arrears (CCMA),
which sets out the framework that must
be used when dealing with borrowers in
mortgage arrears or in pre-arrears.
The Group’s forbearance strategy is built
on two key factors namely affordability
and sustainability. The main objectives
of this strategy are to ensure that arrears
solutions are sustainable in the long-
term, that they comply with all regulatory
requirements and where possible keep
customers in their home.
80
Types of forbearance treatment currently
offered by the Group include short term
temporary arrangements (such as a
payment moratorium) and term appropriate
treatments (such as reduced payment,
arrears capitalisation and term extension).
Requests for concessions in recent
years are arising as a result of temporary
cash flow problems and an inability to
repay at contractual maturity, whereas
during the 2008 financial crisis such
requests reflected more in-depth long-
term affordability issues. This is further
reflected in the change in the volume and
nature of forbearance measures availed.
A request for forbearance is a trigger event
for the Group to undertake an assessment
of the customer’s financial circumstances
prior to any decision to grant a forbearance
treatment. Where a borrower has been
granted a forbearance treatment, the
loan is considered to have experienced a
significant increase in credit risk (SICR) and
is classified as Stage 2 for Expected Credit
Loss (ECL) assessment purposes under
IFRS 9. The customer assessment may
also result in the customer being classified
as Stage 3, credit impaired as a result of
the requirement for a specific impairment
provision.
Further deterioration in the individual
circumstances of the borrower or where
expected improvement in the borrower’s
circumstances fails to materialise may
result in non-compliance with the revised
terms and conditions of the forbearance
measure. In such circumstances the
Group may consider a further forbearance
request or the loan may ultimately prove
unsustainable.
The effectiveness of forbearance
measures over the lifetime of the
arrangements are subject to ongoing
management and review. A forbearance
measure is considered to be effective if the
borrower meets the modified terms and
conditions over a sustained period of time
resulting in an improved outcome for the
borrower and the Group.
Credit Risk Measurement
Applications for credit are rated for
credit quality as part of the origination
and loan approval process. The risk,
and consequently the credit grade,
is reassessed monthly as part of a
continuous assessment of account
performance and other customer related
factors.
Credit scoring plays a central role in
the ratings process. Credit scoring
combined with appropriate portfolio risk
segmentation is the method used to assign
grades, and in turn the PDs to individual
exposures under each framework.
The Group, as approved by the Central
Bank of Ireland, has adopted the
standardised approach for calculation of
Risk Weighted exposure amounts for the
Commercial, Corporate and SME portfolios.
Internal Ratings Based Models
Scorecards have been designed for
each portfolio based on the drivers or
characteristics of default associated
with that portfolio. Typical scoring
characteristics include financial details,
bureau information, product, behavioural
and current account data. For portfolios
where there is not enough data to develop
statistical models, expert judgement-based
models are used.
For each of the Group’s key residential
home loan and buy-to-let mortgage
portfolios, a scorecard combining
application and behavioural factors has
been developed which allows for the
consistent ranking of exposures for risk
through time. These scorecards are used
consistently across IFRS 9 and IRB models
to assign grades and in turn PD, 12 month
and lifetime, to individual exposures.
For capital purposes and in accordance
with the CRR, all of the Group’s internal
ratings based (IRB) exposures are mapped
to a risk rating scale (master scale) which
reflects the risk of default. The assignment
of an exposure to a grade is based on
the probability of an exposure defaulting
in the next year. The credit risk ratings
employed by the Group are designed to
highlight exposures requiring Management
attention. The Group uses the Basel 25
point scale for the IRB approach for credit
risk. The scale ranges from 1 to 25 where 1
represents the best risk grade or lowest PD
and 25 represents the defaulted exposures
or PD equal to 100% for credit risk. All of
the Group’s exposures are mapped to the
rating scale based on PD.
Credit grading and scoring systems
are used by the Group to assist in the
identification of vulnerabilities in loan
quality in advance of arrears. Changes in
scoring information are reflected in the
Permanent TSB Group Holdings plc - Annual Report 2022 credit grade of the borrower and where there is a significant deterioration may result in a reclassification of the exposure into Stage 2 for
ECL assessment purposes.
The Group’s material scorecards and models used for risk origination and ongoing measurement purposes are subject to annual review
by an independent MVT to ensure that they remain fit for purpose.
The following information has not been subject to audit by the Group’s independent auditor.
Satisfactory and above can primarily be expected to be classified as IFRS 9
Stage 1
•
Investment grade (IRB ratings 1 to 7) – includes very high quality exposures.
• Excellent risk profile (IRB ratings 8 to 16) – includes exposures whose general profiles are considered to be of a very low risk nature.
• Satisfactory risk profile (IRB ratings 17 to 21) – includes exposures whose general profiles are considered to be of a low to moderate
risk nature. Accounts are considered satisfactory or above if they have no current or recent credit distress, are not more than 30
days in arrears and there are no indications they are unlikely to pay.
Fair can primarily be expected to be classified as Stage 2
• Fair risk profile (IRB ratings 22 to 24) – Accounts of lower quality and considered as less than satisfactory are categorised as fair and
include the following;
• Emerging: Accounts exhibiting weakness and are deteriorating in terms of credit quality and may need additional management
attention e.g. missed payments, deteriorating savings performance;
• Recovery: Includes accounts with recent default experience, accounts which are performing as a result of forbearance measures
and need to complete a probationary period and accounts with significant terminal payments; and
• Latent: Accounts that are performing but exhibit underlying credit characteristics which could threaten recoverability should they
become non-performing e.g. interest only accounts which are projected to be in negative equity at maturity.
Non-performing will align to Stage 3
Defaulted (IRB rating 25) – Accounts that are considered as defaulted or non-performing.
Credit Exposure
Maximum exposure to credit risk before collateral held or other credit enhancements
The table below outlines the maximum exposure to credit risk before collateral held or other credit enhancements in respect of the
Group’s financial assets as at the statement of financial position date.
Year ended
Year ended
Notes
31 December
2022
31 December
2021
€m
€m
Cash at bank
Items in course of collection
Loans and advances to banks
Other assets (Loans sale receivable)
Derivative financial instruments
Debt securities
Loans and advances to customers
Commitments and contingencies
Further detail on loans and advances to customers is provided in note 38, Financial Risk Management.
14
14
15
17
16
19
22
43
58
40
2,123
-
-
3,177
19,593
24,991
1,342
26,333
57
20
4,174
310
1
2,494
14,256
21,312
1,181
22,493
81
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Risk Management
(continued)
The following tables outline the Group’s exposure to credit risk by asset class
Debt securities
The Group is exposed to the credit risk on third parties where the Group holds debt securities (including sovereign debt). These exposures
are subject to the limitations contained within the Board approved policies, with sovereign debt restricted to those countries that have an
External Credit Assessment Institution (ECAI) rating of investment-grade.
The following table gives an indication of the level of creditworthiness of the Group’s debt securities and is based on the ratings
prescribed by Moody’s Investor Services Limited and Standard and Poor’s for the EU. There are no impaired debt securities as at 31
December 2022 or at 31 December 2021, with the exception of the corporate bond.
Debt securities neither past due nor impaired
Rating
Aaa
AA+
Aa2
A1
A2
Baa1
Baa2
Baa3
Total
The following table discloses, by country, the Group’s exposure to sovereign and corporate debt as at:
Country
Ireland
Portugal
Spain
France
Italy
EU
Total
31 December
2022
31 December
2021
€m
€m
49
110
250
1,734
-
497
456
81
3,177
60
-
-
-
1,463
506
465
-
2,494
31 December
2022
31 December
2021
€m
€m
1,783
456
497
250
81
110
3,177
1,523
465
506
-
-
-
2,494
Loans and advances to banks
The Group has a policy to ensure that loans and advances to banks are held with investment grade counterparties, with any exceptions
subject to prior approval by the BRCC. The following table gives an indication of the level of creditworthiness of the Group’s loans and
advances to banks and is based on the internally set rating that is equivalent to the rating prescribed by Moody’s Investor Services
Limited and Standard & Poors for the CBI.
Rating
Aaa
Aa2
Aa3
A1
A2
Ba1
Total
82
31 December
2022
31 December
2021
€m
€m
1,620
199
286
10
-
8
2,123
3,709
199
258
2
6
-
4,174
Permanent TSB Group Holdings plc - Annual Report 2022
Loan Impairment
Under IFRS 9 an entity is required to
track and assess changes in credit risk
on financial instruments since origination
and determine whether the credit risk on
those financial instruments has increased
significantly since initial recognition. The
change in credit risk should be based on
the change in the risk of default and not
changes in the amount of ECL which may
be expected on a financial instrument.
is based on an instrument’s lifetime PD,
not the losses expected to be incurred;
and
• PD at maturity - For interest only
exposures, all home-loan and
commercial exposures together with
those buy-to-let exposures in excess
of 70% LTV have been assessed as
presenting an increased risk of default at
maturity and are consequently classified
as Stage 2.
The standard is a 3-stage model for
impairment, based on changes in credit
risk quality since initial recognition:
Stage 1
Financial assets that have not had a SICR
since initial recognition are classified
as Stage 1. For these assets, 12-month
ECL is recognised. 12-month ECL is the
expected credit losses that result from
default events that are possible within 12
months of the reporting date. It is not the
expected cash shortfalls over the 12-month
period but the entire credit loss on an asset
weighted by the probability that the loss
will occur in the next 12 months. Therefore
all financial assets in scope will have an
impairment provision equal to at least
12-month ECL.
Stage 2
Financial assets that have had a SICR
since initial recognition but that do not
have objective evidence of impairment
are classified as Stage 2. For these assets,
lifetime ECL is recognised, being the
expected credit losses that result from all
possible default events over the expected
life of the financial instrument.
At each reporting date, the Group has
relied on the following measures to identify
a SICR in relation to an exposure since
origination, and classification as Stage 2
within the IFRS 9 ECL framework:
• Delinquency – greater than 30 days past
due;
• Forbearance – reported as currently
forborne in accordance with European
Banking Authority (EBA) NPL guidelines;
• Risk Grade – accounts that migrate to a
risk grade which the bank has specified
as being outside its Risk Appetite for
origination;
• Change in remaining lifetime PD –
accounts that have a remaining lifetime
PD that is in excess of the risk at which
the bank seeks to originate risk. For the
purposes of this assessment, credit risk
The assessment of SICR is performed on a
relative basis and is symmetrical in nature,
allowing credit risk of financial assets to
move back to Stage 1 if the increase in
credit risk since origination has reduced
and is no longer deemed to be significant.
Transition from Stage 3 to Stage 2
Movements between Stage 2 and
Stage 3 are based on whether financial
assets meet the definition of default as
at the reporting date.
Certain long-term forbearance
treatments may transition from Stage
3 to Stage 2 in line with the definition
of default but would not be expected
to transition from Stage 2 to Stage 1
without an unwind of the forbearance
treatment e.g. part capital and interest
treatments.
Transition from Stage 2 to Stage 1
No longer 30 days past due – transition
automatically (i.e. without probation),
where other criteria are met.
Forborne exposures where certain
criteria are met (e.g. no longer
classified as EBA forborne).
Stage 3
Financial assets that have objective
evidence of impairment at the reporting
date are classified as Stage 3, i.e. are credit
impaired. For these assets, lifetime ECL is
recognised.
The definition of default used in the
measurement of ECL for IFRS 9 purposes
is aligned to the regulatory definition
of default used by the Group for credit
risk management purposes, and which
has been approved for use for capital
management. For the Group’s main
Mortgage Portfolio, this is the definition of
default approved for use under Targeted
Review of Internal Models (TRIM) from 31
December 2018. The definition of default
was implemented under IFRS 9 with effect
from 1 January 2018 in anticipation of
this approval. This definition of default
has been designed to comply with the
Regulatory requirements and guidelines on
default, NPLs and forbearance.
IFRS 9 does not define default, but
contains a rebuttable presumption that
default has occurred when an exposure is
greater than 90 days past due. The Group
did not rebut this presumption for any
portfolio.
Under the Group’s definition of default
an exposure is considered defaulted and
is classified as Stage 3 credit-impaired
where an account is greater than 90 days
past due on any material credit obligation
or is otherwise assessed as unlikely to
pay. Where a material amount of principal
on interest remains outstanding at the
reporting date, the counting of days past
due commences from the first date that a
payment, or part thereof, met materiality
thresholds and became overdue.
Key indicators of unlikely to pay include:
• Accounts that have, as a result of
financial distress, received a concession
from the Group with respect to terms or
conditions. Such exposures will remain
in Stage 3 until certain exit conditions
are met and for a minimum probationary
period of 12 months before moving to a
performing classification;
• Accounts that have, as a result of
financial distress, received a concession
from the Group with respect to terms or
conditions which result in a significant
terminal payment. Such exposures must
fulfil additional conditions in relation to
that terminal payment before moving to
a performing classification; and
• Accounts where the customer is
assessed as otherwise unlikely to
pay, including bankruptcy, personal
insolvency, assisted voluntary sale,
disposal etc.
Exception to the general three stage
impairment model
Purchased or Originated Credit Impaired
(POCI) are excluded from the general
3 stage impairment model in IFRS 9.
POCI assets are financial assets that
are credit impaired on initial recognition.
POCI assets are recorded at fair value at
83
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Risk Management
(continued)
original recognition and interest income
is subsequently recognised on a credit-
adjusted effective interest rate (EIR) basis.
ECLs are only recognised or released to the
extent that there is a subsequent change
in expected credit losses. The Group
purchased the credit impaired Newbridge
Credit Union (NCU) portfolio in 2013, the
NCU portfolio is accounted for on a POCI
basis under IFRS 9.
Low credit risk exemption
A low risk exemption can be availed
for financial instruments under IFRS 9
for which the Group can demonstrate
objective evidence that these financial
instruments are not subject to a SICR.
The Group considers credit risk on a
financial instrument low if it meets the
following conditions:
• Strong capacity by the borrower to meet
its contractual cash flow obligations in
the near term;
• Adverse changes in economic business
conditions in the longer term may, but
will not necessarily, reduce the ability of
the borrower to fulfil its contractual cash
flow obligations; and
• External rating of investment grade or an
internal credit rating equivalent.
Modified financial assets
Where a financial asset is modified or an
existing financial asset is replaced with
a new one, an assessment is made to
determine if the financial asset should be
derecognised. If the terms are substantially
different, the Group derecognises the
original financial asset and recognises a
new asset at fair value and recalculates
a new EIR for the asset. The date of
renegotiation is consequently considered
to be the date of initial recognition for
impairment calculation purposes, including
for the purpose of determining whether
a SICR has occurred. However, the Group
also assesses whether the new financial
asset recognised is deemed to be credit
impaired at initial recognition, especially
in circumstances where the renegotiation
was driven by the debtor being unable
to make the originally agreed payments.
Differences in the carrying amount are
also recognised in profit or loss as a gain or
loss on derecognition. If the terms are not
substantially different, the modification
does not result in derecognition and the
date of origination continues to be used to
determine SICR.
84
ECL Framework
The Group’s IFRS 9 models leverage
the systems and data used to calculate
expected credit losses for regulatory
purposes. In particular, key concepts
such as the definition of default and
measurement of credit risk (i.e. ranking
of exposures for risk) have been aligned
across the impairment (accounting) and
regulatory frameworks. IFRS 9 models,
however, differ from regulatory models in
a number of conceptual ways (e.g. the use
of ‘through the cycle’ (TTC) (regulatory)
versus ‘point in time’ (IFRS 9) inputs, 12
month ECL (regulatory) versus lifetime
ECL (IFRS 9)) and as a result the Group did
not leverage the outputs of its regulatory
models, but instead developed statistical
models tailored to the requirements of IFRS
9.
the PD used for the ECL process. All
components of PD, risk grade, ODR
and economic response model are
independently monitored by the Group’s
MVT to confirm ongoing fitness for
purpose.
IFRS 9 LGD
For the Group’s key mortgage portfolios,
LGD assumes that the Group will have
recourse to collateral in the event that an
exposure fails to return to a performing
state. The LGD model incorporates the
probability of each defaulted account
returning to performing together with the
estimated loss rate should they return to
performing and the estimated loss rate
should they not return to performing. The
Group uses a consistent approach for LGD
estimation for both 12 month and lifetime.
Measurement
For all material portfolios, the Group has
adopted an ECL framework that takes
cognisance of industry best practice,
as set out in the Global Public Policy
Committee (GPPC) paper, and reflects
a component approach using PD, Loss
Given Default (LGD) and Exposure at
default (EAD) components calibrated for
IFRS 9 purposes. To adequately capture
life-time expected losses, the Group also
modelled early redemptions as a separate
component within the ECL calculation.
IFRS 9 PD
For estimating 12 month and lifetime
default, the Group uses a statistical model
methodology that allows the Group to
estimate the risk that a loan will default
at a given point in time, through grouping
exposures with similar risk characteristics
and measuring the historic rate of default
for exposures of this type. This technique
effectively provides a TTC measure of
likelihood of default. To translate this TTC
probability to a Point in Time probability
and to reflect forward looking information
(FLI) at the balance sheet date, the
Group calibrates the starting point for
the projection to the current Observed
Default Rate (ODR). The Group then uses an
economic response model to reflect future
expected macroeconomic conditions.
Behavioural scorecards, containing key
loan performance indicators for each
customer are used for the purpose of
grouping exposures with similar risk
characteristics as described above. A PD
is calculated for each group (internally
referred to as risk grades) which drives
IFRS 9 EAD
For performing loans, the EAD is calculated
for each future period based on the
projected loan balance (after expected
capital and interest payments) at that
future period. A Credit Conversion Factor
(CCF) is then applied to calculate the
percentage increase in balance from
the point of observation to the point of
default including accrued missed interest
payments and any related charges. The
CCF is segmented by the accounts’
repayment type.
Expected life
When measuring ECL, the Group must
consider the maximum contractual period
over which the Group is exposed to credit
risk. All contractual terms should be
considered when determining the expected
life, including prepayment options,
extension and rollover options. For most
instruments, the expected life is limited to
the remaining contractual life, adjusted as
applicable for expected prepayments.
For certain revolving credit facilities that
do not have a fixed maturity (e.g. credit
cards and overdrafts), the expected life
is estimated based on the period over
which the Group is exposed to credit risk
and where the credit losses would not be
mitigated by Management actions. For
instruments in Stage 2 or Stage 3, loss
allowances will cover expected credit
losses over the expected remaining life of
the instrument.
Effective Interest Rate
The discount rate used by the Group
in measuring ECL is the EIR (or ‘credit-
Permanent TSB Group Holdings plc - Annual Report 2022 adjusted effective interest rate’ for POCI
financial assets) or an approximation
thereof. For undrawn commitments, the
EIR, or an approximation thereof, is applied
when recognising the financial assets
resulting from the loan commitment.
Write-off policy
The Group writes off an impaired financial
asset (and the related impairment
allowance), either partially or in full, when
there is no realistic prospect of recovery
or on foot of a negotiated settlement.
Indicators that there is no prospect of
recovery include the borrower being
deemed unable to pay due their financial
circumstances or the cost to be incurred
in seeking recovery is likely to exceed the
amount of the write-off. In circumstances
where the net realisable value of any
collateral has been determined and there
is no reasonable expectation of further
recovery, write-off may be earlier than
collateral realisation. Write-off on those
financial assets subject to enforcement
activity will take place on conclusion of the
enforcement process.
In subsequent periods, any recoveries of
amounts previously written off are credited
to the provision for credit losses in the
income statement.
Governance
The Group has a detailed framework
of policies governing development,
monitoring and validation of Models.
Model Governance Committee (MGC)
oversees the execution of this framework
and approves model changes and
model validation reports prior to their
consideration by the GRC and/or the ALCO
and the BRCC, where appropriate.
The GCC is responsible for oversight of
changes to credit policies, data or post
model adjustments that would affect
model outcomes. The Impairment
Reporting Review Forum (IRRF), a sub-
committee of the GCC, is accountable
for the review and recommendation for
approval of the monthly and cumulative
year-to-date actual impairment charge for
the Group.
IFRS 9 ECL methodologies are subject to
formal review by IRFF and approval by the
GCC on a monthly basis and by the BRCC
on a half-yearly basis. The adequacy of
ECL allowance is reviewed by the BAC on a
half-yearly basis.
Forward looking information (FLI)
IFRS 9 requires an unbiased and probability
weighted estimate of credit losses by
evaluating a range of possible outcomes
that incorporates forecasts of future
economic conditions. Macroeconomic
factors and FLI are required to be
incorporated into the measurement of ECL
as well as the determination of whether
there has been a SICR since origination.
Measurement of ECLs at each reporting
period should reflect reasonable and
supportable information.
The requirement to incorporate a range
of unbiased future economic scenarios,
including macroeconomic factors, is a
distinctive feature of the ECL accounting
framework, which increases both the
level of complexity and judgement in the
measurement of allowance for credit
losses under IFRS 9.
The Group has developed the capability to
incorporate a number of macroeconomic
impacts and scenarios into the ECL
models.
The process to determine the FLI applied
in the ECL models leverages existing
ICAAP processes while recognising
that IFRS 9 scenarios are not stress
scenarios. The methodology to incorporate
multiple economic scenarios into the
ECL models considers, amongst other
things, the Group’s IPP and the views of
policy makers on longer term economic
prospects and key risks. In developing the
methodology, the Group has referenced
publically available information for
key economic indicators including
the RPPI, unemployment, interest
rates and publically available external
macroeconomic forecasts including from
the Department of Finance (DoF), the CBI
and ESRI. The Group employs the services
of an independent economist to determine
forecast macroeconomic scenarios. The
governance and oversight process includes
the review and challenge by ALCO of FLI
and its onward recommendation to the
BRCC for approval.
In general, a review and update of
macroeconomic variables takes place
at least bi-annually. Macroeconomic
scenarios were most recently updated
in December 2022, with a downgrading
of main forward looking indicators in all
indicators to that utilised in December
2021.
The Group has adopted three
macroeconomic scenarios for ECL
purposes. The Group’s approach applies
extreme-but-plausible economic scenarios
(i.e. underpinned by historical evidence) to
estimate the distribution of ECL to which
the Group is exposed. The central scenario
is at the 50th percentile of the distribution
of scenarios (implying a 50% probability
that the actual outcome is worse than the
central forecast and a 50% probability that
the outcome is better). The Upside scenario
is at the 5th percentile and the Downside
scenario is at the 95th percentile. IRRF
reviewed the scenario probabilities and
recommended them to the BRCC, where
they were approved. Using statistical
techniques combined with expert credit
judgement, the Group then formulates an
unbiased probability weighted estimate
of ECL at the reporting date (see note
2, Critical accounting estimates and
judgements for further detail).
Expert Credit Judgement
The Group’s ECL accounting framework
methodology, in line with the requirements
of the standard, requires the Group to
use its experienced credit judgement
to incorporate the estimated impact of
factors not captured in the modelled ECL
results, in all reporting period dates (see
note 1, Critical accounting estimates and
judgements for further detail).
At 31 December 2022, the impairment
provision included €137m of
Management’s adjustments to modelled
outcomes.
3.2 Funding and Liquidity Risk -
audited
Funding Risk is the risk that the Group is
not able to achieve its target funding mix
or is over-reliant on System Funding/
Wholesale Markets. Funding Risk can also
occur if the Group fails to meet regulatory
requirements and, in extremis, is not able to
access funding markets or can do so only
at excessive cost.
Liquidity Risk is the risk that the Group
has insufficient funds to meet its financial
obligations as and when they fall due,
resulting in an inability to support normal
business activity and/or failing to meet
regulatory liquidity requirements. These
risks are inherent in banking operations
and can be heightened by a number
of factors, including over reliance on a
particular funding source, changes in credit
ratings or market dislocation.
85
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Risk Management
(continued)
The level of risk is dependent on the
composition of the balance sheet, the
maturity profile and the quantum and
quality of the liquidity buffer. It is likely that
these risks would be further exacerbated
in times of stress. Given the nature of the
Group’s retail focus which stems from its
business model, Liquidity and Funding
risk will arise naturally due to the maturity
transformation of primarily short term
contractual deposits (albeit recognising
behavioural stickiness) into longer term
loans (predominantly mortgage lending).
With 94% of the balance sheet being
deposit funded, exposure to a potential
deposit run represents the primary liquidity
and funding risk.
The following information has not
been subject to audit by the Group’s
independent auditor.
(i) Regulatory Compliance
The Group is required to comply with
the liquidity requirements of the CBI and
the full spectrum of European regulatory
requirements including CRR, CRD IV and
associated Delegated Acts such as the
LCR Delegated Act.
The primary ratios calculated and
reported are the LCR and the NSFR.
In addition, supplementary liquidity
and funding metrics are measured and
monitored on a regular basis
Under the Bank Recovery and Resolution
Directive (BRRD), the Group is required
to adhere to an MREL target. The
Group has proactively engaged with
the CBI to determine the Group’s
MREL requirement, which represents
a quantification of the eligible liabilities
required to act as a buffer in the event of
a resolution scenario. MREL targets have
been communicated and compliance
with the intermediate target became
binding on 1 January 2022. The final
target becomes binding on 1 January
2024. The Group has a senior unsecured
issuance strategy to meet the MREL
target.
ii. Risk Management, Measurement and
Monitoring
Group Treasury are responsible for the day
to day management of the Group’s liquidity
position and ensuring compliance with the
regulatory requirements. In carrying out
this responsibility, the principal objective
86
is to ensure that adequate liquid assets
are available at all times to meet the
operational and strategic liquidity needs
of the Group under both normal and
stressed conditions. Liquidity management
focuses on the overall balance sheet
structure together with the control of risks
arising from the mismatch in contracted
maturities of assets and liabilities, undrawn
commitments and other contingent
liabilities.
Liquidity risk is measured on a daily basis
using a range of metrics against the
internally as well as regulatory prescribed
limit framework. The Group primarily
monitors its liquidity position through the
LCR. The objective of the LCR is to promote
the short-term resilience of the liquidity
risk profile of banks. It achieves this by
ensuring that banks have an adequate
stock of unencumbered high-quality liquid
assets (HQLA) that can be converted easily
and immediately in private markets into
cash in order to meet the liquidity needs for
a 30-calendar day liquidity stress scenario.
NSFR and Liquidity Stress Survivability
constitute additional core liquidity and
funding metrics within the overarching
Liquidity and Funding Risk Management
framework that are measured, monitored
and reported within the Group.
The Group also actively monitors a
comprehensive suite of Key Risk Indicators
(KRIs) and Early Warning Indicators (EWIs)
covering a range of market wide and Group
specific events. The purpose of these
metrics is to provide forewarning of any
potential liquidity trigger events, ensuring
the Group has sufficient time to intervene
and mitigate any emerging risk.
The Contingency Funding Plan (CFP)
outlines the strategy and action plan
to address liquidity crisis events. The
CFP identifies processes and actions
incremental to the existing daily liquidity
risk management and reporting framework
to assist in making timely, well-informed
decisions.
Stress testing forms a key pillar of the
overall liquidity and funding risk framework
and is conducted from both an economic
and normative perspective (as guided
by the EBA). Overall, the Group takes a
prudent approach in setting the inflow
and outflow parameters at a level which is
appropriate for each stress scenario with
due consideration of the Group’s business
model, liquidity and funding risk exposures
and the liquidity risk drivers, including
those outlined in the EBA SREP Guidelines.
The stress testing framework is designed
to reflect the liquidity and funding position
impact under idiosyncratic, systemic and
combined stresses.
The full suite of liquidity metrics and stress
test results are regularly reported to the
ALCO, the BRCC and the Board.
In addition, the Group Internal Liquidity
Adequacy Assessment (ILAAP) provides
a holistic view of the Group’s liquidity
adequacy. The ILAAP examines both
the short and long term liquidity position
relative to the internal and regulatory limits.
Through the ILAAP process, the Board
attests to the adequacy of the Group’s
liquidity position and risk management
processes on an annual basis.
iii. Liquidity Risk Management
Framework
The exposure to liquidity and funding risk
is governed by the Group’s Liquidity and
Funding Risk Management Framework
and underlying policies, RAS and
associated limits. The framework and
policies are designed to comply with
regulatory standards with the objective
of ensuring the Group holds sufficient
counterbalancing capacity to meet its
obligations, including deposit withdrawals
and funding commitments, as and
when they fall due under both normal
and stressed conditions. The process
establishes quantitative rules and
targets in relation to the measurement
and monitoring of liquidity risk. The
Liquidity and Funding Risk Management
Framework is approved by the BRCC on
the recommendation of the ALCo. The
effective operation of liquidity policies are
delegated to the ALCo, while Group Risk
and GIA functions provide further oversight
and challenge and ensure compliance with
the framework.
The Liquidity and Funding Risk
Management Framework outlines the
mechanisms by which liquidity and
funding risk is managed within the Board
approved Risk Appetite and is in line with
the overarching liquidity and funding risk
principles as follows:
Permanent TSB Group Holdings plc - Annual Report 2022 • Liquidity: maintain a prudent liquid asset
buffer above the internally determined
or regulatory mandated (whichever is
greater) liquidity requirement such that
the Group can withstand a range of
severe yet plausible stress events; and
• Funding: develop a stable, resilient and
maturity-appropriate funding structure,
with focus on customer deposits
augmented by term wholesale funding
sources.
iv. Minimum Liquidity Levels
The Group maintains a sufficient liquidity
buffer comprising both unencumbered
High Quality Liquid Assets (HQLA) and
non-HQLA liquidity capacity to meet LCR
and stress testing requirements.
The Group measures and monitors the
NSFR which is designed to limit over-
reliance on short-term funding and
promote longer-term stable funding
sources.
(v) Liquidity Risk Factors
Over reliance and concentration on any
one particular funding source can lead to a
heightened liquidity impact during a period
of stress. The Group relies on customer
deposits to fund its loan portfolio. The
ongoing availability of these deposits may
be subject to fluctuations due to factors
such as the confidence of depositors in the
Group, and other certain factors outside
the Group’s control including, for example,
macroeconomic conditions in Ireland,
confidence of depositors in the economy in
general and the financial services industry,
specifically the competition for deposits
from other financial institutions.
The availability and extent of deposit
guarantees are of particular importance
especially for a Retail bank. The Irish
Deposit Guarantee Scheme (DGS) protects
deposits up to a balance of €100,000.
The national DGS together with the
establishment of the European Deposit
Insurance Fund is designed to maintain
depositor confidence and protect against a
potential deposit run. A significant change
to the operation of the DGS could adversely
affect the Group’s ability to retain deposits
under a severe stress event.
The Group remains active in capital
markets, be it secured or unsecured
transactions, and any restrictions on
the Group’s access to capital markets
could pose a threat to the overall funding
position. The inability to adequately
diversify the funding base could lead
to over concentration on the remaining
funding sources.
The Group maintains a significant
liquidity buffer split between HQLA
sovereign bonds, deposits placed with the
Central Bank and ECB eligible retained
securitisations which can be monetised
quickly to safeguard against a liquidity
event. While the quantum of the buffer is
sufficient to provide capacity to withstand
a significant liquidity stress event there is
a concentration in Irish based assets which
could reduce overall capacity in the event
of an idiosyncratic Irish stress event.
Significant progress has been made in
reducing the encumbrance levels that
were reached in the period following the
Financial crisis. Following the successful
Non-Performing Loan (NPL) deleveraging
programme and the execution of the
Treasury Funding Plan, encumbrance is
now at a low base historically and well
within the target level. A clear and defined
strategy has been developed to ensure
an encumbrance level consistent with
its economic plan is maintained by the
Group. Disruption to unsecured funding
sources and a requirement to revert to an
overreliance on secured funding channels
could potentially pose a threat to this ratio
and unsecured creditors.
A series of liquidity and funding EWIs are
in place in order to alert the Group to any
potential liquidity trigger event therefore
allowing sufficient time for mitigating
actions to be taken.
(vi) Credit Ratings
The Group’s credit ratings have been
subject to change and may change in
the future, which could affect its cost or
access to sources of financing and liquidity.
In particular, any future reductions in long-
term or short-term credit ratings could:
further increase borrowing costs; adversely
affect access to liquidity; require the
Group to replace funding lost arising from
a downgrade, which may include a loss of
customer deposits; limit access to capital
and money markets; and trigger additional
collateral requirements in secured funding
arrangements and derivatives contracts.
These issues are factored into the Group’s
liquidity stress testing.
During 2022, Moody’s upgraded PTSB
Plc’s and PTSB Group Holdings senior
unsecured credit ratings and S&P
upgraded PTSB Plc’s credit rating. These
upgrades reflect: the view that the financial
disruptions of the Covid-19 pandemic
on the Group has been less severe than
initially anticipated; the continued progress
on reducing the stock of NPLs; and the
potential material opportunities following
the signing of legal agreements for the
Ulster Bank transaction.
The ratings for PTSB plc are as follows:
• Standard & Poor’s (S&P): Long-Term
Rating “BBB” with Outlook “Positive”;
• Moody’s: Long-Term Rating “A2” with
Outlook “Stable”; and
• DBRS: Long-Term Rating “BBBL” with
Outlook “Stable”.
The ratings for PTSB Group Holdings plc
are as follows:
• Standard & Poor’s (S&P): Long-Term
Rating “BB-” with Outlook “Positive”;
• Moody’s: Long-Term Rating “Baa2” with
Outlook “Positive”; and
• DBRS: Long-Term Rating “BBH” with
Outlook “Stable”.
For further details on liquidity and funding
risk see note 38.
3.3 Market Risk - audited
Market Risk can be defined as the risk
of losses in on and off-balance sheet
positions arising from adverse movements
in market prices. From the Group’s
perspective, market risk consists of three
components being Interest Rate Risk, FX
Risk and Credit Spread Risk. Often market
risk cannot be fully eliminated through
diversification, though it can be hedged
against.
The Group’s RAS and the associated
Market Risk Framework set out the Group’s
approach to management of market risk.
The Framework is approved annually by
the BRCC on the recommendation of the
ALCo.
87
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Risk Management
(continued)
All market risks arising within the Group
are subject to strict internal controls and
reporting procedures and are monitored
by the ALCo and the BRCC on a regular
basis. Group Treasury is responsible for
the management of market risk exposures
on the balance sheet. Group Risk and GIA
provide further oversight and challenge
of Group Treasury’s compliance with the
Market Risk framework and associated
Policies.
(i) Interest rate risk
Interest rate risk is the risk to earnings or
capital arising from a movement in the
absolute level of interest rates, the spread
between rates, the shape of the yield curve
or in any other interest rate relationship.
The risk may be subdivided into gap,
option and basis risk. In line with regulatory
standards, the approved Interest Rate Risk
in the Banking Book (IRRBB) methodology
determined that the Group’s interest rate
risk exposure must be derived from both an
earnings (accrual) (Earnings at Risk (EaR))
and economic value perspective (EV).
The Group separately calculates the
contractual Basis Risk exposure which is
factored into the Pillar II ICAAP process.
The risk position is added to the most
severe of EV or EaR risk levels in order to
ensure all material sources of Interest Rate
Risk are capitalised for.
Interest rate gap analysis is used to capture
re-price risk, the EV approach measures
yield curve risk while EAR is utilised to
calculate the risk to earnings.
The following information has not
been subject to audit by the Group’s
independent auditor.
In defining the level of interest rate risk
the Group applies the most severe of the
six scenarios prescribed by the Basel
and EBA Guidelines on the Management
of IRRBB, for EV and applies the most
negative of a 200bps upwards or
downwards shock for EAR models, with
both calculations subject to interest
rate flooring assumptions. The results
are measured and reported against the
Board approved risk limits.
The Group also monitors PV01 (impact
of 0.01% movement in interest rates),
duration mismatches and NII sensitivity
when assessing interest rate risk.
The aim of modelling several types
of interest rate shock scenarios is to
measure the Group’s vulnerability to
loss under multiple stressed market
conditions.
The 31 December 2022 interest rate
risk level, based on the EAR calculation
(more severe than EV), was calculated as
€116m (31 December 2010: €40m). The
risk position has increased as the ECB
has increased its refinance rate from
zero and there is more downside for the
Bank in a scenario where interest rates
decrease by 200 bps.
Based on the internally derived Basis
Risk calculation methodology, the 31
December 2022 risk level stands at
€19m (31 December 2021 €14m). Basis
Risk has increased due to the rise in ECB
rates above the interest rate floors. The
following interest rate floors are applied
in calculating EAR and Basis Risk: 0%
for the ECB Refinance Rate and Retail
Deposits; -50bps for the ECB Deposit
Rate and -100bps for other positions
(ii) Foreign Exchange Risk
Foreign currency exchange risk is the
volatility in earnings resulting from
the retranslation of foreign currency
denominated assets and liabilities.
Consistent with its business model as
a domestically focused Retail bank, the
Group is predominantly exposed to GBP
and USD positions arising from customer
deposits denominated in these currencies
or branch bureau activities.
Derivatives (FX swaps and forwards) are
executed to minimise the FX exposure.
Overnight FX positions are monitored
against approved notional limits. It is the
responsibility of both Group Treasury
and Group Risk to measure and monitor
exchange rate risk and maintain the
exposure within approved limits. The
aggregate euro denominated 31 December
2022 FX position was €0.8m (31 December
2021 €0.8m).
(iii) Credit Spread Risk
Credit Spread Risk is defined as the risk
of a decline in the value of an asset due to
changes in the market perception of its
creditworthiness. This risk applies to the
portion of the Group’s bond portfolio which
is classified as Hold to Collect and Sell
(HTC&S) under IFRS9 classifications.
The Group’s strategy is to hedge, as
much as is practical, the interest rate risk
element of the HTC&S bond volatility. The
remaining Mark-to-Market (MTM) volatility
represents the Group’s Credit Spread Risk
exposure.
The Group held no HTC&S bonds as at
31 December 2022 (31 December 2021:
nil) and as such had no exposure to credit
spread risk. For further details on market
risk see note 38.
88
Permanent TSB Group Holdings plc - Annual Report 2022
Directors’ Report
The Directors present their Annual Report
and audited Group and Company Financial
Statements to the shareholders for the
year ended 31 December 2022.
Results
The Group’s profit for the year was €223m
(2021 loss: €20m) and was arrived at as
presented in the consolidated income
statement.
Dividends
No dividends were paid in 2022.
Review of the Business and likely
Future Developments
A detailed review of the Group’s business
activities, performance for the year and an
indication of likely future developments are
set out in the Strategic Report. Information
on the KPIs and principal risks and
uncertainties of the business are provided
as required by the European Accounts
Modernisation Directive (2003/51/EEC).
The Group’s KPIs are included in the
Strategic Report section. The principal
risks and uncertainties are outlined under
“risk factors” in the Risk Management
section and under “Longer Term Viability”
within the Board Audit Committee section
of the Corporate Governance Statement.
Accounting Policies
The principal accounting policies, together
with the basis of preparation of the
Financial Statements are set out in note 1
to the Consolidated Financial Statements.
Corporate Governance
The Corporate Governance Statement,
as outlined in the Corporate Governance
section, forms part of the Directors’ Report.
Principal Risks and Uncertainties
Information concerning the principal risks
and uncertainties of the Group are set out
in the risk management section of the
Strategic Report on page 67 of the Annual
Report.
Financial Instruments
The financial instruments and use thereof
are outlined in the Risk Management
section, financial risk management note
38 and Derivative financial instruments
note 16.
Going Concern
The Group’s Financial Statements have
been prepared by the Directors on a going
concern basis having considered that it is
appropriate to do so. The going concern
of the Group has been considered in Note
1 of the financial statements and further
information on the assessment of the
going concern position is also set out in
the Governance Statement on page 128
under the Board Audit Committee’s 2022
significant financial reporting judgments
and disclosures.
Longer Term Viability
Taking account of the Group’s current
position and principal risks, the Directors
have assessed the prospects of the
Group over the period 2023-2025. The
Directors confirm that it is their reasonable
expectation that the Group will be able to
continue in operation and meet its liabilities
as they fall due over this period. Further
detail on the assessment of the Group’s
longer term viability is set out in the
Corporate Governance Statement on page
128 under the Board Audit Committee’s
2022 significant financial reporting
judgements and disclosures.
Directors’ Compliance Statement
As required by section 225(2) of the
Companies Act 2014, the Directors
acknowledge that they are responsible for
securing the Company’s compliance with
its relevant obligations (as defined in that
legislation). The Directors have drawn up
a compliance policy statement and have
put in place arrangements and structures
that are, in the Directors’ opinion, designed
to secure material compliance with the
relevant obligations. A review of these
arrangements was conducted during the
year.
Statement of Relevant Audit
Information
In preparing and approving the 2022
Annual Report and in accordance with
Section 330 (1) of the Companies Act
2014, each of the current Directors of the
Company confirm that;
• So far as the Directors are aware, there
is no relevant audit information of which
the statutory auditors are unaware; and
• The Directors have taken all steps
that they ought to have taken to make
themselves aware of any relevant audit
information and have established that
the statutory auditors are aware of that
information.
Audit Committee
In accordance with Section 167(3)(a) of the
Companies Act 2014, the Directors confirm
that the Board has established an Audit
Committee.
Directors
The names of the Directors, together
with a detailed description of the key
strengths, skills, expertise and experience
of each Director, are set out in the Board
of Directors section on pages 100 to 106
of the Annual Report. Nicola O’Brien was
appointed as Chief Financial Officer and
Executive Director on 04 August 2022.
In January 2022, the Board Chairperson
Robert Elliott advised the Board that he
would not seek an extension to his term
of office which will expire on the 31 March
2023. Mr Elliott’s successor, Julie O’Neil
joined the Board as an Independent Non-
Executive Director on 17 January 2023 and
will succeed Robert Elliott as Chairperson
on 31 March 2023. Andrew Power having
completed his term of office will retire as
Non-Executive Directors at the Company’s
AGM to be held on the 19 May 2023.
Further information on the appointment
processes are included in the Nomination,
Culture and Ethics Committee section of
the Corporate Governance Statement.
All of the Directors stood and were re-
appointed by election at the 2022 Annual
General Meeting (AGM). With the exception
of Andrew Power, who will retire as a Non-
Executive Director at the conclusion of the
2023 AGM, all of the Directors will stand for
re-appointment by election at the Group’s
2023 AGM.
Information on Directors’ remuneration
is detailed in the Directors Report on
Remuneration on pages 142 to 146 of the
Annual Report and Directors’ and Secretary
interests in shares are outlined in note 44
to the financial statements.
Other than the Directors’ and Secretary’s
interests as set out in note 44, there
were no other interests disclosed to the
Company in accordance with the market
abuse regulations occurring between the
period under review and up to 28 February
2023.
Share Capital and Shareholders
Under the terms of the Credit Institutions
(Stabilisation) Act 2010 (the “Act”) the
Minister for Finance could, in certain
circumstances, direct the Company to
undertake actions that could impact on the
pre-existing legal and contractual rights
of shareholders. The Act had an original
expiry date of 31 December 2012. However,
the Act was subsequently extended to 31
December 2014 but has not since been
extended. The expiry of the Act does
not affect any order already made, or
89
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Directors’ Report
(continued)
the variance, termination, enforcement,
variation or revocation of any existing
order nor does it affect the ability of the
Minister to impose certain conditions on
any financial support provided under or in
connection with the Act.
Relationship Framework with the
Minister for Finance
The Minister for Finance of Ireland owns
and controls 62.4% (2021: 74.9%) of the
Company’s issued ordinary share capital.
Under the terms of the Relationship
Framework entered into between the
Minister for Finance and the Company, the
Minister for Finance expects the Board and
Management team of the Group to conduct
the Group’s commercial operations in a
prudent and sustainable manner which
seeks to create a commercially oriented
credit institution that recognises the need
to encourage and enforce implementation
of lessons learned from the financial crisis.
The Minister for Finance recognises that
the Group remains a separate economic
unit with independent powers of decision
and that its Board and Management
team retain responsibility and authority
for determining the Group’s strategy and
commercial policies (including business
plans and budgets) and conducting its
day-to-day operations. The Minister for
Finance will ensure that the investment
in the Group is managed on a commercial
basis and will not intervene in day-to-
day management decisions of the Group
(including with respect to pricing and
lending decisions).
Transactions and arrangements between
the Group and the Minister for Finance
or associates of the Minister for Finance
will be conducted at arms-length and on
normal commercial terms. The Minister
will not, in his capacity as a shareholder in
the Company, take any action that would
have the effect of preventing the Group
from complying with its obligations under
applicable law and regulations, including,
but not limited to, the Listing Rules and will
not propose or procure the proposal of a
shareholder resolution which is intended
to circumvent the proper application of
regulatory requirements.
The Minister engages with the Group,
including in respect of the manner in
which he exercises his voting rights,
in accordance with best institutional
practice in a manner proportionate to the
shareholding interest of the State in the
90
Company. The views of the Minister for
Finance and the DOF are expected to be
appropriately considered by the Group as
part of any consultation process under
the Relationship Framework. However the
Board and Management team have full
responsibility and authority for determining
the Group’s strategy and commercial
policies.
The Relationship Framework also provides
that the Minister for Finance and the
Company will review the Relationship
Framework from time to time when either
party reasonably considers that changes
to the Relationship Framework or to the
State Agreements (as defined therein)
would be necessary or desirable to ensure
that the Relationship Framework continues
to reflect certain principles specified in
the Relationship Framework and to enable
the Group to continue to comply with
its obligations under applicable law and
regulations, including, but not limited to,
the Listing Rules.
The Relationship Framework also imposes
restrictions on the Group undertaking
certain actions without where specified,
providing information to, consulting with,
or obtaining the consent of the Minister for
Finance. The principal restrictions are set
out in the Relationship Framework, a copy
of which is available on the Group website
www.permanenttsbgroup.ie.
The Board is satisfied that the Company
has complied with the relevant
independent provisions set out in the
Relationship Framework. The Board is also
satisfied, in so far as it is aware, that the
Minister for Finance has complied with the
relevant independence provisions set out in
the Relationship Framework.
PTSB materially completed the acquisition
of Ulster Bank’s performing non-tracker
residential mortgage business (€5.2bn
of €6.2bn) on 7 November 2022 and
entered into a shareholder co-operation
agreement with NatWest Group plc and the
Minister for Finance of Ireland in relation
to a number of matters including orderly
sale arrangements in relation to both the
shares held by the Minister and the shares
issued to RBS AA Holdings (UK) Limited,
a subsidiary of NatWest Group plc. The
shareholder cooperation agreement does
not provide the Natwest Group with any
direction or control rights or significant
influence with regard to the business of the
Group.
Authorised Share Capital
The authorised share capital of the
Company is €775,000,000 divided into
1,550,000,000 ordinary shares of €0.50
each.
Issued Ordinary Shares
At 31 December 2022, the Company had
545,589,119 ordinary shares of €0.50 each
in issue (2021: 454,695,492). Ordinary
shares represent 100% of the Company’s
issued share capital value. In November
2022, 90,893,627 ordinary shares were
issued to RBS AA Holdings (UK) Limited,
a subsidiary of NatWest Group plc. Each
ordinary share carries one vote and
the total number of voting rights at 31
December 2022 is 545,589,119 (2021:
454,695,492).
At 31 December 2022, the Company holds,
through an employee benefit trust, 4,580
(2021: 4,580) ordinary shares of €0.50
each.
Additional Tier 1 Equity Securities
On 26 October 2022, the Company issued
€250m of AT1 securities. On 25 November
2020, the Company issued €125m of AT1
securities. These AT1 Securities contain no
conversion rights into ordinary shares of
the Company.
European Union Bank Recovery and
Resolution Directive
The BRRD was implemented into Irish law
by the EU (Bank Recovery and Resolution)
Regulations 2015. BRRD provides European
national resolution authorities with
comprehensive and effective powers
for dealing with failing banks and certain
investment firms. BRRD grants a set of
early intervention powers to the Irish
national resolution authority (CBI) that
include the write-down or cancellation of
equity and/or the conversion of certain
eligible liabilities into equity. Further
information on BRRD is available on the
CBI website: https://www.centralbank.ie/
regulation/how-we-regulate/resolution-
framework.
Variation of Rights
Whenever the share capital is divided
into different classes of shares, the rights
attached to any class may be varied or
abrogated with the consent in writing of
the holders of three-quarters in nominal
value of the issued shares of that class or
with the sanction of a special resolution
Permanent TSB Group Holdings plc - Annual Report 2022 passed at a separate General Meeting of
the holders of the shares of the class, and
may be so varied or abrogated either whilst
the Company is a going concern or during
or in contemplation of a winding-up.
Allotment of Ordinary Shares
Subject to the provisions of the Articles
of Association relating to new shares,
the shares shall be at the disposal of the
Directors and (subject to the provisions of
the Articles and the Acts) they may allot,
grant options over, or otherwise dispose
of them to such persons on such terms
and conditions and at such times as they
may consider to be in the best interests of
the Company and its shareholders, but so
that no share shall be issued at a discount
and so that, in the case of shares offered
to the public for subscription, the amount
payable on application of each share shall
not be less than one-quarter of the nominal
amount of the share and the whole of any
premium thereon.
Holders of Ordinary Shares Resident
in the USA
The Board may at its discretion give
notice to certain holders’ resident in the
USA calling for a disposal of their shares
within 21 days or such longer period as the
Board considers reasonable. The Board
may extend the period within which any
such notice is required to be complied
with and may withdraw any such notice
in any circumstances the Board sees
fit. If the Board is not satisfied that a
disposal has been made by the expiry of
the 21 day period (as may be extended), no
transfer of any of the shares to which the
notice relates may be made or registered
other than a transfer made pursuant to a
procured disposal of the said shares by the
Board, or unless such notice is withdrawn.
Refusal to Transfer
The Directors in their absolute discretion
and without assigning any reason therefore
may decline to register:
• any transfer of a share which is not fully
paid save however, that in the case of
such a share which is admitted to listing
on London or Euronext Dublin Stock
Exchanges, such restriction shall not
operate so as to prevent dealings in such
share of the Company from taking place
on an open and proper basis;
• any transfer to or by a minor or person
who is adjudged by any competent court
or tribunal, or determined in accordance
with the Company’s Articles, not to
possess an adequate decision-making
capacity;
• any instrument of transfer that is not
accompanied by the certificate of the
shares to which it relates and such
other evidence as the Directors may
reasonably require to show the right of
the transferor to make the transfer;
• the instrument of transfer, if the
instrument of transfer is in respect of
more than one class of share; and
• any transfer of shares in uncertificated
form only in such circumstances as are
permitted or required by Section 1086 of
the Companies Act 2014.
General Meetings
Under the Articles of Association, the
power to manage the business of the
Company is generally delegated to the
Directors. However, the shareholders
retain the power to pass resolutions at a
general meeting of the Company which
may give direction to the Directors as to the
management of the Company.
The Company must hold a general meeting
in each year as its AGM in addition to any
other meetings in that year and no more
than fifteen months may lapse between
the date of one AGM and that of the next.
The AGM will be held at such time and
place as the Directors determine. All
General Meetings, other than AGMs, are
called Extraordinary General Meetings.
Extraordinary General Meetings shall
be convened by the Directors or on the
requisition of members holding, at the
date of the requisition, not less than five
per cent of the paid up capital carrying
the right to vote at General Meetings and
in default of the Directors acting within
21 days to convene such a meeting to be
held within two months, the requisitionists
(or more than half of them) may, but only
within three months, themselves convene
a meeting. An Extraordinary General
Meeting of the Company convened by the
Directors was held on 24 June 2022 at
which shareholders approved the terms of
the Bank’s proposed acquisition of certain
elements of the Mortgages, SME and Asset
Finance assets, in addition to 25 branches,
from Ulster Bank.
No business may be transacted at any
General Meeting unless a quorum is
present at the time when the meeting
proceeds to business. Three members
present in person or by proxy and entitled
to vote at such meeting constitutes a
quorum.
In the case of an AGM or of a meeting
for the passing of a special resolution or
the appointment of a director, 21 clear
days’ notice at the least, and in any other
case 14 clear days’ notice at the least
(assuming that the shareholders have
passed a resolution to this effect at the
previous year’s AGM), needs to be given in
writing in the manner provided for in the
Company’s Articles of Association to all the
members (other than those who, under the
provisions of the Articles of Association or
the conditions of issue of the shares held
by them, are not entitled to receive the
notice) and to the Auditor for the time being
of the Company. The Company’s Articles
of Association may be amended by special
resolution passed at a General Meeting of
shareholders. Special resolutions must be
approved by not less than 75% of the votes
cast by shareholders entitled to vote in
person or by proxy.
Substantial Shareholdings
As at 31 December 2022, the Directors
have been notified of the following
substantial interests in the voting rights of
Ordinary shares held:
Name
Interest
Date Notified
Minister for Finance of
Ireland
62.4%
340,661,653 shares
RBS AA Holdings (UK)
Limited
16.66%
90,893,627 shares
9 November 2022
8 November 2022
Janus Henderson Group
plc
3.15%
17,181,881 shares
31 May 2017
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Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Directors’ Report
(continued)
There were no other changes to substantial
interests in the voting rights of ordinary
shares reported to the Directors as at 28
February 2023.
Voting Rights of Ordinary Shares
No person holds securities carrying special
rights. There are no particular restrictions
on voting rights. The Company is not aware
of any agreements between shareholders
that may result in restrictions on the
transfer of its shares or on voting rights.
Voting rights at General Meetings of the
Company are exercised when the Chairman
puts the resolution at issue to the vote of
the meeting. A vote may be decided on a
show of hands or by poll. A vote taken on
a poll for the election of the Chairman or
on a question of adjournment is also taken
forthwith and a poll on any other question
or resolution is taken either immediately,
or at such time (not being more than 30
days from the date of the meeting at
which the poll was demanded or directed)
as the Chairman of the meeting directs.
Where a person is appointed to vote for
a shareholder as proxy, the instrument
of appointment must be received by the
Company not less than 48 hours before the
time appointed for holding the meeting or
adjourned meeting at which the appointed
proxy proposes to vote, or, in the case of a
poll, not less than 48 hours before the time
appointed for taking the poll.
Voting at any General Meeting is by a
show of hands unless a poll is properly
demanded. On a show of hands, every
member who is present in person or by
proxy has one vote regardless of the
number of shares held. On a poll, every
member who is present in person or by
proxy has one vote for each share of
which they are the holder. A poll may
be demanded by the Chairman of the
meeting or by at least five members
having the right to vote at the meeting or
by a member or members representing
not less than one-tenth of the total voting
rights of all the members having the right
to vote at the meeting or by a member or
members holding shares in the Company
conferring a right to vote at the meeting,
being shares on which an aggregate sum
has been paid up equal to not less than
one-tenth of the total sum paid up on all the
shares conferring that right. It is current
standing practice at the AGM that voting is
conducted on a poll.
The holders of the ordinary shares
have the right to attend, speak, and ask
92
questions and vote at General Meetings
of the Company. The Company, pursuant
to Section 1105 of the Companies Act
2014 and Regulation 14 of the Companies
Act 1990 (Uncertificated Securities)
Regulations 1996 (S.I. 68/1996), specifies
record dates for General Meetings,
by which date shareholders must be
registered in the Register of Members of
the Company to be entitled to attend and
vote at the meeting.
Pursuant to Section 1104 of the Companies
Act 2014, a shareholder, or a group of
shareholders who together hold at least 3
per cent of the issued share capital of the
Company, representing at least 3 per cent
of the total voting rights of all the members
who have a right to vote at the meeting to
which the request for inclusion of the item
relates, have the right to put an item on the
agenda, or to modify an agenda which has
been already communicated, of a general
meeting. In order to exercise this right,
written details of the item to be included
in the general meeting agenda must be
accompanied by stated grounds justifying
its inclusion or a draft resolution to be
adopted at the general meeting together
with evidence of the shareholder or group
of shareholders’ shareholding must be
received, by the Company, 42 days in
advance of the meeting to which it relates.
The Company publishes the date
of its AGM on its website www.
permanenttsbgroup.ie on or before 31
December of the previous financial year
or no later than 70 days before the date of
the AGM.
Director Appointments
Save as set out below, the Group has no
rules governing the appointment and
replacement of Directors outside of the
provisions thereto that are contained in
the Articles of Association. Under the
Relationship Framework entered into
between the Company and the Minister
for Finance, the Board must consult
with the Minister for Finance for the
appointment or re-appointment of the
CEO or Chairman. Upon receipt of written
notice from the Minister for Finance, the
Board shall appoint up to two nominees
of the Minister for Finance as Directors
of the Company and the appointment(s)
shall be deemed to take effect on the
date of the next Board meeting following
receipt of the aforementioned notice (and
regulatory approval). In 2018, the Board
received written notice from the Minister
for Finance of his intention to appoint
two Directors to the Board. In this regard
Marian Corcoran was appointed to the
Board on 24 September 2019 and Paul
Doddrell was appointed to the Board on
26 November 2020. Nicola O’Brien was
appointed as Chief Financial Officer and
Executive Director on 04 August 2022.
In January 2022, the Board Chairperson
Robert Elliott advised the Board that he
would not seek an extension to his term
of office which will expire on the 31 March
2023. Mr Elliott’s successor, Julie O’Neil
joined the Board as an Independent Non-
Executive Director on the 22 December
2022 and will become Chairperson on the 1
April 2023.
Powers Granted to Directors at the
AGM
The following is a description of the
resolutions passed by members in
connection with powers granted to the
Directors:
Ordinary Remuneration of Directors
At the AGM held on 14 May 2019,
shareholders authorised that the Directors
may from time to time determine in
accordance with the Articles of Association
of the Company, the aggregate ordinary
remuneration of the Directors for serving
as Directors of the Company at an amount
not exceeding €750,000.
Allotment of Shares
The Investment Association has issued
guidance which generally supports
resolutions seeking authority to allot up
to a separate and additional 33.33% of a
company’s issued share capital (excluding
treasury shares) in addition to the 33.33%
authority already supported where the
additional authority is applied to allot
shares pursuant to a rights issue.
At the 2022 AGM held on 24 June
2022, the Directors were generally and
unconditionally authorised, pursuant to
section 1021 of the Companies Act 2014, to
exercise all of the powers of the Company
to allot and issue all relevant securities
of the Company (within the meaning of
section 1021 of the Companies Act 2014)
up to an aggregate nominal amount of
€150,049,512 representing 66.66% of
the issued ordinary share capital of the
Company as at 20 May 2022 of which
€75,024,756 (representing the separate
and additional 33.33% of the issued
ordinary share capital of the Company
(excluding treasury shares) as at 30 March
2021 referred to above may be applied
to allot shares pursuant to a rights issue.
Permanent TSB Group Holdings plc - Annual Report 2022 The authority conferred commenced
on the 24 June 2022 and will expire at
the conclusion of the 2023 AGM or 24
September 2022 (whichever is earlier)
unless and to the extent that such power
is renewed, revoked, or extended prior to
such date; provided that the Company
may before such expiry make an offer or
agreement which would or might require
relevant securities to be allotted after such
expiry, and the Directors may allot relevant
securities in pursuance of such an offer
or agreement as if the power conferred by
this Resolution had not expired.
Disapplication of Pre-emption Rights
At the 2022 AGM held on 24 June 2022,
the Directors were authorised to allot
equity securities (within the meaning of
section 1023(1) of the Companies Act
2014) for cash as if Section 1022(1) of the
Companies Act 2014 did not apply to any
such allotment, such power to be effective
from 24 June 2022 and shall expire at
the conclusion of the 2023 AGM or 24
September 2023 (whichever is earlier)
unless and to the extent that such power
is renewed, revoked, or extended prior to
such date; and such power being limited to:
(a) the allotment of equity securities in
connection with any offer of securities,
open for a period fixed by the Directors,
by way of rights issue, open offer or other
invitation to or in favour of the holders of
ordinary shares and/or any persons having
a right to subscribe for equity securities
in the capital of the Company (including,
without limitation, any persons entitled or
who may become entitled to acquire equity
securities under any of the Company’s
share option scheme or share incentive
plans then in force) where the equity
securities respectively attributable to the
interests of such holders are proportional
(as nearly as may reasonably be) to the
respective number of ordinary shares held
by them and subject thereto the allotment
in any case by way of placing or otherwise
of any securities not taken up in such issue
or offer to such persons as the Directors
may determine; and generally, subject to
such exclusions or other arrangements
as the Directors may deem necessary or
expedient in relation to legal or practical
problems (including dealing with any
fractional entitlements and/or arising in
respect of any overseas shareholders)
under the laws of, or the requirements of
any regulatory body or stock exchange in,
any territory;
(b) and/or the allotment of equity securities
up to a maximum aggregate nominal
value of €11,367,387, which represents
approximately 5% of the issued ordinary
share capital of the Company as at the
close of business on 20 May 2022.
The Directors were also empowered to
allot equity securities (within the meaning
of Section 1023(1) of the Companies Act
2014) for cash as if Section 1022(1) of the
Companies Act 2014 did not apply to any
such allotment, such power to be effective
from 24 June 2022 and shall expire at
the conclusion of the 2023 AGM or 24
September 2023 (whichever is earlier)
unless and to the extent that such power
is renewed, revoked, or extended prior to
such date and such power being limited to:
(a) the allotment of equity securities
up to a maximum aggregate nominal
value of €11,367,387, which represents
approximately 5% of the issued ordinary
share capital of the Company as at the
close of business on 20 May 2022; and
(b) used only for the purposes of financing
(or refinancing, if the authority is to be
used within six months after the original
transaction) a transaction which the
Directors determine to be an acquisition
or other capital investment of a kind
contemplated by the Statement of
Principles on Disapplying the Pre-Emption
Rights most recently published by the
Pre-Emption Group and in effect prior to 20
May 2022.
Market purchases of own Shares
At the 2022 AGM held on 24 June 2022
members gave the Company (and its
subsidiaries) the authority to make market
purchases and overseas market purchases
provided that the maximum number of
ordinary shares authorised to be acquired
shall not exceed:
(a) 5% above the higher of the average
of the closing prices of the Company’s
ordinary shares taken from the Euronext
Dublin Daily Official List and the average
of the closing prices of the Company’s
ordinary shares taken from the London
Stock Exchange Daily Official List in each
case for the five business days (in Dublin
and London, respectively, as the case
may be) preceding the day the purchase is
made (“the Market Purchase Appropriate
Price”), or if on any such business day
there shall be no dealing of ordinary shares
on the trading venue where the purchase
is carried out or a closing price is not
otherwise available, the Market Purchase
Appropriate Price shall be determined by
such other method as the Directors shall
determine, in their sole discretion, to be fair
and reasonable; or, if lower,
(b) the amount stipulated by Article 3(2)
of Commission Delegated Regulation (EU)
2016/1052 relating to regulatory technical
standards for the conditions applicable
to buy-backs and stabilisation (being the
value of such an ordinary share calculated
on the basis of the higher of the price
quoted for: (i) the last independent trade;
and (ii) the highest current independent
purchase bid for any number of such
ordinary shares on the trading venue(s)
where the purchase pursuant to the
authority conferred by this Resolution will
be carried out). The authority will expire
on close of business on the date of the
2023 AGM of the Company or on the 24
September 2023 (whichever is earlier)
unless previously varied, revoked or
renewed. While the Directors do not have
any current intention to exercise this power,
this authority and flexibility was sought as
it is common practice for companies on
the Official List of the Euronext Dublin and/
or London Stock Exchanges. Furthermore,
such purchases would be made only at
price levels which the Directors considered
to be in the best interests of the members
generally, after taking into account the
Company’s overall financial position. In
addition, the authority being sought from
members would provide that the minimum
price (excluding expenses) which may be
paid for such shares would be an amount
not less than the nominal value of the
shares;
(c) the amount stipulated by Article 3(2)
of Commission Delegated Regulation (EU)
2016/1052 relating to regulatory technical
standards for the conditions applicable
to buy-backs and stabilisation (being the
value of such an ordinary share calculated
on the basis of the higher of the price
quoted for: (i) the last independent trade;
and (ii) the highest current independent
purchase bid for any number of such
ordinary shares on the trading venue(s)
where the purchase pursuant to the
authority conferred will be carried out). The
authority will expire on close of business on
the date of the 2023 AGM of the Company
or on the 24 September 2023 (whichever is
earlier) unless previously varied, revoked or
renewed. While the Directors do not have
any current intention to exercise this power,
this authority and flexibility was sought as
93
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Directors’ Report
(continued)
it is common practice for companies on the
Official List of the Irish and/or London.
Re-Allot Treasury Shares
At the 2022 AGM held on 24 June 2022,
members gave the Company (and its
subsidiaries) the authority to re-allot
treasury shares pursuant to Section 1078
of the Companies Act 2014 and the re-
allotment price range at which treasury
shares may be re-allotted is as follows: (a)
the maximum price at which a treasury
share may be re-allotted off-market
shall be an amount equal to 120% of the
Treasury Share Appropriate Price; and,
(b) the minimum price at which a treasury
share may be re-allotted off-market shall
be an amount equal to 95% of the Treasury
Share Appropriate Price (provided always
that no treasury share shall be re-allotted
at a price lower than its nominal value).
This authority will expire at the conclusion
of the next annual general meeting of
the Company or at midnight (Irish Time)
on the date which is 15 months after the
passing of the resolution (whichever is
earlier), unless previously varied, revoked
or renewed.
Post Balance Sheet Events
Events after the reporting period are
described in note 48 to the financial
statements.
Accounting Records
The measures taken by the Directors to
secure compliance with the Company’s
obligation to keep adequate accounting
records are the use of appropriate systems
and procedures and the employment
of competent persons. The accounting
records are kept at the Company’s
registered office, 56-59 St Stephen’s
Green, Dublin 2.
Disclosure Notice
The Company did not receive a disclosure
notice under section 33AK of the Central
Bank Act 1942 during 2022.
Political Donations
The Directors have satisfied themselves
that there were no political contributions
during the year, which require disclosure
under the Electoral Act, 1997.
Location of Information required
pursuant to Listing Rule 6.1.77
Listing Rule
Information Included*
LR 6.1.77
(12)
LR 6.1.77
(14)
The Trustees of the
Employee Benefit Trust have
elected to waive dividend
entitlements.
As stated on page 72 the
Minister for Finance has
entered into a Relationship
Framework with the
Company. A copy of the
Relationship Framework
is available at www.
permanenttsbgroup.ie
* No information is required to be disclosed in respect
of Listing Rules 6.8.1(1), (2), (3), (4), (5), (6), (7), (8), (9),
(10), (11), and (13).
Subsidiary Undertakings
The principal subsidiary undertakings and
the Company’s interests therein are shown
in note 46 to the financial statements.
Independent Auditor
PricewaterhouseCoopers (PwC) Chartered
Accountants and Statutory Audit Firm will
resign after the completion of the 2022
audits for the Group following a period of
10 years as External Auditors. Upon PwC’s
resignation, KPMG, Chartered Accountants
and Statutory Audit Firm will be appointed
in their place and will continue in office
in accordance with Section 383(2) of the
Companies Act 2014.
Board Diversity Report
The Board Diversity Report, as set out in
the Corporate Governance Statement (see
page 120) is deemed to be incorporated
into this part of the Directors’ Report.
Non-Financial Statement
For the purposes of Statutory Instrument
360/2017 EU (Disclosure of Non-Financial
and Diversity Information by certain large
undertakings and groups) Regulations
2017, the following sections of this Annual
Report and any cross references made
in the Directors’ Report are deemed to be
incorporated into this part of the Directors’
Report:
Reporting requirements
Policies and standards which govern our approach
Risk management and additional information
Environmental matters
Environmental statement
Addressing Climate Change and
Supporting the Transition to a Low
Carbon Economy, page 25
Climate Risk, page 25
Task Force on Climate Related Financial
Disclosure (TCFD), page 26
Taxonomy Regulation, page 26
Our Carbon Footprint, page 27
Energy Usage, page 27
Waste Management, page 28
Responsible Procurement, page 30
Environmental Policy Statement, page
30
94
Permanent TSB Group Holdings plc - Annual Report 2022
Reporting requirements
Policies and standards which govern our approach
Risk management and additional information
Social and Employees
Human rights
Social matters
Anti-corruption and anti-bribery
Description of principal risks and
impact of business activity
Description of the business model
Non-financial key performance
indicators
Code of Ethics
Diversity and Inclusion Strategy
Conflicts of Interest Policy
Whistleblowing Policy and associated
procedures
Board Diversity Policy
Colleague Conduct Policy
Enhancing our Culture and Investing in
our People, page 34
Code of Ethics, page 43
Listening to Employees and acting on
feedback, page 35
Diversity and Inclusion, page 36
Health, Safety and wellbeing, page 38
Conflict of interest, Page 43
Speak Freely, page 18, 43
Board Diversity Policy, page 120
Colleague Conduct Policy, Page 43
Human Rights
Dignity and Respect Code
Equality Through Diversity Policy
Human Rights, page 43
Living Our Purpose and Ensuring Strong
Corporate Governance, page 42
Elevating our Social Impact and
Connecting with Local Communities
Anti-bribery Policy
Anti-bribery Policy Statement
Anti-money laundering and counter
terrorist financing Policy
Elevating our Social Impact and
Connecting with Local Communities,
page 30
Financial Crime Compliance, page 44
Data Protection, page 42
Responsible Conduct and Culture, page
43
Operational Risk, page 73
Speak Freely, page 18, 43
Risk Overview, pages 60
Principal Risks, pages 67
Our Strategy, page 11
Our Business Model, page 14
Non-financial Performance Indicators,
page 3
Living our Purpose and Ensuring Strong
Corporate Governance, page 42
Championing Our Customers & Creating
a Bank that is Fit for the Future, page 39
Enhancing our Culture and Investing in
our People, page 34
Elevating our Social Impact and
Connecting with Local Communities,
page 30
Addressing Climate Change and
Supporting the Transition to a Low
Carbon Economy, page 25
On behalf of the Board:
Robert Elliott
Chairman
Eamonn Crowley
Chief Executive
Nicola O’Brien
Chief Financial Officer
Conor Ryan
Company Secretary
95
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Chairman’s Introduction
Dear Shareholder,
2022 was a transformational year for Permanent TSB as we
work towards our ambition of being Ireland’s best personal
and small business bank.
2022 was another very busy period for the
Board who met on a total of 26 occasions.
This level of Board activity was primarily
driven by the Ulster Bank transaction
together with ongoing focus by the
Board on change within the organisation,
particularly in the area of technology,
workforce strategy, customer service and
planning for growth.
As announced in 2022, I will step down
from the Board at the end of March 2023
having completed my six year-term of
office and it is very pleasing to see how
the Bank is now well positioned to achieve
sustainable growth over the years ahead
having executed principal completion of the
Ulster Bank transaction in November 2022.
This has been a milestone achievement for
the Bank realised through the hard work
and dedication of many colleagues within
the Bank and overseen by the Board. In
2021 the Board established a committee
of the Board (Board Sun Committee)
to provide support and guidance to the
Board on the process to agree and execute
the commercial and legal terms for the
Ulster Bank transaction. This committee
remained constituted during 2022 and will
continue into 2023 as the Bank completes
the Ulster Bank transaction.
During 2022 the culture of the Bank
continued to evolve centred on our purpose
“to work hard every day to build trust with
customers – we are a community serving
the community”. I am very pleased with
the work the Board Nomination, Culture
and Ethics Committee has carried out in
this regard with key focus on diversity and
inclusion, culture, colleague wellbeing,
sustainability and the reputation of the
Bank. Indeed culture was a key focus
for the Board in terms of a successful
integration of our new colleagues from
Ulster Bank.
Change continued to be a key focus for
the Board during the year. It was a priority
for the Board that, notwithstanding the
importance placed on the Ulster Bank
transaction, both strategic and operational
change could be managed in a manner
that minimised risk to the organisation and
without impacting ongoing business as
usual operations that were necessary to
96
support customers in terms of service and
safety. During the year, the Board focussed
considerable time on strengthening the
Bank’s change management processes,
the continued embedding of risk
awareness within change management
programmes and ensuring the Bank had
capacity to deliver on its ambitions. The
Board ensured that resource allocation
(capital, people, technology) was rigorously
prioritised to deliver strategic change
projects safely and on time. All of this
was achieved through the continued
embedding of a risk aware system of
governance that responds to the needs of
the Bank’s stakeholders, while upholding
the standards expected of a retail credit
institution.
The Board is aware that it needs to have
the collective knowledge, experience
and skills in order to provide effective
governance oversight for the Bank.
Therefore, succession planning and
Board refreshment is both an active and
well defined process. During 2022 and
early 2023, the Board appointed Nicola
O’Brien and Julie O’Neill, as Directors and
undertook a complete review of Board
Committee composition. The Board also
approved a new Board Diversity Policy
which sets gender balance (50/50) on the
Board as a committed target in addition
to other key metrics as set out in the
Board Diversity Report on page 120. All
of these changes were made to ensure
the knowledge, experience, skills and
diversity of the Board and its committees
were maximised to deliver on the Bank’s
strategic ambitions. Indeed, to ensure an
orderly succession for my own position
as Chairman, the Board commenced a
process to identify my own replacement
a little over a year ago. Indeed, I am
very pleased with the appointment of
my successor Julie O’Neill. Julie is an
accomplished business leader with
extensive executive and board experience
which will be invaluable as we further
transform and grow the Bank.
2022 was also a year where preparations
continued for the introduction of the
Individual Accountability Framework. The
Board will continue to provide oversight
on this important piece of governance
legislation to ensure any enhancements
required to the Bank’s governance
processes are effectively implemented in
good time.
The purpose of this short introduction is
to provide assurance to stakeholders that
the Board has an engaging and committed
approach to corporate governance and,
while respecting executive responsibility,
has an active role in all key decisions that
are made.
The following report sets out the detail
of our approach to corporate governance
principles and practices, how we
implement and endeavour to achieve
compliance with the UK Corporate
Governance Code and how our Board and
its Committees operated during the year.
The reports from the Chairs of the Board
Audit, Risk and Compliance, Nomination
Culture and Ethics, and Remuneration
Committees on pages 125, 133, 130 and
136 respectively highlight the key activities
and areas of focus for each Committee.
Robert Elliott
Chairman
CBI Corporate Governance Code
The 2015 Central Bank of Ireland Corporate
Governance Requirements for Credit
Institutions (the “CBI Code”) imposes
statutory minimum core standards
upon credit institutions, with additional
requirements upon entities designated as
High Impact Institutions. The Company’s
retail banking subsidiary, PTSB, was
subject to the provisions of the CBI Code
during the reporting period. PTSB has
been designated as a High Impact Credit
Institution under the CBI Code and is
subject to the additional obligations set
out in Appendix 1 of the CBI Code. PTSB
has also been designated as LSI for the
purposes of the Capital Requirements
Directive (SI 158/2014) and is subject to the
additional obligations set out in Appendix
2 to the CBI Code. A copy of the CBI Code
is available on the CBI’s website www.
centralbank.ie.
Permanent TSB Group Holdings plc - Annual Report 2022 Compliance Statement with UK
Corporate Governance Code and Irish
Annex
The Company’s shares are admitted to
trading on the Main Securities Market of
Euronext Dublin and the London Stock
Exchange and the Company must comply
or explain against the provisions of the
2018 UK Corporate Governance Code
(the “UK Code”) and the Irish Corporate
Governance Annex (the “Irish Annex”). A
copy of the UK Code is available on the
UK Financial Reporting Council’s website
www.frc.org.uk and the Irish Annex is
available at www.euronext.com/en/
markets/dublin.
Details of how the Group applied the main
principles and supporting provisions of
the UK Code are set out in this Corporate
Governance Statement, the Business
Model and Strategy section, the Risk
Management section and in the Directors’
Report on Remuneration. These also
cover the disclosure requirements set
out in the Irish Annex, which supplement
the requirements of the UK Code with
additional Corporate Governance
provisions. The Board confirms that the
Company has complied with the detailed
provisions of the UK Code and Irish Annex
during 2022, save as set out in the following
paragraphs.
Director and Committee Independence
Provision 24 and 25 of the UK Code
requires both the audit and risk committee
(where established) to consist of
Independent Non-Executive Directors.
Marian Corcoran is a member of the
Board Risk Committee and Paul Doddrell
is a member of both the Board Risk and
Audit Committee. Paul Doddrell and
Marian Corcoran were nominated to
the Board by the Minister for Finance of
Ireland under the terms of a Shareholder
Relationship Agreement and, as a result
are not considered independent under
the code. Each of the aforementioned
committees is chaired by and has a
majority of independent non-executive
directors within their membership. The
Board believes it appropriate to ensure that
the aforementioned committees consist
of members with appropriate knowledge,
experience and skills and, notwithstanding
the basis of their appointment, can
demonstrate effective contribution through
an independent mind-set. The Board
believes it is in the best interest of the Bank
to utilise Mr Doddrell’s and Ms Corcoran’s
considerable risk management experience
on the Board Risk and Compliance
Committee (see below for the Board’s
position on Mr Doddrell as a member of the
Board Audit Committee.
As part of the Board’s succession planning
activities, preliminary plans had been
agreed for Andrew Power and Ken Slattery
to step down from the Board at the 2023
AGM having completed their respective
six and nine year terms of office. A
process to identify a candidate to replace
the knowledge and experience vacated
by Andrew Power remains ongoing with
an expectation of an appointment in the
second half of 2023. Mr Power will step
down from the Board at the 2023 AGM.
The appointment process to identify and
appoint a replacement for Ken Slattery
(with knowledge and experience in retail
and SME banking) was more advanced
with a preferred candidate identified and
due to commence a regulatory assessment
process. Sadly, the intended appointee
for this role passed away unexpectedly
in January 2023 and the Board has now
re-started a process to identify a new
candidate.
The Board had planned for the intended
appointee to replace Paul Doddrell on the
Board Audit Committee. As previously
referenced, Mr Doddrell does not meet the
independence criteria under provision 10
of the UK Code having been nominated to
the Board by the Minister for Finance of
Ireland. The Board had previously stated
how Mr Doddrell’s knowledge, experience
and independent mindset has been of
material benefit to the Audit Committee.
However, the Board acknowledges the
voting patterns at the 2022 AGM which
provide guidance that a proportion of
the Company’s shareholders would
prefer the Board to adhere strictly to the
independence requirements for the Board
Audit committee under provision 24 of the
UK Code (all committee members to be
independent). The Board acknowledges
this guidance but as an interim measure
and to maintain membership levels above
minimum quorum requirements (with
Andrew Power stepping down at the AGM)
have agreed Mr Doddrell should remain
on the Audit Committee until the end of
2023 to allow time to appoint Mr Slattery’s
replacement at which point Mr Doddrell’s
responsibilities will transfer to another
Board committee.
The Directors have requested, and Ken
Slattery has agreed, to remain on the
Board until the end of 2023 to allow time
for the identification and appointment
of his replacement. Mr Slattery will have
served just over 10 years in office when he
steps down from the Board at the end of
2023. In recommending this extension, the
Board undertook a rigorous review of Mr
Slattery’s performance and interests and is
satisfied he continues to be independent.
As part of the appointment process for
Julie O’Neill, the Board undertook a rigorous
assessment of her independence. The
Board is satisfied Ms O’Neill meets the
independence criteria under the UK Code
and will remain independent upon her
appointment as Chairperson on the 31 March
2023. Ms O’Neill served as an independent
non-executive director of the Company
from 2014 to 2020. In assessing Ms O’Neill’s
independence, the Board took account of the
fact that Ms O’Neill had previously served
six years as an independent non-executive
director (less than the nine year threshold set
out in the UK Code) and was the Board’s senior
independent director when she stepped down
from the Board.
Remuneration
Provision 33 of the UK Code requires that
the Remuneration Committee shall have
delegated responsibility for setting the
remuneration for all executive directors
and the chairman. However, under EBA
guidelines on sound remuneration practices,
the Remuneration Committee is designated
as being responsible for the preparation of
decisions to be taken by the Board regarding
the remuneration for executive directors and
other identified staff. The Board’s view is that,
from a regulatory perspective, the Group is
compelled to comply with the EBA guidelines
and therefore its Remuneration policy reflects
this position.
Provision 38 of the UK Code requires that
the pension contribution rates for executive
directors, or payments in lieu, should be
aligned with those available to the workforce.
Since 2019, the Board has approved certain
enhancements to staff defined contribution
pension schemes where, based on market
benchmarking, the maximum employer
contributions were increased up to 16%
linked to increases in each employee’s own
contributions and subject to certain age-
based eligibility criteria. In carrying out these
reviews, the Remuneration Committee
paid due cognisance to existing State
Agreements relating to remuneration and
the Group’s ability to provide competitive
reward arrangements to retain and motivate
executive talent in an increasingly competitive
marketplace. Given the particular challenges
faced in attracting and recruiting the most
senior talent, it is now proposed to increase
the Executive Directors maximum pension
contribution to 16%, or 20% in the case of
the CEO. Given the difficulties experienced
in respect of senior talent acquisition,
and aligned with the current approach for
members of the Bank’s Executive Committee,
it is also proposed to exempt the Executive
Directors from the age-related eligibility
criteria.
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Stakeholder Engagement
“How the Board ensures
effective engagement with,
and encourages participation
from the Company’s
Stakeholders”
Stakeholder Engagement
A key role of the Nomination, Culture
and Ethics Committee is to ensure
there is effective engagement with
and participation from the Bank’s key
stakeholders. Reputation management
is an integral part of the corporate affairs
strategy for the Bank.
Sustainability Materiality
Assessment
The Bank takes a number of factors into
consideration when assessing where to
prioritise resources for its sustainability
activity. These include, but are not limited
to: the Bank’s business model and strategy;
principal risks; sector issues; public policy
and regulation; and, the impact of the
Bank’s activities on wider society.
To understand the issues that are
important to stakeholders, in 2021 the
Bank engaged a sample of stakeholders
to complete a comprehensive Materiality
Assessment of the Bank’s Sustainability
programming.
The assessment offered insight into
the relative importance of specific
Environmental, Social and Governance
(ESG) issues relevant to conducting
business in a responsible way, and assisted
the Bank in building out a Sustainability
Strategy which was launched in November
2021. Central to the Bank’s Sustainability
Strategy is a focus on climate change and
supporting the transition to a low carbon
economy.
Reference to the Bank’s stakeholders
includes the Bank’s customers (personal
and small business), colleagues (Board,
management, employees and unions),
the Bank’s investors, suppliers, society
(community partners and industry
influencers) and the Bank’s regulators.
Outside of the materiality exercise, the
Bank interacts with stakeholders at regular
intervals during the year through the
following:
• Customers – Voice of the Customer
Programme, focus groups, surveys, in
person through the branch network
and through the Bank’s online digital
channels (website, App, customer
contact centres etc.);
• Colleagues – Every Voice Counts
employee engagement survey, regular
micro-pulse surveys, team meetings,
virtual and in person networking
forums, internal intranet platform, a
Bank-wide communications platform
and app, in-house digital screens, four
Employee Resources Groups, People
Experience Council and other channels
as appropriate;
•
Investors – AGM and shareholder
services, financial reporting, roadshows,
industry conferences and other channels
as appropriate;
• Suppliers – Regular supplier engagement
processes and procedures, supplier
on boarding and contracting and other
channels as appropriate;
• Society – Community Partners, Media,
Government Officials and industry
influencers such as the BPFI and Irish
Banking Culture Board; and
• Regulators – Regular engagement and
regulatory reporting and other channels
as appropriate.
Focus for 2023
The Bank’s focus for 2023 will be to build
on the progress achieved and to continue to
rollout a series of proactive engagements
amongst its key stakeholders that will allow
the Bank to cultivate relationships, gain
trust and build further the reputation of the
Bank. The Bank’s Corporate Development
and HR Function will continue to ensure
that feedback from colleagues, customers
and communities is measured effectively
in line with the Bank’s Purpose and that
key insights are brought to the Nomination,
Culture and Ethics Committee on a regular
basis.
Shareholder Engagement
In addition to this, the Bank has a dedicated
Investor Relations team, headed by the
CFO. The Bank will continue to have an
active market engagement programme in
place where it reports financial results live
through a webcast twice a year typically
in March/July and updates the market on
trading twice a year typically in May and
November. The Bank publishes all results,
including the webcasts, on its website.
The Bank also reports other relevant
information to the market on a timely basis.
The Investor Relations team, together
with the CEO and the CFO, will continue to
provide regular updates to the Board on the
types of activities mentioned above, along
with market reactions in order to ensure
that the members of the Board continue to
develop an understanding of the views of
major shareholders.
Workforce Engagement
The UK Corporate Governance Code
places an obligation on boards to keep
workforce engagement mechanisms
under review so that they remain effective.
Furthermore, the Code also states that
where the Board chooses to implement
alternative arrangements to those set out
in the Code, it should explain in its Annual
Report what alternative arrangements
are in place and why it considers that they
are effective. During 2021 and 2022, while
COVID-19 impacted on the capability of
the Board to engage with employees in
a face to face manner, the utilisation of
electronic communication facilitated this
engagement.
There are currently a number of ways
the Board engages with the Group’s
workforce and hears the employee ‘Voice’
on an on-going basis through alternative
arrangements to those set out in the
UK Code. A summary of these alternate
arrangements are outlined in the below
table:
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Permanent TSB Group Holdings plc - Annual Report 2022 Mechanism
Detail
Board and
Committee
Meetings
During 2022 the Board met in total on 26 occasions and this
facilitated regular Board engagement with subject matter
experts from across the Bank. The Board also visited off-
site locations such as the Bank's technology centre in Cork
and scheduled visits were arranged throughout the year for
directors to visit the Bank's branches and call centres for the
purposes of engagement with Bank colleagues on the ground.
Nomination,
Culture and Ethics
Committee
Dedicated Board Committee with accountability for culture,
behaviour, ethics and reputation management oversight in the
Bank.
Biannual review of employee ‘Speak Freely’ concerns raised
through a Colleague Conduct Report.
Employee Events
Attendance at and participation in employee events on an
on-going basis.
Employee
Representative
Bodies
Examples include the Employee Resource Group initiatives
such as the Heritage launch, Better Balance Webinars, Values
in Practice Awards and Sustainability events.
CEO and CHRO and Corporate Development Director bi-
annual engagements with Employee Representative Bodies
to update them on the organisational trading position, the
Bank’s purpose and strategy together with opportunities and
challenges being faced.
Employee Surveys
The Employee collective voice is shared with the Board
Nomination, Culture and Ethics through a variety of employee
surveys that are run.
Examples include the Every Voice Counts Annual Survey and
Every Voice Counts Micro-pulse, Irish Banking Culture Board
(Éist).
Employee
Engagement
Group
The Company Secretary (Board Nominee) attends the People
Experience Council (PEC) to support the Board and gain a
greater understanding of culture / employee sentiment.
Nomination Culture and Ethics Committee met with the
Bank’s People Experience Council incorporating two formal
engagements with the Council in 2022.
As noted in the table above a People
Experience Council was incepted in 2020
to support the embedding of Culture with
a mandate and a set of accountabilities.
Their role is to lead out on culture across
the Bank, provide a collective voice
(qualitative data) to the organisation and
solicit People Experience Leads across
their functions to champion organisational
engagements. Leads are made up of
colleagues from all areas of the business,
representing a diverse group of employees
at all levels. The Nomination Culture and
Ethics committee identified an opportunity
for the Board to engage with this group and
to be updated on the employee sentiment
and mood on the ground. As part of this
group, the Board not only gains a deeper
understanding of the drivers behind the
employee engagement survey results
(Every Voice Counts, Éist), they also gain
diverse perspectives on what actions will
address the areas for development and
also any emerging areas of discontent from
employees. It is intended that periodic
attendance by Non-Executive Directors will
occur again in 2023.
All material organisational changes are
discussed and consulted on in advance
with employee representative bodies.
It is important in the context of these
discussions that colleagues understand
and can provide feedback on the financial
and strategic position of the Bank over
its 5 year planning period. During 2022,
the CEO attended engagement sessions
with Employee representative bodies to
explain and provide context to the Bank’s
current and medium term outlook as part
of negotiations on reward.
Having reviewed the series of employee
engagement during 2022, the Nomination,
Culture and Ethics Committee was
satisfied that this engagement was
effective and in compliance with the UK
Code.
Board Decision Making
The Board has a clear understanding of
the Bank’s key stakeholders and how
the operations of the Bank effect the
environment and communities in which
it operates. The Bank’s Stakeholder
Engagement Programmes facilitate a
clear and unfettered information flow
to and from the Board. This allows the
Board to make informed decisions that are
both in the best interest of the Company
and facilitate a clear understanding of
how decisions impact on the Bank’s
stakeholders, wider community and
environment.
A key focus for the Nomination Culture
and Ethics Committee is to ensure that
directors are able to make a positive
contribution to the long term sustainable
success of the Company. Directors are
more likely to make good decisions
and maximise the opportunities for the
Company’s success if the right skillsets
and breadth of perspectives are present
on the Board. The Nomination Culture
and Ethics Committee, aligned with the
Bank’s Purpose and Ambition, considers
the appropriate skillsets and perspectives
and sets them out in a Board approved
Suitability Matrix. Appointments to the
Board are recommended in accordance
with the Suitability Matrix. The key skillsets
and experience that each of the Directors
bring to the Board are set out in the Board
Biographies section.
Directors’ Report
The Directors’ Report and the Statement of
Directors’ Responsibilities forms part of the
Corporate Governance Statement.
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Board of Directors
A key focus for the Nomination Culture and Ethics Committee is to ensure that directors are able to make a positive contribution to the
long term sustainable success of the Company. Directors are more likely to make good decisions and maximise the opportunities for
the Company’s success if the right skillsets and breadth of perspectives are present on the Board. The Nomination Culture and Ethics
Committee, aligned with the Group’s Purpose and Ambition, considers the optimal knowledge, experience and skills requirements of the
Board and sets them out in a Board approved Suitability Matrix. Appointments to the Board are guided by the Board Assessment and
Suitability Policy, Board Diversity Policy and Board Suitability Matrix. The key knowledge and experience that each of the Directors bring
to the Board are set out in the Biographies below.
ROBERT ELLIOTT (70)
CHAIRMAN
INDEPENDENT ON
APPOINTMENT
Appointed Chairman:
31 March 2017
Nationality:
British
Committee Membership:
Nomination, Culture and Ethics
Committee (Chair)
Remuneration Committee
Principal External Appointments:
Chairman of Windship Technology
Ltd and Director of Royal Yacht
Squadron Racing Limited
EAMONN CROWLEY
(53)
CHIEF EXECUTIVE OFFICER
Appointed to Board:
10 May 2017
Nationality:
Irish
Committee Membership:
Principal External Appointments:
President of the Banking and
Payments Federation Ireland
(BPFI) and President Institute of
Bankers in Ireland.
Key Strengths, Skills and Experience
The breadth of Robert’s knowledge and experience of
advising corporates on strategy and governance, building
teams and driving culture, enables Robert to contribute to
the strategic, cultural evolution and long-term sustainable
success of the Group. Robert also has extensive legal, banking
and leadership experience and a track record of championing
greater inclusiveness and diversity.
Robert is an experienced Chairman and Lawyer, having
advised on major UK and international banking and
restructuring projects. Robert is a former Chairman and
Senior Partner of Linklaters LLP, the global law firm with a
partnership of 490 members and approximately 5,500 staff.
In his role as the firm’s ambassador, he also contributed
widely to industry and City organisations, think tanks and
community-led initiatives. Robert previously chaired the
Nomination and Governance Committee for the TheCityUK an
industry-led body which represented UK-based financial and
related professional services.
Key Strengths, Skills and Experience
Eamonn brings to the Board extensive international banking,
accounting, corporate treasury and leadership experience
with a significant customer focus which is reflected in the
Bank’s Purpose, Ambition and Strategy to build trust and grow
a sustainable Bank for the longer-term.
Eamonn was appointed CEO in June 2020. Before joining
PTSB as Chief Financial Officer in 2017, Eamonn worked
as Chief Financial Officer at Bank Zachodni WBK S.A. (“BZ
WBK”), Banco Santander’s publicly listed Polish retail and
commercial bank. (BZ WBK was formerly 70% owned by AIB.
Banco Santander acquired that AIB stake in 2010.) During
his period as CFO, Eamonn executed the merger of BZ WBK
with Kredyt Bank to form Poland’s number three bank,
placed over 20% of the bank on the Warsaw Stock Exchange
through a Euro 1.2bn secondary IPO and led the acquisition of
a controlling stake in Poland’s number one Consumer Bank.
Prior to joining Santander, Eamonn worked for the AIB Group
in a variety of different roles.
• MBA Smurfit Business School
• Certified Accountant (FCCA) and Member of Association of
Corporate Treasurers
100
Permanent TSB Group Holdings plc - Annual Report 2022 NICOLA O’BRIEN (52)
CHIEF FINANCIAL OFFICER
Appointed to Board:
4 August 2022
Nationality:
Irish
Committee Membership:
None
Principal External Appointments:
Director of First Home Scheme
Ireland DAC (on behalf of PTSB)
Julie O’Neill (67)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
17 January 2023
Nationality:
Irish
Committee Membership:
Remuneration Committee,
Nomination, Culture and Ethics
Committee
Principal External Appointments:
Chairperson of the Convention
Centre Dublin, Director at XL
Insurance Company SE and AXA
Life Europe
Key Strengths, Skills and Experience
Nicola is a qualified Accountant (ACMA) with over 20
years’ experience operating at a senior level within the
Retail Banking sector in Ireland. Nicola brings a strong
understanding of the commercial, strategic, operational,
financial and regulatory requirements of Banking.
Nicola joined the Bank in 2017 and has a depth of experience
in the Commercial and Retail banking sectors. Prior to
joining the Bank, Nicola held a number of senior roles in
Bank of Ireland, including: Head of Finance Group Customer
Operations; Head of Group Finance Strategy and Divisional
Financial Controller for the Retail Ireland division.
• ACMA & CGMA
Key Strengths, Skills and Experience
Julie is an accomplished business leader with extensive
executive and board experience, having held a number of
senior government positions, including Secretary General
of both the Department of Transport and the Department
of Marine and Natural Resources and holds/held a number
of other prominent Non-Executive Director roles, including:
Chairperson of the Convention Centre Dublin, Non-Executive
Director at XL Insurance Company SE, AXA Life Europe and
previously Ryanair Group plc.
Note, a number of Julie's current appointments will cease shortly
before or just after her appointment as Board Chairperson on
the 31 March 2023 (given the additional time demands of the
Chairperson role).
Julie previously served a six-year term on the Permanent TSB
Group Holdings plc Board (2014 to 2020) as an Independent
Non-Executive Director, the latter 4 years as the Board’s
Senior Independent Director. During this period she played
a significant role as a Board member in guiding positive
transformation of the Bank. Julie’s has extensive business and
leadership experience and will bring an in-depth knowledge of the
Bank and wider banking /insurance industry to the Board.
• Certified Bank Director
• Batchelor of Commerce
• MSc Policy Analysis
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Board of Directors (continued)
RONAN O’NEILL (69)
SENIOR INDEPENDENT
NON-EXECUTIVE
DIRECTOR
Appointed to Board:
26 July 2016
Nationality:
Irish
Committee Membership:
Audit Committee (Chair)
Nomination, Culture and Ethics
Committee
Principal External Appointments:
None
RUTH WANDHÖFER,
(47)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30 October 2018
Nationality:
German
Committee Membership:
Risk and Compliance Committee
Remuneration Committee
Principal External Appointments:
Director at: RTGS Global Ltd;
Gresham Technologies plc; Aquis
Exchange Plc; and Leximar Ltd
(personal consultancy company).
Key Strengths, Skills and Experience
Ronan, a chartered accountant, brings to the Board extensive
banking and leadership experience with a particular
competency in finance, risk and treasury. His strong strategic
and corporate development insights enable Ronan to provide
challenge and support to the development of the Bank’s
organisational change programmes. His previous experience
as a member of the Group Risk Committee at AIB is of
particular benefit to the Board Audit Committee which Ronan
chairs.
Prior to retiring from AIB in 2013, Ronan was Chief Executive
Officer of AIB (UK) plc and a member of the AIB Group
Leadership Team. Ronan had responsibility for SME Business
in the UK and the retail banking business of First Trust in
Northern Ireland. He put in place a strategic plan to revitalise
AIB’s UK and NI businesses and oversaw its implementation.
• Fellow Chartered Accountants Ireland
• Certified Bank Director
• Bachelor of Commerce from UCD
• Fellow, Institute of Bankers
Key Strengths, Skills and Experience
Ruth has substantial banking and leadership experience
with extensive knowledge of both regulatory and market
strategy, and together with her insight on regulatory and
financial technology innovation provides invaluable insight
for the Board as it provides oversight for the Group’s digital
transformation development.
Ruth was Head of Regulatory and Market Strategy at Citi
from 2007 to 2018 where she drove regulatory and industry
dialogue in addition to developing product/market strategy
in line with the evolving regulatory and innovation landscape.
Prior to joining Citi, Ruth was Policy Advisor for Securities
Services and Payments at the European Banking Federation.
• MA in Financial Economics (UK)
• MA in International Politics (FR)
• LLM in International Economic Law (UK)
• PhD Finance
• Certified Bank Director
102
Permanent TSB Group Holdings plc - Annual Report 2022 MARIAN CORCORAN,
(58)
NON-EXECUTIVE
DIRECTOR
Appointed to Board:
24 September 2019
Nationality:
Irish
Committee Membership:
Risk and Compliance Committee
Nominations, Culture and Ethics
Committee
Principal External Appointments:
Director of IDA Ireland, Member
of DCU Governing Authority, and
Director of MC2 Change Limited
(personal consultancy company)
DONAL COURTNEY (58)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
3 October 2018
Nationality:
Irish
Committee Membership:
Audit Committee
Risk and Compliance Committee
(Chair)
Principal External Appointments:
Director at Iput plc, Special
Olympics Ireland and NBC Global
Finance Limited.
Key Strengths, Skills and Experience
Marian has broad experience in technology and business
transformation, executive leadership and strategy
development. Marian brings to the Board wide-ranging
experience in advising and leading transformational
programmes in multiple industries including banking. Marian’s
experience of risk management brings invaluable experience
to the Board Risk and Compliance Committee. Marian’s
cross-industry skills in stakeholder management, risk
management, corporate governance and technology-enabled
transformation benefits the Board as the Group’s strategy
and change programmes evolves at an ever increasing pace.
Marian has a strong track record in championing inclusion and
diversity.
Marian is an experienced non-executive director and a former
executive director and partner in Accenture Ireland. Marian
has extensive experience in strategy delivery, delivery of
technology-enabled change and business transformation
both locally and internationally. During her career in
Accenture Ireland she operated in a number of key senior
executive positions including as Executive Director on the
Board. Marian serves on the Board of IDA Ireland, is a member
of the Governing Authority at DCU and was also a member of
the Irish Public Service Pay Commission.
• Chartered Director
• Certified Bank Director
• Professional Certificate in Leadership Coaching
• BSc Biotechnology
Key Strengths, Skills and Experience
Donal is highly experienced finance, accounting and risk
professional across leasing, lending and property financing
with a particular competence in financial reporting,
governance and internal controls. Donal brings to the Board
experience in asset financing and funding vehicle structures
such as collateralised loans and securitisations. Donal has
extensive risk and audit experience holding audit and risk
committee chair positions at Dell Bank International, IPUT plc
and formerly at Unicredit Bank Ireland plc.
Donal is a former SVP and CFO at Capmark Bank Europe, a
licensed real estate financing bank with operations in UK,
France and Germany. Prior to this, Donal held Executive
Director roles with the Irish operations of Orix Corporation,
Airbus Industrie and GMAC Commercial Mortgage where he
gained extensive experience in the aircraft leasing, financing
and commercial property sectors. Donal is a qualified
Chartered Accountant and started his career with Arthur
Andersen where he went on to become a practice manager
in its financial services division working with a broad range of
clients across the leasing and banking industries.
• Fellow of Chartered Accountants Ireland
• BBS Trinity College, Dublin
• Certified Bank Director
• Accredited Funds Professional, Institute of Bankers
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Board of Directors (continued)
PAUL DODDRELL (54)
NON-EXECUTIVE
DIRECTOR
Appointed to Board:
26 November 2020
Nationality:
British
Committee Membership:
Audit Committee
Risk & Compliance Committee
Principal External Appointments:
Director at Cabot Financial
Ireland Ltd, Coastline Housing
Limited and 3 to 48 Ltd (personal
consultancy company)
CELINE FITZGERALD
(60)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30th March 2021
Nationality:
Irish
Committee Membership:
Nominations, Culture and Ethics
Committee
Remuneration Committee
Principal External Appointments:
Director at: VHI Health And
Wellbeing DAC; VHI Health And
Wellbeing Holdings DAC; and;
Chair, Pieta House CLG.
Key Strengths, Skills and Experience
Paul has significant executive leadership experience
spanning finance, asset servicing, lending, operations, sales
with specific management expertise in business strategy
development and execution; risk management and change
management. Paul’s strategic insights and experience
particularly in the area of mortgage servicing and credit
provide core skills which the Board requires.
Paul is a highly experienced financial services executive and
Board member who has successfully operated at executive
management level in a number of organisations globally.
Paul served as Pepper Group’s Managing Director for Shared
Services, and led the successful establishment and growth of
Pepper’s financial services operations in Ireland. Previously
Paul held a number of key executive roles at GE Capital. Paul
is currently a Non-executive Director and chair of the Audit
and Risk committees at Cabot Financial Ireland.
• Chartered Management Accountant – ACMA, CGMA
• Certified Six Sigma Master
• BA(Hons) Business Studies
• Certified Bank Director
Key Strengths, Skills and Experience
Celine is a former Non-Executive Director at the commercial
semi-state company Ervia and has previous senior executive
experience in the telecommunications (senior executive at
Vodafone 1999 – 2007) and the managed services (CEO of
Rigney Dolphin 2007 - 2012) industries. Celine was a Non-
Executive Director on the VHI Main Board between 2010 and
2020 and was General Manager at the charity Goal between
2016 and 2018. Celine has also contributed her time to many
other charitable foundations and is the current Chair of the
charity Pieta House.
Celine is an experienced senior executive and Independent
Non-Executive Director and has led culture transformation
in challenging environments. Celine has had practical
experience of handling ethical challenges in the charity sector
during her time as Managing Director of Goal. Celine has an
in-depth understanding of strategic differentiation to deliver
customer value. Celine’s knowledge and experience will be of
significant benefit for the Board in its role to lead on evolving
an open ethical, risk aware and inclusive culture which is
focussed on building trust with customers, colleagues and
communities.
• BA Management
• Chartered Director
104
Permanent TSB Group Holdings plc - Annual Report 2022 ANNE BRADLEY (63)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30th March 2021
Nationality:
Irish
Committee Membership:
Audit Committee
Risk and Compliance Committee
Principal External Appointments:
Director at Northern Trust
International Fund Administration
Services Ireland Ltd and
Pieta House CLG.
KEN SLATTERY (74)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30 August 2013
Nationality:
Irish
Committee Membership:
Nomination, Culture and Ethics
Committee
Remuneration Committee (Chair)
Principal External Appointments:
Director of Home Building Finance
Ireland, Home Building Finance
Ireland (Lending) DAC, National
Shared Services Office and The
Glencree Centre for Reconciliation
CLG
Key Strengths, Skills and Experience
Anne’s experience is centred on transformation and business
change and her cross industry knowledge and experience will
support the Board as the Group continues to implement its
digital transformation strategy while maintaining resilient and
reliable IT systems.
Anne’s has extensive experience in technology and has
operated at senior levels, leading on IT resilience, emergency
response, technology evaluation, crisis management,
operational efficiency and IT infrastructure.
Anne worked with Aer Lingus/IAG Group until 2020 where,
during a 40 year career she held a number of senior executive
roles. Between 2015 and 2018 she was Director of IT with
Aer Lingus and thereafter Head of Group IT Delivery/Digital
Development (2018 -2020) with IAG Group. Anne was an
Independent Non-Executive Director at Bus Eireann from
2015 to 2018 and more recently joined the Board of Northern
Trust International Fund Administration Services Ireland Ltd.
• Fellow of the BCS The Chartered Institute for IT
• Chartered Director Certified Bank Director
• Certified Bank Director
Key Strengths, Skills and Experience
Ken has wide-ranging experience of the Irish Financial
Services landscape and his retail banking experience
complements the key markets in which the Bank operates.
Ken has a deep understanding of the legal and regulatory
environment for Irish Banks and his previous role at MABS
provides the Board with the customer advocacy skills in order
to fulfil PTSB’s purpose to build trust and grow a responsible
and sustainable business. Ken also has significant experience
serving as chair and member of various Board Committees
which is of particular benefit as Chair of the Board
Remuneration Committee and is well versed in the challenges
of ensuring employee talent is both attracted to and retained
by the Group.
Ken is an experienced banker having retired from Bank
of Ireland in 2006 following a career spanning 40 years in
Corporate, Commercial and Retail banking. Ken has held
non-executive director positions with a number of Irish and
Northern Ireland government departments, including chair
positions on audit and risk committees. He is also a former
director of MABS and Realex Financial Services where he was
chair of the Company’s audit and risk committees until 2013.
• Fellow, Institute of Bankers
• Certified Bank Director
105
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Board of Directors (continued)
ANDREW POWER (66)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
26 September 2016
Nationality:
British
Committee Membership:
Audit Committee
Remuneration Committee
Principal External Appointments:
Director at A.M. Best Europe
- Rating Services Limited and
Andrew Power Consultancy
Limited (personal consultancy
company).
Key Strengths, Skills and Experience
Andrew has wide-ranging experience as industry subject
matter expert across banking, insurance, wealth management
and investment management. Andrew’s extensive retail
financial services experience particularly around strategy
development, operational model transformation and process
improvement is a major benefit to the Board’s collective
skillset.
Andrew is a former partner in the Consulting arm of Deloitte
UK, where he specialised in providing strategic advice. Andrew
has advised many of the world’s major financial services
companies and has significant know-how of major financial
markets and the regulatory landscape around the globe.
• MBA Harvard Business School
• MA Economics
• Certified Bank Director
CONOR RYAN,
COMPANY SECRETARY
Conor joined the Group in 1989 and was appointed Company Secretary in 2017. As Company
Secretary and Head of Corporate Governance, Conor is responsible for advising the Board, through
the Chairman, on all governance matters. The role of Company Secretary is to align the interests
of different parties around the boardroom table, facilitate dialogue, gather and assimilate relevant
information, and support effective decision-making. Conor is a fellow of ICSA: The Governance
Institute and was President of the Institute in Ireland from 2014 to 2016.
2022 Board Meeting Attendance and Directorships
Member
Appointed
Ceased
Number of Years on
Board
2022 meetings
Number of
Directorships held
Non-Executive Directors
Robert Elliott
Ken Slattery
Paul Doddrell
Ronan O’Neill
Andrew Power
Donal Courtney
Ruth Wandhöfer
Marian Corcoran
Anne Bradley
Celine Fitzgerald
Executive Directors
Eamonn Crowley
Nicola O’Brien
Mike Frawley
31 Mar 2017
30 Aug 2013
26 Nov 2020
26 Jul 2016
26 Sep 2016
03 Oct 2018
30 Oct 2018
24 Sep 2019
30 Mar 2021
30 Mar 2021
-
-
-
-
-
-
-
-
-
-
10 May 2017
04 Aug 2022
29 Oct 2019
-
-
31 Mar 2022
5.9
9.4
2.1
6.5
6.3
4.3
4.2
3.3
1.8
1.8
5.7
0.4
2.2
25/26
25/26
26/26
26/26
21/26
23/26
25/26
26/26
26/26
25/26
26/26
11/13
5/5
4/2
6/3
7/2
2/1
6/2
6/3
8/4
5/2
4/2
5/2
9/1
4/2
2/1
Notes:
PTSB is the sole direct subsidiary of PTSBGH. During 2022, the composition of the Boards of PTSBGH and PTSB were identical. Meetings of the Boards of PTSB and PTSBGH
run concurrently. Concurrent Board meetings or consecutive Board meetings of PTSB or PTSBGH held on the same day are counted as a single attendance above.
Number of Directorships: the first number stated is the total number of directorships held and the second number is the number of directorships as counted under Article 91(3)
and (4) of Directive 2013/36/EU (for the purposes of calculating these directorships, multiple directorships within a group are counted as a single directorship and directorships
in organisations which do not predominantly pursue commercial objectives are also not included). Directorships are those held at 31 December 2022 or at time of cessation from
the Board. A full listing of each Board member’s external directorships are available in the Group’s Pillar 3 Disclosures Report available at https://www.permanenttsbgroup.ie/
investors/result-centre/year/2022.
106
Permanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Leadership and Effectiveness
Division of Responsibilities
The roles and responsibilities of the Board collectively, the Executive and Non-Executive Directors, the Chairman, Senior
Independent Director and Company Secretary, are clearly laid out and documented in a Board Manual, which is reviewed and
updated on a regular basis by the Board and at least annually.
The Chairman
Robert Elliott’s responsibility as Chairman is to ensure the efficient and effective working of the Board. His role is to lead and
manage the business of the Board, promoting the highest standards of corporate governance and ensuring accurate, timely and
clear information for the Board, and to lead the process for the annual performance evaluation of the Board, its Committees and the
Non-executive Directors. The Chairman promotes a culture of openness and debate by facilitating the effective contribution of Non-
Executive Directors in particular, and ensuring constructive relations between Executive and Non-Executive Directors. The Chairman
has a strong working relationship with the CEO, Eamonn Crowley, and acts as a confidential sounding board for the Directors. Robert
Elliott is also Chairman of the Nomination Culture and Ethics Committee.
The Senior Independent Director
Ronan O’Neill is the Board’s Senior Independent Director and his primary role is to support the Chairman on all governance related
matters. In addition, he specifically leads the annual appraisal of the Chairman’s performance, acts as an intermediary for other
Directors, and ensures that the views of the Non-Executive Directors are heard. He is available to shareholders, should they wish to
raise any matter directly.
The CEO
The Board delegates executive responsibility to Eamonn Crowley, the CEO, for the Bank’s operations, compliance and performance.
The role of the CEO is to select and lead an effective team to manage the Bank. The executive management team is called the
Executive Committee (Exco), details of which are set out on pages 108 to 109. The CEO is responsible for the formulation of the
Group’s strategic, operating and financial plans, for review and presentation to the Board, and for the implementation of these plans.
The CEO is also required to provide information to the Board that is reliable, relevant, timely, clear and balanced, in order to assist the
Board in monitoring the performance of the Group and in making well informed and sound decisions.
The Company Secretary
Conor Ryan, Company Secretary and Head of Corporate Governance, assists the Chairman in promoting the highest standards of
corporate governance. He supports the Chairman in ensuring Directors receive timely and clear information so that the Directors are
properly equipped for constructive debate and informed decision making. He is a central source of guidance and advice on policy,
procedure and governance. He co-ordinates, when necessary, access to independent professional advice for Directors. He oversees
compliance with all of the Group’s governance related legal and regulatory obligations. In addition, he has responsibility for providing
a high quality service on all shareholder related matters. All Directors have access to the advice and services of the Company
Secretary and Head of Corporate Governance.
107
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Leadership and Effectiveness (continued)
EXECUTIVE COMMITTEE
EAMONN CROWLEY
CHIEF EXECUTIVE
NICOLA O’BRIEN
CHIEF FINANCIAL OFFICER
GER MITCHELL
CHRO & CORPORATE
DEVELOPMENT
DIRECTOR
Ger has been a member of the Executive Committee since 2012. Ger is an experienced
commercial leader who has held a number of senior retail, commercial and customer roles prior
to his appointment as HR Director in 2017. In 2020 Ger’s role was expanded to include ‘Corporate
Development’ which brings the strategic disciplines of; marketing, brand, corporate affairs,
customer experience, sustainability and communications together with organisation design,
talent development, people experience and culture evolution. The HR and Corporate Development
Function leads the embedding of the Bank’s Purpose; to build trust by making a difference in the
lives of customers, colleagues and communities, every day. HR and Corporate Development lead
a number of strategic programmes focused on Brand, Culture and Reputation; Customer Strategy
and Experience; Enterprise Transformation, including Hybrid Workplace; and Sustainability.
ANDREW WALSH
LEGAL COUNSEL
Andrew has extensive legal advisory experience, in both private practice and in-house roles.
Andrew joined the Bank in 2014 and became a member of the Executive Committee in 2015. Prior
to joining the Bank, Andrew was a partner in a leading corporate Irish law firm, where he worked for
over 10 years. While in private practice, Andrew advised a number of Irish and international banks
and financial services institutions.
In his role as Legal Counsel, Andrew leads the Bank’s Legal function. The Legal function is
responsible for overseeing all legal aspects of the Bank’s business, as well as inputting into the
Bank’s strategic decisions and identified growth opportunities. The Legal function also provides
support to ensure that the Bank’s operations, products and service strategies are designed to
consistently adhere to legislative/regulatory requirements and best practice.
Claire, a Chartered Accountant with over 20 years’ experience, joined the Bank in 2021 as the
Bank’s Head of Group Internal Audit from KPMG, where her most recent role was Managing
Director, Risk & Regulatory Consulting. In this role Claire led major risk transformation projects and
the delivery of internal audit services to a portfolio of financial services clients for over six years.
Prior to her role as Managing Director, Risk & Regulatory Consulting, Claire held a number of senior
roles including: Retail Division Audit Partner in the Group Internal Audit division of Bank of Ireland
and Deputy Group Secretary of Bank of Ireland.
Internal Audit provides independent assurance to the Board over the adequacy and effectiveness
of the governance, risk management and control processes in operation across the Bank. Claire
is a regular attendee at Group Executive Committee meetings but, in accordance with good
governance practice, has no voting rights. Claire has a direct reporting line to the Chairman of the
Board Audit Committee.
CLAIRE HEELEY
HEAD OF INTERNAL
AUDIT
108
Permanent TSB Group Holdings plc - Annual Report 2022 DAVID CURTIS
CHIEF RISK OFFICER
(INTERIM)
David is a senior risk professional with thirty years’ plus experience in banking and has had a
varied career in both public & private sectors in a range of disciplines including Credit, Executive
Management, Risk Management, Stress Testing, Compliance, Audit (internal & external) and
Information Management.
TOM HAYES
CHIEF TECHNOLOGY
OFFICER
He is currently the Interim Chief Risk Officer with the Bank and is responsible for the management
of the Group Risk function which ensures the Bank has an effective Risk Management Framework
& Process in place. Prior to his current role, he was Chief Credit Officer with responsible for the
management of Credit Risk through the full credit lifecycle. Before his appointment as Chief Credit
Officer, he has held a number of senior roles both within & outside Credit Risk including Risk COO.
He is a graduate of Trinity College Dublin where he received a Master’s in Business Administration
and has a Degree in Computer Science. He is a qualified Accountant (FCCA), holds the Certified
Bank Director qualification and is a fellow of the Institute of Internal Auditors - UK.
Tom is an experienced business transformation and technology leader with deep experience in
leading Digital change and operational resilience. Tom joined the Bank in 2017 from AIB where he
had most recently held the role of Head of Digital Transformation Delivery. Tom had held various
senior technology leadership roles at AIB including: Head of Customer Engagement Technology,
AIB Digital and Group Head of IT Infrastructure & Operations.
PTSB Group Technology has responsibility for the development and implementation of the Bank’s
Technology strategy, the implementation of the Digital Transformation roadmap and the full
portfolio of IT Change Delivery. This involves close collaboration across the Bank and especially
with the Retail Banking and Group Operations teams to design and deliver on the Bank’s Digital
Transformation. The Division also has responsibility for the day-to-day critical technology
operations, resilience and protection of technology enabled customer services.
PATRICK FARRELL
RETAIL SALES DIRECTOR
Patrick has over 25 years’ experience across the banking industry. Patrick joined the Bank in
December 2018 as Retail Banking Director. Patrick has previously held senior management roles in
Strategy, Product and Proposition Development, Marketing, Private Banking and, Retail Sales and
Service Distribution.
PETER VANCE
CHIEF OPERATING
OFFICER
The Retail Banking Division is responsible for all sales and service channels and the Bank’s
product management strategy. The Function has multi-channel oversight across sales and service
with a focus on improving customer experience, meeting customer needs and wants, enabling
income growth and delivery. The division closely collaborates with the Corporate Development and
HR Team on customer propositions and experience.
Peter joined the Bank as Chief Operations Officer in 2021 from AIB, where his most recent role was
Head of Customer Services. In this role, Peter was responsible for leading multiple activities in both
Ireland and the UK including; Payments, Treasury services, Financial Crime, SME Lending and the
Customer Service Centre. Prior to his role as Head of Customer Services, Peter held a number of
other senior executive positions at AIB including; Head of Payments, Cards and Treasury Services,
Head of Payments and Head of Payments Transformation.
Group Operations encompasses Banking Operations, Collections & Recoveries and other key
functions. The business unit is focussed on consolidating, standardising and simplifying activity
so as to enable the Bank to deliver an exceptional customer experience, while also generating
efficiencies.
Executive Committee Vacancies
David Curtis was appointed to fill the Chief Risk Officer role on an interim basis, the Bank’s recruitment process to fill the position on a
permanent basis is at an advanced point.
109
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Governance Structure, Roles and Responsibilities
Board
CEO
Nomination, Culture & Ethics Committee
Audit Committee
Risk & Compliance Committee
Remuneration Committee
Executive Committee
Risk
Committee
Customer
Committee
Sustainability
Committee
Assets and Liabilities
Committee
OP Risk
Committee
Credit
Committee
Board
The Board retains accountability for corporate governance within the Group at all times. The Board has reserved for itself a documented
schedule of matters for its own approval. The Board delegates executive responsibility to the CEO for the Group’s operations, compliance
and performance. The CEO is the principal executive accountable to the Board for the day to day management of the Group. The CEO has
established the Executive Committee whose terms of reference are approved by the Board.
Without prejudice to the powers delegated to it, the Board, directly or through its Committees, has exclusive powers regarding a number
of matters including acting on behalf of the shareholders to oversee the day-to-day affairs of the business, ensuring the Group’s
sustainability by collectively directing the company’s affairs, whilst meeting the appropriate interests of its shareholders, customers,
colleagues and other key stakeholders. In addition to business and financial issues, the Board will determine the business strategies and
plans that underpin the corporate strategy, whilst ensuring that the Group’s organisational structure and capability are appropriate for
implementing the chosen strategies. The Board must deal with challenges and issues relating to corporate governance, sustainability
and corporate ethics.
Board
• Sets and oversees performance against strategy.
• Ensures business activity aligns with the Company’s stated
Purpose, Ambition, Values and Culture.
• Set and oversees all risk, financial, compliance and
performance standards.
• Demonstrates leadership (sets the tone from the top)
In line with its legal and regulatory obligations, the Board
has established Audit, Risk, Remuneration and Nomination
committees as described below. Being composed of the
same members and in managing a common agenda,
Board Committee meetings of the Company and PTSB run
concurrently.
Nomination, Culture and
Ethics Committee
Robert Elliott (C)
Marian Corcoran
Celine Fitzgerald
Ken Slattery
Ronan O’Neill
• Reviews structure, effectiveness
and composition of the Board.
• Reviews all new Director
and senior management
appointments.
• Oversees succession planning
and performance for directors
and senior management.
Audit
Committee
Ronan O’Neill (C)
Donal Courtney
Anne Bradley
Paul Doddrell
Andrew Power
• Oversees internal financial
controls.
Risk and Compliance
Committee
Donal Courtney (C)
Marian Corcoran
Paul Doddrell
Ruth Wandhöfer
Anne Bradley
• Oversees financial and non-
financial risks.
• Reviews full year and half-year
• Monitors and makes
Remuneration Committee
Ken Slattery (C)
Robert Elliott
Ruth Wandhöfer
Celine Fitzgerald
Andrew Power
• Oversees remuneration and
reward strategies.
• Ensures remuneration strategy
is aligned with the Company’s
appetite for risk.
financial statements.
• Oversees all relevant matters
pertaining to the external
auditors.
recommendations to the Board on
the Company’s appetite for risk.
• Oversees credit, funding and
• Oversees senior management
liquidity policies.
reward.
• Monitors the output of internal
• Reviews the Company’s regulatory
• Monitoring relevant external
• Review/monitors the
audit findings
design, implementation and
effectiveness of the Company’s
Purpose, Ambition and Values.
• Oversees the Company’s
Culture, Ethics, Diversity,
Workforce Engagement,
and Responsible Business
Programmes.
• Monitors the effectiveness of
the Internal Audit Function.
• Reviews discoveries of fraud and
violations of laws and regulations
as raised by the head of GIA.
obligations and treatment of
customers.
• Review and provide guidance
to the Board on the Company’s
capital and liquidity position for
use in strategic decision making.
• Oversight and guidance to the
Board on Recovery and Resolution
Planning.
• To assess the impact of Climate
and Environmental Risk on the
Group’s overall Risk Profile.
110
benchmarks for posts within the
scope of Committee.
Permanent TSB Group Holdings plc - Annual Report 2022
Executive Committee
The Executive Committee reports upward through the CEO to the Board, and where delegated, have the power to act on behalf of the
Board. The Executive Committee advise the Board on matters ranging from business performance, strategy, planning, policy, people and
culture, investment and risk. The Executive Committee is accountable for the operations, compliance and performance of the Group. It
is responsible for delivery of all delegated governance commitments. The terms of reference of the Executive Committee is approved by
the Board.
The Executive Committee has established a number of sub-committees made up of senior management with relevant expertise to
address the delegated obligations of each sub-committee. The duties of these sub-committees are based on providing organisational
direction on behalf of the Executive Committee. Each Executive Committee member provides relevant leadership to the sub-
committees, making sure objectives are met. The Executive Committee member which chairs the respective sub-committee provides
updates to the Executive Committee, serving as a conduit between the sub-committees and the Executive Committee. The Board has
delegated oversight of Group Wide Risk Management Issues to the Group Risk Committee and an important safeguard in exercising this
delegation is the requirement that all members of the Executive Committee be concurrent members of the Group Risk Committee.
Executive Committee
• Developing and implementing (as approved by the Board) the Group’s Strategy, Strategic Direction and Operating Model
• Allocating, and re-allocating, the Group’s resources (financial and people) to ensure that commitments are executed and delivered
• Accountable for the Group’s operations, compliance and performance
• Oversees day-to-day management of the Group
• Forum for Group-wide functional issues
Assets and
Liabilities
Committee
• Manages assets and
liabilities, treasury
investments, capital
management and
asset allocation
• Manages risks,
hedging and ALM
systems
• Refresh and
recommend to Risk
and Compliance
Committee for
approval a number
of Treasury and
Liquidity related
Policies
• Reviews the ongoing
capital adequacy for
the Group
• Reviews the output
from internal capital
stress testing
programmes
• Oversees the
Capital Risk related
activities and
supporting Policies
Risk
Committee
• Oversight of
Group wide Risk
Management Issues
• Developing the
structure and
content of the
Group’s Risk
Management
Architecture
• Maintains, monitors
and enforces
adherence to
risk policies and
frameworks
• Recommends
changes to risk
appetite and internal
capital and liquidity
levels
• Measure and
monitor the total
risk position of
the Group and to
maintain a Risk
Register of top risks
facing the Group,
together with an
assessment of the
probability and
severity of those
risks
Credit
Committee
Operational Risk
Management
Committee
Customer
Committee
Sustainability
Committee
• Recommends
• Monitors the
• Prioritise
• Oversight of
development and
implementation
of the Group’s
Sustainability
Strategy and related
KPIs
• Monitor and report
progress against
Sustainability
objectives
• Oversees the
Sustainability
related activities
and provide support
and guidance
into sustainability
activities across the
Group
relevant Portfolio
Credit Risk elements
of the Group’s RAS
for approval by the
Board
• Monitors adherence
to the Group’s
Credit Policy and
Framework
• Monitors the
portfolio Credit risks
to which the Group
is exposed
• Escalation point for
customer lending
decisions
• Maintains and
assesses the
portfolio Credit Risk
profile against set
limits and approves
(within governance)
remediation plans
to restore Risk
Appetite where
required
• Reports any
breaches of
approved limits in
accordance with
agreed protocol
Operational and IT
risks to which the
Company is exposed
• Oversees risk
mitigation,
performance and
prioritisation related
to the management
and control of risk
• Reviews and
discusses the
outputs and results
of control testing
• Creates awareness
of commonly
experienced
operational & IT
risk matters, to
share learnings and
enhance the control
environment across
the Company
• Review and monitor
KRIs and the
operational and
IT Risk Appetite
Statement
• Review emerging
risks and other
relevant operational
and IT risk metrics
opportunities,
resources and
capabilities to
deliver sustainable
commercial growth
• Oversight of
significant business
propositions and
strategies that have
a material customer
impact
• Approval body for
product governance
arrangements
• Review body for
all high impact
customer events,
issues and
complaints
• Monitor and report
on customer
performance
indicators aligned
to the Group’s
strategic pillars
• Monitor and report
on conduct risk
indicators against
the Board approved
risk appetite
and conduct risk
principles
• Serve as the central
oversight body for all
significant customer
matters ensuring
fair treatment of
customers
111
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Board Leadership and Effectiveness
“The Board has overall governance responsibility for the operations of the Group”
Board Role and Responsibilities
The Board as a whole is collectively responsible for the leadership, strategic direction and policy, operational performance, financial
matters, risk management and compliance of the Bank. The Board exercises leadership, integrity and judgement in directing the Bank,
based on transparency, accountability and responsibility. The Board is also the focal point for the implementation of best practice
corporate governance within the Bank. All Directors must take decisions objectively in the interests of the Bank. The key responsibilities
of the Board as a whole are to:
Key Responsibilities of the Board
Customers
Ensure that the Bank’s culture, systems and practices build trust and promotes the fair and
transparent treatment of customers, both existing and new.
Deliver a positive customer-focused culture that is both embedded through adherence to the Bank’s
purpose, ambition and values and can be effectively demonstrated through regular updates from
Management.
Culture and Diversity
Setting the Bank’s purpose, ambition and values, and monitoring culture and alignment to the
established purpose and values.
Embedding the Bank’s Organisational Culture and Diversity and Inclusion Programmes.
Strategy
Question, challenge, assist in the development of, and approve the strategic and operating plans
proposed for the Bank by Management. Ensure that an appropriate level of balance exists between
its strategic contribution and that of its monitoring and policing activity.
Identifying the ESG factors considered material to the business and ensuring they are monitored and
managed as part of the Bank’s strategic formulation.
Stakeholders
Ensure effective engagement with and understanding of stakeholders views.
Risk Appetite and Risk
Management
Define the strategy for the ongoing management of material risks and ensure that the Board is
sufficiently briefed on major risk factors (both current and emerging) by ensuring that there is a robust
and effective internal control framework that includes well-functioning risk management, compliance
and internal audit functions as well as an appropriate financial reporting and accounting framework.
Provide leadership for the Bank within a framework of prudent, ethical and effective controls which
enable risk and compliance to be assessed and managed.
Capital Structure
Set and oversee the amounts, types and distribution of both internal capital and own funds adequate
to cover the risks of the Bank.
Be accountable, particularly to those who provide the Bank’s capital.
People and Reward
Strategy
Ensure that there is a remuneration framework that is in line with the risk strategies of the Bank.
Ensure that there is a robust and transparent organisational structure with effective communication
and reporting channels.
Ensure that Management create and develop a performance culture that drives sustainable value
creation and not expose the Bank to excessive risk of value destruction.
Ensure that workforce policies and practices are consistent with the Company’s values and support its
long-term sustainable success and that the workforce should be able to raise any matters of concern.
Oversight
Make well informed and high quality decisions based on a clear line of sight into the business.
Ensure that the Bank has a robust finance function responsible for accounting and financial data.
Governance
Arrangements
Review regularly the appropriateness of its own governance arrangements and conduct internal as
well as external evaluation of the Board’s effectiveness.
Review corporate governance matters such as Group Frameworks, terms of reference and
succession plans.
Directors must also act in a way they consider, in good faith, would promote the success of the Bank for the benefit of shareholders as
a whole and, in doing so, have regard (amongst other matters) to the likely consequences of any decision in the long-term; the need to
foster the Bank’s business relationships with customers, suppliers and others; interests of the Bank’s employees; impact of the Bank’s
operations on the community, environment and tax payer; and desirability of the Bank maintaining a reputation for high standards of
business conduct.
112
Permanent TSB Group Holdings plc - Annual Report 2022 Board Decisions
There is an effective Board to lead and
control the Bank with members who have
diverse expertise in various aspects of the
Bank’s business. The Board has reserved
to itself for decision, a formal schedule
of matters pertaining to the Bank and
its future direction, such as the Bank’s
commercial strategy, major acquisitions
and disposals, Board membership, the
appointment and removal of senior
executives, executive remuneration, trading
and capital budgets, risk management and
compliance frameworks. This schedule
is updated on a regular basis and at least
annually. On an annual basis, the Board
approves a Risk Appetite Statement (RAS)
together with its strategic, operating and
financial plans. The RAS is a description
of the level and types of risk the Bank is
willing to accept or to avoid, in order to
achieve its business objectives.
The Board delegates day-to-day
management of the Bank to the CEO.
The Board relies on the Risk Appetite and
the delivery of strategic, operating and
financial plans to be implemented by the
CEO, the Bank’s Executive Management
Committee and their Management sub-
committees. All strategic decisions are
referred to the Board. Documented rules
on management authority levels and on
matters to be notified to the Board are
in place, supported by an organisational
structure with clearly defined authority
levels and reporting responsibilities.
Board Focus Areas and Priorities
As in previous years, the Board adopted
a set of objectives closely aligned to the
Bank’s purpose, ambition and strategic
objectives. A key focus for the Board
during 2022 was providing enhanced
oversight on the execution of the deal
announced at the end of 2021 to acquire
certain elements of the Ulster Bank Retail
and SME franchise. This, together with
the opportunity presented for customer
acquisition following the withdrawal
of both Ulster Bank and KBC from the
Irish market was a priority focus for the
Board. The Board ensured that the Bank’s
human and financial resource allocation
was being prioritised to ensure safe
execution of the transaction with Ulster
Bank while also maintaining secure and
resilient systems to support customers.
This included providing oversight on the
execution of the Bank’s digital banking
programme which is transforming front
end and back end systems to support
customers and colleagues, improve the
Bank’s competitiveness and deliver value
to shareholders. 2022 was a year were
significant focus was placed on colleagues
and culture with the Bank welcoming over
1,400 new colleagues including 112 from
Ulster Bank. Ensuring these colleagues
were welcomed, received appropriate
induction/training/tooling and understood
the values to which the Bank espoused
where key focus areas for the Board.
The Bank has gone through a significant
change in 2022 and the Board has provided
oversight to ensure this change was
actively managed/prioritised and in a risk
aware manner while maintaining resilient
day to day operations. The Board continued
to focus on ensuring the Bank was evolving
its culture, strengthening its balance sheet,
adapting its corporate strategy, conforming
to effective, prudent and ethical standards
of corporate governance and effectively
managed in the areas of risk and
compliance.
Board priorities in 2023 include oversight
of the migration of the remaining Ulster
Bank business (circa. €1.5bn of a mortgage
book and an Asset Finance business) and
colleagues to the Bank, and on continuing
to execute the Bank’s digital transformation
initiatives. The Board will also continue
to focus on maturing the Bank’s SME
Strategy to complement the acquisition
of the Lombard and Ulster asset finance
business which will be supported through
digital enablement and personal customer
service. The Board will also be focussing
on the continued execution the Bank’s
sustainability strategy and working with
stakeholders towards the development and
execution of a new brand proposition. The
Board will continue to ensure this is done in
a prudent manner which ensures the Bank
can execute change while maintaining
resilient systems and customer service
during an uncertain economic and geo-
political environment.
“The Board is responsible
for setting, approving
and overseeing the
implementation of the overall
business strategy taking into
account the Bank’s long-
term financial interests and
sustainability”
Strategy Development
The Board has responsibility for developing
the Bank’s purpose, ambition, values and
strategy, ensuring these are the drivers of
the Bank’s evolving culture.
The Bank’s strategy is reviewed and, if
relevant, refreshed annually. In 2022, the
Board approved four strategic priorities:
Connected Customer Experience;
Sustainable Business Growth; Secure
and Resilient Foundations; and, Cultural
evolution. When aligned to the Bank’s
Purpose and Ambition, the strategic
priorities will frame and drive delivery of
the Bank’s strategy in the medium-term.
In addition, all significant change and
transformation programmes are aligned
to these four priorities, and executed via
the Bank’s ‘Strategic Portfolio’ – a tool for
managing, tracking and reporting strategy
execution. This ensures that the Bank’s
strategy is aligned to its stated purpose
and ambition.
The Board annually approved a five year
strategic and operating plan (Medium
Term Plan or MTP). The annual strategy
refresh is undertaken as part of the Bank’s
Integrated Planning Process, which links
Strategic, Financial and Change Delivery
plans to the Bank’s ICAAP, ILAAP, Recovery
Plan and Risk Appetite Statement.
The role of the Non-Executive Directors
is to help Management: develop,
constructively challenge and critically
review proposals on strategy; oversee
and monitor strategy implementation;
and, address any weaknesses identified
regarding its implementation. While there
is a formalised strategy development and
approval process as set out below, there
is also regular and ongoing discussion
and challenge of strategy development
and execution at Board meetings. The
effectiveness of the strategy development
process is a key element of the annual
Board review where feedback is sought on
the process’ effectiveness during the year
in review.
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Board Leadership and Effectiveness (continued)
3 Stage Annual Strategy
Development Process
Strategy Session 1 (October 2022)
This is a standalone strategy meeting
which addresses key strategic themes
in the external market and internal
environment in which the Bank operates.
The session is structured around
presentations from management and
external partners. For example, in 2022, the
meeting included interactive presentations
on: customer experience; emerging societal
trends; and, domestic macro-economics
and the evolving global financial context.
The first strategy session outlines the
point of departure for the Bank, as well
as key challenges facing the Bank over
the planning period. The Board discusses
and debates the key areas of strategic
focus for the Bank over the coming years
and discusses the relevant priorities of
the Bank, reflecting on the alternative
viewpoints provided from external
partners during the session. This is a key
opportunity for Non-Executive Directors to
provide feedback and input to the Bank’s
Strategic Plan before the first advanced
draft is presented to Board at Strategy
Session 2 (alongside the related draft
Financial and Change Delivery plans).
Strategy Session 2 (Late November 2022)
At the second Board Strategy meeting,
advanced drafts of the Bank’s Strategic,
Financial and Change Delivery plan
are presented to the Board for further
discussion, input and iteration. The
Bank’s Executive Management Team sets
out how Board feedback from Strategy
Sessions 1 and 2 has been addressed and
incorporated into each respective plan.
This session is the last formal checkpoint
that the Board has to provide input and
challenge to the plans in advance of formal
approval of each respective plan by year
end. The third session also provides an
opportunity for the Second Line of Defence
to present their emerging challenge
and assessment of the proposed plans.
Similarly to the first Strategy Session,
this meeting includes deep-dives into key
strategic programmes or themes; however,
in this session they are more internally
focused.
Final Sign-Off (Mid-December 2022)
Following completion of the second
strategy session, and with continued
engagement with the Bank’s Management
Team, the final draft Strategic, Financial
and Change Delivery plans are presented to
Board for formal approval. This takes place
114
in mid-December as part of the agenda for
the standing monthly Board meeting.
The Board is responsible for overseeing
the implementation of the overall business
strategy. On an ongoing basis throughout
the year, the Board receives management
updates on key strategic programmes
of work as well as on agreed KPIs and
reporting metrics.
Independence
The independence status of each Director
on appointment is considered by the Board.
In addition, the independence status of
each Director is reviewed on an annual
basis to ensure that the determination
regarding independence remains
appropriate. In determining independence,
the Board will consider guidance on
independence provided within the UK Code.
The Board has carried out its annual
evaluation of the independence of each
of its Non-Executive Directors, taking
account of the relevant provisions of the
UK Code, namely whether the Directors are
independent in character and judgment and
free from relationships or circumstances
which are likely to affect, or could appear to
affect the Directors’ judgment.
With the exception of Marian Corcoran and
Paul Doddrell, who were each nominated
for appointment to the Board under the
terms of a Relationship Framework with the
Minister for Finance of Ireland, the Board
is satisfied that each of the current Non-
Executive Directors fulfil the independence
requirements of the UK Code. The
Chairman meets the UK Code requirement
to be independent on appointment.
Each of the Chairman and all of the Non-
Executive Directors bring independent
challenge and judgement to the
deliberations of the Board through their
character, objectivity and integrity.
Board Size and Composition
The Composition of the Board and its
Committees is reviewed by the Nomination,
Culture and Ethics Committee and the
Board annually to ensure that there is an
appropriate mix of knowledge, experience
and skills. This review considers tenure,
succession planning, Board gender
diversity targets and assessment of the
continued collective suitability of the Board.
The Board has a target size of 12 Directors.
In addition to having Directors with a broad
range of knowledge, experience and skills,
a principal consideration used to determine
the size of the Board is the ability to
resource all of the Board’s Committees with
at least four Non-Executive Directors and
without need for over reliance on any one
Director or small group of Directors.
Save where a Director is nominated for
appointment by the Minister for Finance
under the Relationship Framework, the
Board requires that all Non-Executive
Directors are Independent Non-Executive
Directors. The Board believes that there is
an appropriate combination of Executive
and Non-Executive Directors so that there
is sufficient independent challenge and
oversight of the Executive Directors and
such that no individual or small group of
individuals can dominate Board decision
making.
At 31 December 2022, the Board comprised
twelve Directors: the Chairman, who was
independent on appointment, the CEO,
the CFO and ten Non-Executive Directors,
eight of whom have been determined
by the Board to be independent Non-
Executive Directors. Changes to the Board
during 2022 included the appointment of
Nicola O’Brien as an Executive Director
on 4 August 2022. Biographies of each of
the Directors are set out in the Board of
Directors section on pages 100 to 106. The
wide range of knowledge, experience and
skills that is encapsulated in the biographies
is harnessed to the maximum possible
effect in the deliberations of the Board.
Having Directors with diverse backgrounds
in areas such as risk management, banking,
change management, digital/IT, strategy
and planning, finance, culture evolution,
change management and auditing provides
both subject matter expertise and facilitates
a broad spectrum of review and challenge
at Board meetings, particularly when
addressing major issues affecting the Bank.
Decisions on Board membership are
taken by the Board or by shareholders
with recommendations coming from the
Nomination, Culture and Ethics Committee.
Term of Office
The term of office of Non-Executive
Directors is three years, (with an option
for a further three years) and is subject to
satisfactory performance that is reviewed
annually. In accordance with the UK Code,
all Directors are required to seek re-
appointment by election at the AGM. Non-
Executive Directors will automatically retire
from the Board after six years. It is always
at the discretion of the Board to invite a
Non-Executive Director to continue for a
Permanent TSB Group Holdings plc - Annual Report 2022 further 3 year period and any term beyond
this will only be exercised in exceptional
circumstances (see page 97 on UK Code
disclosures).
The Chairman is proposed for re-
appointment by the Directors on an annual
basis. The term of office of the Chairman is
six years. In 2022 the Chairman informed
the Board he would not be seeking an
extension to his term of office which was
due to expire in March 2023. Julie O’Neill
who joined the Board on 17 January 2023
will succeed Robert Elliott as Chairperson
when he steps down from the Board on
the 31 March 2023. All other members of
the Board will stand for re-election at the
2023 AGM with the exception of Andrew
Power who will retire from the Board in 2023
having completed his six year term of office.
Executive Directors’ service contracts are
reviewed by the Remuneration Committee
and approved by the Board. Existing
Executive Directors’ contracts provide
for a rolling 6 month notice period for all
Executive Director Board appointments
from 2020. Holders of Executive office
in the Company will vacate the office of
Director on ceasing to hold Executive office.
Directors who hold any directorship in a
subsidiary of the Company will vacate said
directorship on ceasing to be a Director of
the Company and no Director will receive
compensation for loss of office as a Director
of a subsidiary of the Company.
2022 Board Performance Evaluation
The Board has a formal and rigorous
performance evaluation process to
assess the effectiveness of the Board,
its Committees, and individual Directors.
The performance evaluation is conducted
internally on an annual basis, and externally
facilitated every three years. An externally
facilitated evaluation of performance last
took place in 2021 by Promontory Financial
Group (Promontory) and will take place
again in 2024; the Chairman requested the
2022 performance evaluation process to
be internally facilitated by the Company
Secretary.
The evaluation of the Board and its
Committees considers the balance of skills,
experience, independence and knowledge
of the Board, its diversity, including gender
balance, how the Board works together
as a unit, and other factors relevant to its
effectiveness. In addition, the evaluation
ensures that Board committees have the
requisite expertise to properly discharge
their duties.
The process for the 2022 Board
performance evaluation is described
below. The methodology used for the
evaluation sets out to ensure that there
was a formalised approach to the Board
evaluation that took into account both
the views of the Directors and Senior
Management. The rationale for the
approach taken also ensured that the
performance evaluation of individuals
and of the Board collectively was brought
together into one integrated process.
2022 Board Evaluation Process
During 2022
The Board Chairman met collectively with
the Non-Executive Directors without the
presence of the Executive Directors.
November 2022
Full governance and internal stakeholder
engagement as part of review of Board
and Committee meeting packs, Terms of
Reference, Board Manual, and Governance
documents.
A questionnaire based on key governance
related themes was issued to the Board to
assess the performance of the Board and
its Committees. A separate questionnaire
on Board performance was also issued to
the Executive Committee.
December 2022 - January 2023
Non-Executive Directors: The Chairman
held private one-to-one interactions with
each of the Non-Executive Directors to
evaluate their performance and agree
developmental areas relating to their own
individual performance. These interactions
also provided a forum for the Chairman
to obtain views of individual Directors
with regard to the effectiveness of the
Board and that of its Committees and to
assess training requirements for individual
directors and collectively for the Board.
Chairman: Led by the Senior Independent
Director, the Non-Executive Directors
carried out the performance evaluation of
the Chairman, taking into account the views
of Executive Directors. The Chairman was
not present at the meeting when dealing
with the evaluation of his performance.
CEO: The Chairman obtained feedback
from the Non-Executive Directors and
subsequently presented his evaluation of
the CEO’s performance against agreed
objectives to the Nomination, Culture and
Ethics Committee.
Executive Directors: The Board met
collectively with the Non-Executive Directors
with the CEO present.
February 2023
The Nomination, Culture and Ethics
Committee’s review of 2022 Board
performance took place on 20 February
2023. At this meeting, the members of the
Committee received and discussed the
following reports:
• The Chairman presented his report
on individual Non-Executive Director
performance;
• The SID, without the presence of the Chair,
presented his report on the performance of
the Chairman;
• The Chairman, without the presence
of the CEO, presented his report on the
performance of the CEO;
• The CEO presented his assessment of
performance of the Bank’s ExCo members;
• Each of the Committee Chairs presented
their review of the performance of their
respective Committee;
• The Chair of the Audit Committee
confirmed that he had undertaken,
with input from the members of the
Audit Committee, an assessment of
the performance of the Head of GIA to
the Audit Committee and presented a
summary of his report;
• A governance discussion document
prepared by the Company Secretary and
which included;
• A Board and Committee tenure report;
• An attendance schedule for 2022 Board
and Board Committee meetings;
• An independence assessment of the Non-
Executive Directors;
• An outline of the responsibilities of the
Board, Chairman and CEO;
• An assessment of External Directorships;
• Details of any declared Conflicts of
Interests of the Directors.
During a Board meeting held on 28
February 2023, the Chairman presented
the 2022 Board performance evaluation for
consideration by the Board.
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Board Leadership and Effectiveness (continued)
Outcomes of 2022 Board Performance Evaluation
During a meeting held on 20 February 2023, the Nomination Culture and Ethics Committee received a report from the Company
Secretary on the performance evaluation of the Board for 2022. The Board was satisfied that the Non-Executive Directors, the Chairman
and the Executive Directors contributed effectively to Board debate and discussion and demonstrated a knowledge and understanding
of the business, its risks and material activities. A number of actions, arising from the Chairman’s report, were agreed which will be
overseen by the Chairman during the year.
2022 Board Performance Action Plan
Culture
Risk
Culture
IAF and SEAR
Board Reporting
Sustainability
Enhanced focus on developing, maintaining and monitoring the desired culture of the Group as it becomes a larger organisation
through the acquisition of parts of the Ulster Bank business.
Continue to prioritise oversight on the effectiveness of the Bank's Risk Management Framework across
all three lines of defence, with a particular focus on operational resilience and embedding new digital and
operational risk management tools and processes from 2023.
Enhanced focus on developing, maintaining and monitoring the desired culture of the Bank as it becomes a
larger organisation through the Ulster Bank transaction.
In light of the impending introduction of IAF and SEAR, the Company Secretary should continue to review
and update board processes and documentation and ensure the Board understand their collective and
individual responsibilities and accountabilities arising from the new legislation.
The Board should continue to encourage the timely delivery of management reporting to the Board and its
committees with key risks and issues being a key element of executive summaries.
The Board has requested a review of the Board committee responsibilities to ensure the wide spectrum
of activity under the Bank's Sustainability Strategy is being effectively overseen at Board and Board
Committee level.
Director Induction and On-Going Business Awareness
On appointment to the Board or to any Board Committee, all Directors receive an induction training schedule tailored to their individual
requirements. The induction, which is designed and arranged by the Company Secretary in consultation with the Chairman, will include
meetings with Directors, Senior Management and key external advisors, to assist Directors in building a detailed understanding of the
Group’s operations, management and governance structures, including the functioning of the Board and the role of Board Committees
and key issues facing the Group. Directors will also be encouraged, where appropriate, to make site visits to see the Groups operations
first hand. Where appropriate, additional business awareness briefing sessions and updates on particular issues identified in
consultation with the Chairman and Non-Executive Directors will be arranged by the Company Secretary. These will be held regularly to
ensure that Non-Executive Directors have the knowledge and understanding of the business to enable them to contribute effectively at
Board meetings. The business awareness and development needs of each Non-Executive Director will be reviewed annually as part of
the performance evaluation process.
2022 Board Training and On-Going Business Awareness
Board Training Sessions
A number of Board training sessions were facilitated during 2022 to support on-going business awareness and Director development.
During COVID-19 these sessions were delivered through electronic channels, and given the increased flexibility of theses electronic
/ hybrid sessions, the Board agreed to maintain this approach for training sessions throughout 2022 and beyond as the Bank had
moved to a hybrid working model. Topics for Board training sessions are recommended by the Board Nomination, Culture and Ethics
Committee and include a balance of technical, governance and professional development. Training delivered during 2022 included:
Risk and Control Management; Macro-Economic Outlook; Operational Resilience; Climate and Environmental Risk; Anti-Money
Laundering; Market Abuse; and Corporate Legal and Regulatory latest Developments.
Board Briefings
In addition to formal Board training sessions, a number of Board briefings were presented to the Board during 2022. The purpose of
these briefings is to ensure Directors have the knowledge and understanding of the business to enable them to contribute effectively
to meetings, by providing insight into impending changes which may impact on the Board’s responsibilities, the Bank’s progress
in implementing such changes, or to present industry updates. Board briefings presented during 2022 included: macro-economic
outlook; capital and liquidity planning; recovery planning; future of banking and technology; strategic vendor management; Russia &
Ukraine War; hybrid working; and organisational design spotlights.
Individual Director Development
An individual training plan is developed for each Director on appointment and reviewed annually by the Chairman. The purpose of
individual training plans is to support individual Director development. Each Director is required to undertake the Institute of Bankers
Certified Bank Director programme. Directors are also offered the option of attending suitable external educational courses, events
or conferences designed to provide an overview of current issues of relevance to their work on the Board. Led by the Chair, the Non-
Executive Directors met without the Executive Directors present.
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Permanent TSB Group Holdings plc - Annual Report 2022 During 2022, two of the Board’s
permanent Committees were composed
of Independent Non-Executive Directors
and two were composed of a majority of
Independent Non-Executive Directors.
The Board acknowledges that it is not
in compliance with the UK Code (which
requires all directors to be independent)
with regard to the membership of its Audit
Committee and has set out is approach to
dealing with this matter on page 97. The
Membership and the Chairmanship of each
committee are reviewed annually.
Each of the Board Committees has Terms
of Reference, under which authority is
delegated by the Board, which are reviewed
annually. The Terms of Reference of each
Committee are available on the Bank’s
website www.permanenttsbgroup.ie. As
Covid receded in early 2022 the Bank held
a hybrid AGM (in person and webcast). The
Board Committee Chairs together with
a number of Board members attended
the AGM and were available to answer
questions from shareholders.
commercial and financial performance
at each of its meetings. The minutes of
Board committees are made available to
all Directors through a designated reading
room in the Board portal. The Board portal
also contains an extensive document
repository and is the primary method of
communication with Directors.
The Board, Board Committees and the
Bank’s Executive Committee operating
rhythm supports a proactive and focused
agenda planning and paper preparation
process. This process includes pre-
meetings of the Board between the
Chairman, CEO and Company Secretary
to ensure the Board and Executive
Management are aligned on Board
agendas.
Board Committees
The Board has established four permanent
Committees to assist in the execution of its
responsibilities. These Committees are:
• Audit
• Risk & Compliance
• Nomination, Culture & Ethics
• Remuneration
Other Committees are formed from time to
time to deal with specific matters. During
2021, the Board established a committee
of the Board to provide support on the
corporate transaction to acquire certain
elements of the Ulster Bank business in
Ireland. This committee operates within
a Board approved terms of reference and
consists the following members: Robert
Elliott (Chair), Eamonn Crowley, Marian
Corcoran, Anne Bradley, Paul Doddrell,
Ronan O’Neill and Donal Courtney; Mike
Frawley ceased to be a member on 31
March 2022 when he resigned from the
Bank.
Board Meetings
The table on page 106 shows Board
membership and directors’ meeting
attendance during 2022. There were ten
scheduled Board meetings for 2022, the
same number as in 2021. In addition to
scheduled meetings, additional meetings
of the Board, and some of its Committees
(detailed in each Committee report) were
held throughout the year to receive updates
and deal with time-critical matters,
primarily these were related to the Ulster
Bank transaction. There were 16 additional
Board meetings held in 2022 compared to
19 additional meetings held in 2021.
As the impact from the pandemic receded
during 2022 the Board met for the first time
in person in February 2022. The Board has
since operated a hybrid (a mix of in person
and online meetings) meeting format
for scheduled Board meetings during
H2 2022. Board Committee meetings
and training sessions were held virtually
through the whole of 2022. The plan for
2023 and beyond is to move to in person
for scheduled Board meetings and a mix
of hybrid and virtual meetings for Board
Committee meetings and training sessions.
Agendas and papers are circulated to
Directors electronically via a secure online
Board portal in sufficient time to facilitate
review by the Directors. In circumstances
where a director is unable to attend a
meeting, they receive the papers and have
the opportunity to provide their feedback in
advance of the meeting to the Chairman.
At each of the scheduled Board meetings
the directors received reports from the
Chairman, Board Committee Chairmen,
the Chief Executive Officer, the Chief
Financial Officer, the Chief Risk Officer
and other members of the executive
management team, as appropriate.
Other senior executives attended Board
meetings throughout the year to present
reports to the Board. This provided the
Board with an opportunity to engage
directly with management on key issues
and support succession planning. The
Board receives formal reports on Bank
risk and compliance matters together
with its strategic, customer experience,
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Risk Management and Internal Control
Board responsibilities
The Board has overall responsibility for
maintaining a system of risk management
and internal control which provides
reasonable assurance of effective and
efficient operations, internal financial and
operational control, and compliance with
laws and regulations.
The Group’s business involves the
acceptance and management of a range
of risks, consistent with its Corporate
Purpose. The Group’s system of risk
management and internal control is
designed to ensure the delegation of
responsibility for risk oversight and
management is appropriate to the nature
and type of risk faced by the Group.
Provision 29 of the UK Code requires the
Board to review annually the effectiveness
of the Group’s system of risk management
and internal control. This requires a review
to cover all material controls including
financial, operational and compliance
controls. The Board confirms that a
detailed review on the effectiveness of
the Group’s risk management and internal
control systems was undertaken by the
Board Audit Committee during 2022.
In assessing the effectiveness of the
Group’s systems of risk management
and internal control during 2022, the
Committee received assurance from the
CRO (second line of defence) and each
of the accountable Executive Committee
members (first line of defence) that a suite
of documented controls were in place to
effectively manage each of the Group’s
key risks. Supporting this assurance, the
Committee also considered the opinion
of the Head of Group Internal Audit (Third
Line of Defence) in their assessment on the
adequacy and effectiveness of key controls
during 2022 for the Group which were
found to be effective.
While the review indicated there were
areas of the Group’s control environment
that would continue to require
enhancement, the overall effectiveness
of the Group’s control environment during
2022 was a contributing factor in the
Board’s determination of compliance with
Principle C of the UK Code, which requires
the Board to establish a framework of
prudent and effective controls, which
enable risk to be assessed and managed.
The Board also considers the effectiveness
of the Group’s system of risk management
and internal control on an on-going basis.
In this context, the Board has a particular
focus on ensuring that appropriate
governance structures are in place to
address issues raised through internal
review and by feedback from stakeholders,
including regulators. There was no
significant failure of the Group’s system
of risk management and internal control
during 2022 leading to a material financial
loss.
Internal Control Procedures
The Group’s internal control procedures
are designed to safeguard the Group’s net
assets, support effective management
of the Group’s resources, and provide
reliable and timely financial and operational
reporting both internally, to Management
and those charged with governance, and
externally to other stakeholders. They
include the following:
• An organisational structure with formally
defined lines of responsibility and
delegation of authority;
• As set out in the Risk Management
Section a ‘Three Lines of Defence’ model
has been adopted by the Group for the
effective oversight and management of
risks across the Group, with GIA being
the Third Line of Defence;
• A corporate governance structure
has been defined showing the key
governance and decision making bodies
of the Group; each governance body has
a terms of references that sets out its
key areas of responsibility;
• The preparation and issue of financial
reports, including the consolidated
Annual Report, is managed by the Group
Finance department, with oversight
from the Board Audit Committee. The
Group’s financial reporting process is
controlled using documented accounting
policies and reporting formats issued
by the Group Finance department to all
reporting entities (including subsidiaries)
within the Group in advance of each
reporting period end. The Group Finance
department supports all reporting
entities in the preparation of financial
information. Its quality is underpinned by
arrangements for segregation of duties
to facilitate independent checks on the
integrity of financial data. The financial
information for each entity is subject
to review at reporting entity and Group
level by Senior Management. In addition
to reviewing and approving the full year
Annual Report, the Interim and Annual
Report are also reviewed by the Board
Audit Committee in advance of being
presented to the Board for their review
and approval;
• Comprehensive budgeting systems are
in place, with annual financial budgets
and a five year MTP prepared and
considered by the Board. Actual results
are monitored and there is monthly
consideration by the Board of progress
against budgets and forecasts;
• There are clearly defined capital
investment control guidelines and
procedures set by the Board;
• Responsibilities for the management
of credit, investment and treasury
activities are delegated within limits to
line management. In addition, Group
and divisional Management have been
given responsibility to set operational
procedures and standards in the areas
of finance, tax, legal and regulatory
compliance, human resources and
information technology systems and
operations;
• GIA’s responsibility for the independent
assessment of the Group’s corporate
governance, risk management and
internal control processes. The Head of
GIA reports directly to the Chair of the
BAC;
• The reviews by the Board Audit
Committee on the scope, nature and
independence of the work of undertaken
by GIA;
• The reviews by the Board Audit
Committee of progress with the internal
audit programme of work. The Head
of GIA reports regularly to the BAC.
The BAC also reviews the Interim and
Annual Report and the nature and
extent of the external audit. There
are formal procedures in place for the
external auditors to report findings
and recommendations to the Audit
Committee. Any significant findings or
identified risks are examined so that
appropriate action can be taken;
• Under the Group’s Internal Control
Framework, there are divisional control
frameworks in place within each
business unit under which Executive
Management reviews and monitors, on
an on-going basis, the controls in place,
both financial and non-financial, to
manage the risks facing that business;
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Permanent TSB Group Holdings plc - Annual Report 2022 • The monitoring of regulatory compliance
within the Group by the Head of
Regulatory Compliance who reports
to the CRO and who also provides
regular updates to the Board Risk and
Compliance Committee; and,
• Established systems and procedures to
identify, control and report on key risks.
Exposure to these risks is monitored
at Board level by the Board Risk and
Compliance Committee. As a standing
item on both Board Risk and Compliance
Committee and Board agendas, the CRO
regularly reports on all material issues
related to activity within the Group’s
risk and control environment. The CRO
is a member of ExCo, Chairs the Group
Risk Committee and has reporting lines
to the CEO and Chair of Board Risk and
Compliance Committee.
The Board Risk and Compliance
Committee reviews the compliance
and risk management programmes and
monitors the risk profile of the Group. The
Board Risk and Compliance Committee
supports the Board in carrying out its
responsibilities for ensuring that risks are
properly identified, reported, assessed and
controlled, and that the Group’s strategy is
consistent with the Group’s Risk Appetite.
The Remuneration Committee is
responsible for oversight of the Group’s
remuneration and reward strategies.
It ensures the remuneration strategy
is aligned with the Group’s appetite for
risk, business strategy, values, culture
and ambitions, and oversees Senior
Management reward.
The Nomination, Culture and Ethics
Committee is responsible for the
culture, behaviour, ethics and reputation
management oversight in the Group.
The Group is committed to nurturing a
Speak Freely culture where it is safe and
acceptable for all to raise any concerns
that they may have about practices,
processes or behaviours that do not meet
these standards or align with the Group’s
Ambition, Purpose and Values. The
Group’s Speak Freely Procedure protects
colleagues who wish to raise a concern,
or to make a protected disclosure, relating
to an actual or potential wrongdoing in
the workplace. Speak Freely focuses
on encouraging colleagues to raise
a concern via a number of different
channels by creating a psychologically
safe environment in which to do so. In
addition, the Group also has in place a
Colleague Conduct Policy, which outlines
the standards of responsibility and ethical
behaviour to be observed by all the Group’s
employees.
Internal Control over Financial
Reporting
The Group operates a Financial Control
Framework (a divisional framework of
the Group’s Internal Control Framework)
over financial reporting to support the
preparation of the consolidated financial
statements. The effectiveness of the
Group’s systems of control over financial
reporting are reported on to the Board
Audit Committee on an annual basis. The
main features are as follows:
• A comprehensive set of accounting
policies are in place relating to the
preparation of the interim and annual
financial statements in line with IFRS, as
adopted by the EU;
• A control process is followed as part
of the interim and annual financial
statements preparation, involving the
appropriate level of Management review
of the significant account line items,
and where judgments and estimates are
made, they are independently reviewed
to ensure that they are reasonable
and appropriate. This ensures that
the consolidated financial information
required for the interim and annual
financial statements is presented fairly
and disclosed appropriately;
• The Interim and Annual Report are
subject to detailed review and approval
through a process involving Senior and
Executive finance personnel;
• Summary and detailed papers are
prepared for review and approval by the
BAC covering all significant judgmental
and technical accounting issues together
with any significant presentation and
disclosure matters; and
• A GIA function with responsibility for
providing independent, reasonable
assurance to key internal committees
and Senior Management, and to external
stakeholders (regulators and external
auditors), on the effectiveness of the
Group’s risk management and Internal
Control Framework.
•
119
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Board Diversity Report
PTSB recognises the benefits of having a diverse Board and sees increasing diversity at Board
level as an important element in maintaining a competitive advantage.
Diversity
A diverse and inclusive culture is essential to the long-term success of Permanent TSB and enables the Group to respond to diverse
customer and wider stakeholder needs. Further details on the Group’s Organisational Culture, Diversity and Inclusion Programmes are
set out on page 36.
Board Diversity Policy
The Board has a Diversity Policy which is reviewed annually. The Board Diversity Policy sets the target for gender diversity and also sets
guidance on the appropriate mix of financial versus non-financial knowledge and experience on the Board as well as the geographic
location/background of Directors. The Policy also describes how the Board will consider other key metrics when carrying out succession
planning activities or Board recruitment/refreshment.
The Group recognises the benefits of having a diverse Board and sees increasing diversity at Board level as an important element in
maintaining a competitive advantage.
A diverse Board includes and makes good use of differences in the knowledge, experience and skills (in particular those identified as
relevant to the business and culture of PTSB) as set out in the Board Suitability Matrix, including regional and industry experience,
education and professional experience, together with nationality, gender, age, cognitive and personal strengths and other qualities
of Directors. These differences are considered in determining the optimum composition of the Board, and where possible, balanced
appropriately. In December 2022, the Board Diversity Policy was reviewed and updated setting the following target and guidance
principles for 2023:
Area of Diversity
Rationale
Guidance or Target
Knowledge
Experience and
Skills
The Board aims to engage a broad set
of qualities and competencies when
recruiting Board members to achieve a
variety of views and experiences and to
facilitate independent opinions and sound
decision-making within the Board. See
also below:
Target:
At least 50% of Non-Executive Directors, the Board Chair
together with the Chairs of the Audit and Risk and Compliance
Committee should have core relevant banking and/or financial
services knowledge and experience (obtained working for a
financial institution or through the provision of services to a
financial institution).
Board Suitability
Matrix
The Board regularly reviews the
knowledge, experience and skills of the
Board to ensure they are aligned with the
current, emerging and future needs of the
Bank.
Note:
Knowledge examines achievement in education,
training and practice.
Experience looks at the practical and professional
experience gained.
Skills focus on personal attributes, how the person is
capable of behaving and acting.
Knowledge and Experience:
Skills:
• Retail and SME Banking
• Authenticity
• Culture and Ethics
• Decisiveness
• Sustainability
• Communication
• Customer Advocacy/
• Judgement
Experience
• Accounting/Auditing
• Risk Management
• Governance
• Technology (including
Cyber/IT Resilience)
• Organisational Change
• Strategy Development
• Legal and Regulatory
• Capital Markets
• Customer and Quality
Orientated
• Leadership
• Loyalty
• External Awareness
• Persuasive
• Teamwork
• Sense of Responsibility
•
•
Integrity
Independence of Mind
120
Permanent TSB Group Holdings plc - Annual Report 2022 Area of Diversity
Rationale
Guidance or Target
Gender
The Board understands that gender is an
essential component of Board diversity
facilitating a more independent mindset
at Board bringing together richer more
informed debate and challenge
Target 1:
The Board will be gender balanced (50%between Directors
identifying as male or as female). Where the Board has an
uneven number of Directors, a rounding down of the majority
gender is deemed to have achieved balance.
Target 2:
At least one of the Chair, Chief Executive Officer, Senior
Independent Director or Chief Financial Officer) positions
will be held by a female (including those self-identifying as a
female).
Target:
Between 20% - 30% of the Non-Executive Directors should
be in a position to draw on current or recent knowledge and
experience obtained from having lived outside of Ireland.
Guidance:
For each Director appointment, the Board will consider
age and other demographics of the Group’s customer base
together with relevant Board composition benchmarking data
to inform the design of the role profile. Consideration will also
include latest Irish census data on non-white ethnic minorities.
Geographic
Location
Age and Ethnicity
The Board should comprise of directors
who understand the social, economic,
business and cultural environment in
which the Group operates. However,
the Board also understands the benefit
of having an ‘external’ perspective, to
draw learnings and insights from other
jurisdictions and cultures to support
independent and effective decision
making.
The Board of PTSB recognises that in
addition to tenure of knowledge and
experience, value should also be placed
on the timing of when knowledge and
experience is acquired. This is ever more
relevant where latest rapidly evolving
developments in technology, innovation
and customer behaviour will play an ever
greater role in delivering the Group’s
Ambition. The Board also recognises the
importance that diversity on the Board
brings particularly given the diverse age
and ethnic profile of the Group’s customer
base.
The Board Diversity Policy is published on the Group Website: https://www.permanenttsbgroup.ie/document-centre/year/governance
121
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 All candidates for appointment need to
demonstrate the financial literacy required
for a proper understanding of the Group’s
activities and associated risks. The
Nomination, Culture and Ethics Committee
seeks to ensure that a proportion of
the Board has a deep understanding of
financial products and has established
guidelines to ensure that Board candidates
are selected on merit, based on their skills,
competencies, qualifications and ability to
commit sufficient time to the role.
2022 Board Diversity Progress
At 31 December 2022 the Board gender
diversity ratio stood at 42% (40%for Non-
Executive Directors). With planned Board
changes, it is expected the target of 50%
will be achieved at the conclusion of the
AGM in May 2023 when the Board gender
diversity ratio will be 56% for both Board
and Non-Executive Directors. The Board
achieved its objective of 50% of Non-
Executive Directors having banking and/
or financial experience and is satisfied that
all Directors have attained the required
financial literacy threshold.
Corporate Governance Statement
Board Diversity Report (continued)
Objective of Board Diversity Policy
The Group recognises the benefits of
having a diverse Board and sees increasing
diversity at Board level as an important
element in delivering on the Group’s stated
Purpose and Ambition. The Board aims
to engage a broad set of qualities and
competences when recruiting Directors to
achieve a variety of views and experiences
and to facilitate independent opinions and
sound decision-making within the Board.
All Board appointments are made on merit,
in the context of the aggregate knowledge,
experience and skills that the Board as a
whole requires to be effective.
The Nomination, Culture and Ethics
Committee discuss and agree annually
all measurable objectives for achieving
diversity on the Board and recommends
them to the Board for adoption. When
setting diversity objectives, the
Nomination, Culture and Ethics Committee
considered diversity benchmarking
results and latest regulatory guidance
published by competent authorities, the
EBA, or other relevant international bodies
or organisations. At any given time, the
Nomination, Culture and Ethics committee
may seek to improve one or more aspects
of its diversity and measure progress
accordingly.
How the Board Diversity Policy was
implemented during 2022
All Board appointments are made on merit,
in the context of the knowledge, experience
and skills that the Board as a whole
requires to be effective. The balance and
mix of appropriate knowledge, experience
and skills of Non-Executive Directors are
taken into account when considering a
proposed appointment and is reviewed
annually by the Board.
The Board Nomination Culture and Ethics
Committee carries out an evaluation of
Board performance annually. A part of
that review considers the succession
planning, composition and diversity
needs of the Board. In November 2022,
the Committee carried out a detailed
analysis of Board and Committee
composition, Board Independence levels,
Board diversity analysis, review of the
Board Suitability Matrix (desired mix of
knowledge, experience and skills) and
planned retirements over the following
two year period. This comprehensive
assessment allows that the Board to plan
for knowledge, experience, skills and other
diversity needs of the Group.
The behaviours likely to be demonstrated
by potential Non-Executive Directors
are also considered when interviewing
for new appointments to ensure that
an environment in which constructive
challenge is expected and achieved, is
maintained in the Boardroom. In reviewing
Board composition, the Nomination,
Culture and Ethics Committee considers
the benefits of diversity, including
gender, and looks to ensure that there
is appropriate representation from
other industry sectors. In addition to
core financial services knowledge and
experience, the Board also can draw from
expertise in law, technology, change and
risk management, customer advocacy,
aviation, healthcare, communications and
charities sector strategy development and
governance.
The Board considers the skills, experience
and expertise, including education
and professional background, in areas
relevant to the operation of the Board.
122
Permanent TSB Group Holdings plc - Annual Report 2022
2022 Board Diversity
Gender
Board Diversity by Tenure
0-3 years
Board Diversity by Tenure
3-6 years
Board Diversity by Tenure
6-9 years
Board Diversity by Tenure
9+ years
Nationality
Age Profile
1
3
Irish
British
German
1
2
8
4
5
40-49
50-59
60-69
70+
Independence
Executive & Non-Executive Directors
2
2
2
8
10
Independent Non-Executive Directors
Non-Executive Directors
Non-Executive Directors
Executive Directors
Executive Directors
Note: Statistics are at year end 2022 and do not include the appointment of Julie O’Neill on the 17 January 2023
123
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Board Diversity Report (continued)
2023 Board Diversity Priorities
Area of Diversity
Board Objective
2022 Board Action
The Board remains committed
to gender diversity on the
Board.
• Board Gender Diversity Target increased from 30% to 50%.
• Encourage initiatives that promote broader inclusive gender diversity
across the Group, in line with the Organisational Culture, Diversity and
Inclusion Programmes.
• The Board Diversity Policy has been updated to ensure the Board has
a clear line of sight on the diverse makeup of the Group’s colleague and
customer base when considering appointments to the Board.
• Customer diversity metrics such as age, ethnicity and gender will
influence how the Board thinks about its own construct.
• Consider the aspects of diversity relevant to the operation of the Group,
such as gender, age, cognitive, social/ethnic background, personal
strengths, education and professional background;
• Ongoing review of the Board Diversity Policy to ensure all relevant
aspects of diversity are included in the Policy;
• Ongoing review the Board Suitability Matrix to ensure that the diverse
range of knowledge, skills and experience required by the Group is
represented at Board level; and
• Encourage initiatives that promote broader inclusive gender diversity at
Board level.
• Maintain a minimum of 50% of Non-Executive Directors, including the
Board Chair, together with the Chairs of the Audit and Risk Committees,
to have banking and/or financial experience and this will also be taken
into account when recommending appointments;
• Between 20% - 30% of the Non-Executive Directors should be in
a position to draw on current or recent knowledge and experience
obtained from having lived outside of Ireland;
• Retain the requirement that all candidates for appointment need to
demonstrate the financial literacy required for a proper understanding
of the Group’s activities and associated risks;
• Ensure that a proportion of the Board has a deep understanding of
financial products;
• Review Board Recruitment and Selection procedures, to ensure Board
candidates are selected on merit, based on their knowledge, experience
and skills, and have the ability to commit sufficient time to the role, with
due regard to relevant aspects of diversity; and
• Undertake an assessment of individual and collective suitability, taking
into account relevant aspects of diversity to determine the continued
individual and collective suitability of members of the Board.
• Review Succession Plans of the Board and Senior Executives
• Ensure the Group pipeline of successors takes account of the Group’s
diversity measures and ambitions.
Gender
Alignment to
customer base
Board Diversity
Policy
Board
Recruitment and
Selection and
Suitability
The Board acknowledges the
Group has a diverse customer
base and should take account
of same in considering the
diversity requirements of the
Board.
The Board recognises that
there are many aspects of
diversity such as social and
ethnic backgrounds, gender,
cognitive and personal
strength, skills and experience,
and the importance of
ensuring wider diversity
is considered for Board
appointments.
The Board remains committed
to having a diverse range of
knowledge, experience and
skills, including education
and professional background,
in areas relevant to the
operation of the Board, while
ensuring that the recruitment
and selection process for
members of the Board is an
open and fair process.
Board Succession
Planning
The Board is responsible for
overseeing succession plans
for the Board and Senior
Executives.
124
Permanent TSB Group Holdings plc - Annual Report 2022
Corporate Governance Statement
Board Audit Committee
The Audit Committee ensures that the financial and internal
control policies, practices and decisions of the Group
are carried out appropriately, and are properly aligned to
strategy and the interests of its Shareholders.
Dear Shareholder,
I am pleased to present my report as Chair
of the Board Audit Committee. 2022 was
a key year for the Group in the context of
the Ulster Bank transaction which I will
come to shortly. I was pleased with the
internal appointment of Nicola O’Brien as
the Group’s Chief Finance Officer. Nicola
is an experienced finance professional
with over 20 years’ experience operating
at a senior level within the Retail Banking
sector in Ireland. Nicola brings a strong
understanding of the commercial,
strategic, operational, financial and
regulatory requirements of Banking. I
look forward to working with Nicola and
drawing on her considerable experience as
the Group continues to grow and expand
its business model. In that regard, I would
also like to thank Declan Norgrove for his
valuable contribution as Interim Chief
Financial Officer over the past year.
As referenced earlier, a key area of focus
for the Committee during 2022 was the
technical analysis of the transaction
with Ulster Bank and in particular the
application of business combination
accounting under IFRS 3 to the acquisition
of elements of the Ulster Bank retail
and asset finance business. The key
judgements in the business combination
accounting was to determine if the
acquired set of activities and assets
met the definition of a business and
when controls transfers. Estimates and
judgments were also used to fair value
the net identifiable assets acquired in the
business combination. The Committee
provided ongoing oversight throughout
the year on the appropriateness of the
accounting treatment and the fair value
assessment.
During 2022, the Committee led a
comprehensive selection process to
identify new external auditors for the Group
as the existing auditors approach 10 years
in service. It was a competitive process and
I am pleased that the Group has, subject
to Shareholder Approval at the 2023 AGM,
agreed to appoint KPMG as the Group’s
new external auditors. KPMG will be in
situ to undertake the 2023 Interim review
and 2023 full year audit. The Committee
undertook careful monitoring during the
year to ensure that any non-audit work
undertaken by the short-listed firms did
not impede their independence.
Our Group Internal Audit function
developed and delivered an Internal Audit
Plan for 2022 which provided reasonable
assurance in relation to the key current and
emerging risks facing the Group, including
key strategic initiatives such as the Ulster
Bank transaction and our ongoing Digital
Transformation Programme. The Head
of Group Internal Audit provides ongoing
reporting to the Board Audit Committee
in relation to the outcome of their work
and also progress on actions taken by
Management to mitigate any issues
identified. During 2022, the GIA function
underwent a significant transformation
program to enhance the GIA methodology
and related processes and procedures.
This program of work is well progressed,
contributing to a continued evolution of
the risk assurance processes across the
Three Lines of Defence. A comprehensive
skills analysis and related recruitment and
training program was also completed by
the GIA team to ensure that the resourcing
of the function continues to reflect the
current and emerging risk profile of the
Group.
I have worked closely with the Chair of the
Board Risk and Compliance Committee
to ensure the work programme for both
Committees are aligned. In that regard,
the Board Audit Committee has taken on
additional responsibility for the monitoring
of internal control within the Group with
a quarterly review of the Group’s control
environment which provides analysis
of GIA audit issues, Compliance and
Conduct monitoring, and issues within the
operational and IT control environment.
I will continue to work closely with the
Chair of the Board Risk and Compliance
Committee to ensure the effectiveness of
both committees are maximised.
As the Committee now focusses on 2023
and beyond, particular attention will be
given to working closely with the Board
Risk and Compliance Committee on
assessing the impact of both rising interest
rates and cost of living on customers, and
the subsequent risk to loan impairment
that may arise therefrom. Another key
focus of the Committee will be preparing
the Group for enhanced sustainability
reporting under the EU’s Corporate
Sustainability Reporting Directive. This will
represent quite a challenge for the Group
as it evolves the requisite governance
architecture, reporting processes and
controls frameworks to support the
veracity of what will be reported and
assured.
On behalf of the Board Audit Committee
Ronan O’Neill
Chair, Board Audit Committee
125
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Board Audit Committee (continued)
Composition and Operation
The Board Audit Committee (‘BAC’) consists of five Non-Executive Directors. The
biographical details of each member are set out on pages 100 to 106. Neither the Board
Chair nor the CEO is a member of the Committee. The Board requires the Chair of the
BAC to have recent and relevant financial experience. The Chair of the Committee is
responsible for leadership of the Committee and for ensuring its effectiveness. Together
the members of the Committee bring a broad and diverse range of relevant knowledge
and experience contributing to effective governance.
The members of the BAC meet together at the start of each scheduled meeting in
private session. The head of GIA is then invited to join the meeting so that the Committee
can review and discuss internal audit activity without Senior Management present.
Subsequent attendance by the CEO, CFO, Board Chairman, external auditors and others
is by invitation only and managed to ensure the ongoing independence of the Committee.
The Board requires that a minimum of one member is common to the BAC and the Board
Risk and Compliance Committee. Donal Courtney and Anne Bradley are members of both
Committees.
2022 Committee Meeting Attendance
Member
Ronan O’Neill*
Donal Courtney
Paul Doddrell
Anne Bradley
Andrew Power
* Chair
Appointed
02 Nov 2021
03 Oct 2018
26 Nov 2020
30 Mar 2021
26 Sep 2016 -
Ceased
-
-
-
-
Number of
Years on the
Committee
1.2
4.3
2.1
1.8
6.3
2022 Meeting
Attendance
13/13
13/13
13/13
13/13
13/13
report received by the Committee from the
external auditors and were discussed in
the Committee’s meeting with the external
auditors.
The BAC also had regard to the
assessment of internal control over
financial reporting, details of which are
outlined in the Risk Management and
Internal Control section of the Corporate
Governance Statement.
Matters considered by the
Committee in 2022
During 2022, the Committee spent a
significant amount of time considering
those issues set out in the Significant
Financial Reporting Judgments and
Disclosures and, recommending for
approval to the Board, the Annual Report
and Interim Report.
During 2022, the Committee also:
• Reviewed GIA activity throughout the
year, including a review of performance
against the 2022 internal audit plan;
• Analysed Business Combination
Accounting Treatment for the Ulster
Bank business acquisition
Role and Responsibilities
The BAC monitors the effectiveness and
adequacy of internal control, internal
audit and IT systems and reviews the
effectiveness of risk management
procedures, in addition to reviewing
the integrity of the Company’s internal
financial controls. The BAC reviews
the arrangements by which staff of the
Group may, in confidence, raise concerns
about possible improprieties in matters
of financial reporting or other matters.
The BAC monitors and reviews the
effectiveness of the Group’s Internal
Audit (GIA) function and also considers
the external auditor’s independence and
objectivity and the effectiveness of the
audit process. The BAC also reviews
discoveries of fraud and violations of laws
and regulations as raised by the head of
GIA.
The BAC monitors the integrity of the
Financial Statements of the Company,
reviewing significant financial reporting
judgements contained therein, to ensure
that they give a “true and fair view” of
the financial status of the Group and to
recommend to the Board whether to
approve the Annual and Interim Reports
and also to recommend to the Board that it
believes that the Annual Report, taken as a
whole, is fair, balanced and understandable
126
and provides the necessary information
for shareholders to assess the Group’s
position, performance, business model and
strategy.
• Reviewed the accounting and regulatory
treatment of the sale of loan assets, in
line with IFRS;
• Reviewed the Group’s Pillar 3 policy and
In considering whether the Annual Report
is fair, balanced and understandable, the
Committee reviewed the Annual Report
and considered whether the Financial
Statements were consistent with the
financial review elsewhere herein. The
Committee also reviewed governance
and approval processes in place within
the Group as they were relevant to the
Financial Statements. These included the
completion by Management of disclosure
checklists to ensure all required disclosures
required by applicable company law, listing
requirements and accounting standards
are included in the draft Annual Report
which was reviewed by various Executives
and Management of the Group.
The Committee also had regard to the
significant judgements relating to the
Financial Statements that are set out in
this report. Each of these significant issues
were addressed in papers received by the
Committee from Management and in the
disclosures;
• Reviewed External Auditor
Independence and Effectiveness;
• Approved a new Special Investigations
Framework;
• Reviewed the continued recognition of a
Deferred Tax Asset (DTA) on tax losses
carried forward;
• Approved changes within International
Financial Reporting Standards (IFRS)
and International Accounting Standards
(IAS);
• Reviewed impairment provisions;
• Reviewed control environment reports
• Reviewed the effectiveness of internal
control over financial reporting;
• Approved the Internal Audit Plan for
2023;
• Reviewed the action plan to address the
findings of an External Quality Review
of GIA.
• Reviewed the governance and
approval arrangements underlying
the fair, balanced and understandable
assessment of the Annual Report;
Permanent TSB Group Holdings plc - Annual Report 2022 • Assessed the Longer Term Viability and
Going Concern Statements;
• Reviewed the disclosures on compliance
with the UK Corporate Governance Code;
• Reviewed provisions including legacy,
legal and compliance liabilities;
• Reviewed the basis, background and
level of Non-Audit fees paid to PwC; and
• Reviewed and recommended to Board
the appointment of KPMG as External
Audits subject to shareholder approval at
the 2023 AGM.
Financial Reporting and Significant
Financial Judgments and Disclosures
During the year, the BAC reviewed the
External Auditors’ findings, and the
following significant financial judgments
made, the related disclosures for the 2022
Financial Statements as set out on the
current and the following page.
IFRS 3 Business Combination Accounting
(BCA)
One of the key judgement and estimates
for 2022 was in relation to the accounting
for the acquisition of certain elements
of the Retail, SME and Asset Financing
activities, including 25 branch properties
and staff, of Ulster Bank Ireland DAC
(“Ulster Bank”) in the Republic of Ireland.
IFRS 3 Business Combination Accounting
(BCA) was applied to the acquisition
which resulted in a gain on bargain
purchase being recognised in the income
statement. The Committee reviewed the
technical accounting paper presented
by Management outlining the below
accounting treatment of the acquisition
and is satisfied that it is in line with IFRS 3.
Management assessed whether the
acquired set of activities and assets
constituted a business and ensured that,
at a minimum, the inputs and substantive
processes when applied to the inputs
were critical to the ability to continue
producing outputs. Management consider
substantive processes to include strategic,
operational and resource management
processes in order to be considered a
business. These processes are usually
documented but the intellectual capacity of
an organised workforce with the necessary
skills and experience may also provide
the necessary processes to determine
the acquired set of assets and activities
as a business. Management determined
that the acquisition of the organised
workforce from Ulster Bank that included
key individuals with the necessary skills
and experience to direct the substantive
processes within credit risk, underwriting
and customer relationship management
met the requirements of IFRS 3.
Committee was satisfied that the provision
and related disclosures in the financial
statements were appropriate.
IFRS 3 requires that the net identifiable
assets acquired as part of the business
combination are recognised at fair value
on the acquisition date. The fair value
measurements were performed by
independent professional valuers having
appropriate qualifications and recent
experience in the fair value measurement
of loan portfolio categories being valued.
A discounted cash flow model was used to
estimate the fair value of the acquired retail
mortgage assets. This included calculating
the expected contractual cash flows of
the assets and applying the following to
the portfolio of assets; prepayment rate,
redemption rate, transition rate (from
fixed to variable rates and vice versa),
probability of default (PD) and loss given
default assumptions, servicing cost, risk
weights based on the asset characteristics
and a discount rate based on cost of
funding, capital and targeted capital ratio.
Management determined that the fair
value of the net identifiable assets met the
requirements of IFRS 3.
Expected Credit Loss Provisions
The Committee considered the Group’s
methodology including assumptions and
parameters for generating the Group’s
allowance for Expected Credit Loss (ECL)
for its secured portfolios. The Committee
discussed with Management in detail any
changes and revisions made to the Group’s
IFRS 9 ECL models, macro-economic
scenarios, significant increase in credit
risk, and post model adjustments.
Multiple scenarios
The Committee reviewed and approved
the macro-economic scenarios for use in
IFRS 9 ECL estimation, which included the
central scenario used for financial planning
purposes, a more favourable scenario, and
an adverse scenario.
Expert credit judgements
At 31 December 2022, the impairment
provisions included €137 million of
Management’s adjustments to modelled
outcomes. A key focus of the Committee
during the year was an assessment of the
level and rationale for such adjustments.
The Committee concluded that a robust
governance framework existed to monitor
provisioning adequacy and that the
assumptions and judgements applied
by Management were appropriate. The
Recognition and Recoverability of
Deferred Tax Assets
The Committee considered the extent of
DTAs recognised by the Group in respect
of unutilised tax losses, and in particular,
the future profits of PTSB against which
losses may be utilised in future years.
The Committee noted that the Group’s
performance and strategic outlook has
improved, as outlined in more detail
under “Going Concern” and “Longer Term
Viability” below.
Accordingly, in line with the requirements
of IAS 12 “Income Taxes,” Management
have formed the view that the carried
forward tax losses within PTSB could
be utilised against future profits which
will be generated by PTSB. This requires
significant judgments to be made about
the projection of long-term profitability
because of the period over which recovery
extends.
Having considered the above, the
Committee agreed with Management’s
assessment that it was probable that the
level of DTAs recognised in the financial
statements at 31 December 2022 would be
recovered. The Committee noted that IFRS
does not allow for the DTA recognised to
be discounted notwithstanding that it will
likely take a significant number of years to
be fully recovered.
Impairment review of the Group’s
subsidiary undertaking
The Company carries its investment in
its subsidiary undertaking at cost less
impairment and reviews whether there
is any indication of impairment at each
reporting date. Impairment testing involves
comparing the carrying value of the
investment to its recoverable amount. The
recoverable amount is the higher of the
investment’s fair value or its value in use
(VIU). An impairment charge arises if the
carrying value exceeds the recoverable
amount.
Management provided the Committee
with a paper that detailed the recoverable
amount of the investment. The Committee
reviewed the paper and calculations and
is satisfied with the recoverable value of
the subsidiary and that no impairment was
required.
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Board Audit Committee (continued)
The Committee also considered the
appropriateness of a write-back of
previous impairment charges taken over
the last number of years on the investment
in subsidiary. Both external and internal
factors indicated that there had been a
significant change in the value in the asset,
and on the basis that the VIU calculation
provided sufficient headroom, a full
impairment write back of €697m was
approved by the Committee in the PTSBGH
company accounts.
IT Access
Certain matters in relation to IT access
controls have been communicated to the
BAC through the external audit process.
The Committee is however satisfied there
are sufficient mitigating controls in place
from a financial reporting perspective.
Going Concern
Note 1 of the financial statements includes
details of the going concern of the Group
and Company, which outlines the Directors’
view that the Group will continue as a going
concern for a period of 12 months following
the signing of this report.
In making the judgment, the Committee
was provided with detailed papers
containing Management’s considerations
of the risks and uncertainties as they may
pertain to going concern. The Committee
reviewed these judgments, and agree
with Management’s view that the Group
continues on a going concern basis and
that there are no material uncertainties.
Longer Term Viability
In accordance with the requirements of
the UK Corporate Governance Code, the
Directors are required to issue a viability
statement of the prospects of the Groups
taking into account the Group’s current
and projected financial position taking
in account the principal risks facing the
Group.
The period over which we confirm longer-
term viability
The Directors have assessed the viability
of the Group over a three-year term which
falls within the time horizons considered
within the various strategic planning and
scenario testing frameworks employed by
the Group. The Directors are satisfied that
this is an appropriate period of assessment.
Assessing the governance and prospects
of the Company and Group
In making this assessment, the Directors
have assessed the key factors that are
128
likely to affect the Group’s business model
and medium term plan which have been
stress tested and sensitised for a downside
scenario to reflect the challenges that the
Group is facing primarily on the Group’s
capital, solvency and liquidity position
while taking into account other principal
and emerging risks.
The Board has reviewed the medium term
plan and the BRCC reviewed the outputs
from stress testing of capital and liquidity
positions both pre and post management
actions.
The Directors have carried out a robust
assessment of the emerging and principal
risks facing the Group, including those
that would threaten its business model,
future performance, solvency or liquidity.
The stress testing is designed to explore
the resilience of the Group to the potential
impact of principal risks set out in the
Annual Report, including in particular
funding and liquidity, capital adequacy,
the economic environment, regulatory
risks and or a combination of these risks.
A description of the Group’s principal risks
together with the Group’s approach to risk
identification and control are set out in the
Risk Management section.
The medium term plan is reviewed annually
and with increased frequency when
necessitated by significant changes in the
external environment and is approved by
the Board each year.
The medium term plan closely aligns to
Group’s Risk Appetite Statement and
Risk Management Framework and details
the Group’s future profitability, cash flow
projections, capital requirements and
the Group’s key performance measures.
Management’s performance against
the medium term plan is reviewed on an
ongoing basis by the Board.
The Group made a profit for the 2022
financial year. While the Group remains
strongly capitalised and has significant
liquidity at the year-end, the future
projections in the medium term plan, which
were sensitised for a downside scenario
indicate no breaches in either regulatory
capital and liquidity positions in the viability
period of assessment to December 2025.
The assumptions underpinning the stress
testing to determine the resilience of the
Group’s balance sheet, profitability and
robustness of the business model were
significantly conservative. While the
downside scenario marginally pushes out
profitability, there were no breaches of
regulatory requirements with a marginal
recourse to internal buffers in the viability
period.
There are certain key assumptions that
are critical to the viability of the Group and
these are outlined below:
Funding & Liquidity
The Group continued to have sufficient
liquidity throughout 2022, and continues to
undertake initiatives to improve its liquidity
position in the areas of deposits, collateral
optimisation, and wholesale markets
activity.
A key assumption in determining the longer
term viability is that the Group will continue
to be able to access the required liquidity
and funding across all channels during the
period of assessment.
The Directors and Management are aware
that the Group’s ability to monetise its
contingent counterbalancing capacity is
dependent on the underlying collateral
remaining eligible.
Our funding plans assume, based on our
interaction with wholesale markets and
deposit trends, that the required liquidity
and funding will be available to the Group
over the medium term.
Capital Adequacy
The Group made a profit for the year
ended 31 December 2022, and expects
to remain profitable in the medium
term. Directors and Management have
reviewed the Medium Term Plan (MTP)
and based on this, the near-term macro-
economic conditions of the country and the
resolution of legacy issues, the Directors
and Management are satisfied that the
Group is well positioned to deliver profits in
future years.
The Directors and Management have
considered the Group’s forecast capital
position, including the potential impact of
further deleveraging and a deterioration
in economic conditions as might arise.
The Group expects to be in a position
to meet its minimum regulatory capital
requirements in the period to 2025.
Confirmation of longer-term viability
Based upon our assessment of the
above, the Directors have a reasonable
expectation that the Group and Company
will be able to continue in operation and
Permanent TSB Group Holdings plc - Annual Report 2022 meet its liabilities as they fall due over
the three period of their assessment to
December 2025.
ethical and professional guidance and that,
in their professional judgment, they are
independent of the Group.
Provisions for Liabilities
The Committee considered the provisions
made in the Financial Statements in order
to assess the appropriateness of the
underlying liabilities.
Management presented a paper outlining
the requirements of IAS 37 and the basis of
the provisions proposed. The Committee is
satisfied that the provisions represent the
best estimate of the potential liabilities at
31 December 2022.
Accounting Treatment of Project
Glenbeigh IV
The key accounting requirements for
Project Glenbeigh IV follow the same
principles that the Committee considered
in the prior year in relation to Project
Glenbeigh III. Management assessed
the transaction, considering transfer of
contractual rights and transfer of risks
and rewards. The Committee reviewed
the technical accounting paper presented
by Management outlining the accounting
treatment of the transaction and is
satisfied that it is in line with IFRS 9.
Relationship with External Auditors
The Group’s External Auditors are PwC who
were appointed by shareholders in 2013.
The BAC provides a link between the Board
and the external auditors, independent of
the Company’s Management. The external
auditors regularly attend BAC meetings
and the Committee meets with the external
auditors at least once a year without
Management present to discuss their remit
and any issues arising from the audit.
The BAC reviewed the external audit plan
prior to the commencement of the 2022
audit. The BAC met with the external
auditor to review the findings from the
audit of the Group financial statements.
The BAC has an approved policy on the
provision on non-audit services by the
external auditor. The policy seeks to ensure
that processes are in place to make sure
that the independence and objectivity
of the external audit process is not
compromised. This includes monitoring the
nature and extent of the services provided
by the external auditor through its quarterly
review of fees paid to the external auditor
for audit and non-audit work, seeking
confirmation from the external auditor
that they are in compliance with relevant
The BAC reviews all fee arrangements with
the external auditor. Fees paid in respect
of audit, other assurance services, tax
advisory services and non-audit services
are outlined in note 8 to the financial
statements.
Other assurance services are services
carried out by the auditors by virtue of their
role as auditors and include assurance
related work, reporting to the regulator
and other assurance services. In line with
best practice, the auditors do not provide
services such as system design and
valuation work which could be considered
inconsistent with the audit role.
The amount of fees payable to external
auditors for their audit services for the year
2022 was €1.4m (excluding VAT) payable
to PwC Ireland. €0.9m (excluding VAT)
was paid in respect of non-audit services,
which relate to various assurance works.
The Company’s external auditor generally
performs these services.
The external auditor is required to rotate
audit partner every five years. The current
audit partner is John McDonnell who was
appointed in 2018. The Committee also
reviews the effectiveness, independence,
and objectivity of the external auditor. The
Committee also considered a paper by
Management regarding auditor’s efficiency
and effectiveness.
The BAC reviews the effectiveness of the
external auditor through discussion and
assessment of its performance. The BAC
has concluded that it was satisfied with the
external auditor’s performance.
A competitive tendering process for the
appointment of the external auditor took
place during the year and KPMG will be
appointed as external auditors subject
to Shareholder approval at the 2023
AGM. This development followed a Board
decision that the position of auditors
should be subject to regular, competitive
tendering. Due to the mandatory firm
rotation requirements, the Independent
Auditors, PricewaterhouseCoopers,
Chartered Accountants and Statutory
Audit Firm will resign from office once they
have completed the 31 December 2022
audit.
Review of Group Internal Audit
The BAC approves the annual work
programme for the GIA function and
ensures that it is adequately resourced
and has appropriate standing within the
Group. The Head of Internal Audit has a
direct reporting line to the Chair of the
BAC and the BAC meets with the Head of
Internal Audit on a regular basis without
the presence of Management. The BAC
receives regular reports from GIA, which
include summaries of the key findings of
each audit in the period. The BAC ensures
co-ordination between GIA and the
external auditor.
As set out in the Risk Management Section
a ‘Three Lines of Defence’ model has been
adopted by the Group for the effective
oversight and management of risks across
the Group, with GIA being the Third Line of
Defence.
In line with the Institute of Internal Auditors
(IIA) Standards (1300), the Head of GIA is
required to develop and maintain a quality
assurance and improvement programme
that covers all aspects of internal audit
activity. An internal quality assessment
must be completed on an annual basis
with an independent external assessment
undertaken every five years to evaluate
the Internal Audit Function’s conformance
with IIA Code of Ethics and Standards.
The Group’s Internal Audit function was
reviewed by the Chartered Institute of
Internal Auditors (IIA) in 2021 and an action
plan has been approved by the BAC to
address the findings of the IIA Report and
the BAC is kept apprised with updates on
same. The Committee regularly reviews
the available skills and resources within
the Internal Audit Function in order to
ensure that the function has the necessary
capabilities to provide a quality audit
service. Through these measures the Audit
Committee has assessed the effectiveness
of internal audit function and is satisfied
that the quality, experience and expertise
of the function is appropriate to the needs
of the Group.
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Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Nomination, Culture and Ethics Committee
The Board Nomination, Culture and Ethics Committee
evaluate the skills and characteristics required of Board
members and to ensure the tone on culture and leadership
is set from the top
Of course, a key focus for the Committee
this year was the transaction with Ulster
Bank and recognising how the merger of
two organisational cultures presented both
risk and opportunity. Ensuring alignment
and understanding of Our Culture Charter
amongst PTSB colleagues ahead of the
asset migration was a key focus for the
Committee. This facilitated development
of a culture migration ambition to integrate
our new Ulster Bank colleagues into the
Group, taking the best from the culture
they brought with them and creating a
‘One PTSB’ ethos as we moved forward
together to deliver on the Group’s Purpose
and Ambition
The Committee also had a busy year
in terms of assessing new Board
appointments and ensuring the suitability
and assessment process was effective and
produced candidates of the highest quality.
I am indeed very pleased with the calibre of
new Directors who have joined the Board in
2022 and early 2023
In 2022, the Committee oversaw the
annual performance evaluation of the
Board, its Committees and individual
Directors, to understand how effectively
they were performing while providing
assurance to the regulatory authorities,
stakeholders and investors of our
commitment to the highest standards of
governance and probity. The Committee
also carried out a detailed assessment
of Board and Senior Management
succession plans, a review of the Board
Committee structure and approval of a
new Board Diversity policy.
On behalf of the Nomination, Culture and
Ethics Committee
Robert Elliott
Chair, Board Nomination, Culture and
Ethics Committee
Composition and Operation
The Committee is composed of Independent Non-Executive Directors. The Board requires
that the Board Chair and the Senior Independent Director (SID) are members of the
Committee.
2022 Committee Meeting Attendance.
Member
Robert Elliott*
Ronan O’Neill
Ken Slattery
Marian Corcoran
Celine Fitzgerald
* Chair
Appointed
31 Mar 2017
26 Jul 2016
28 Sept 2020
30 Mar 2021
30 Mar 2021
Ceased
-
-
-
Number of
Years on the
Committee
5.9
6.5
2.3
1.8
1.8
2022 Meeting
Attendance
8/8
8/8
8/8
8/8
8/8
Dear Shareholder,
As Chair of the Board Nomination, Culture
and Ethics Committee, I am pleased to
present the report of the Committee for the
year ended 31 December 2022. This report
has been prepared by the Committee and
approved by the Board. The report provides
further context and insight into the role
and responsibilities of the Committee
together with a description of the work
undertaken during 2022 as set out below.
During the year I also informed the Group
of my intention to not seek re-election as
Chair of the Board when my term ends
in March 2023. It has been a privilege to
lead the Committee and the Board to the
position where it has principally completed
the Ulster Bank transaction and setting the
Group on a course for sustainable growth. I
wish my successor Julie O’Neill, the Board,
Management and colleagues of PTSB
every success in this regard.
The Committee continues to engage in
a meaningful way to shape and support
evolution of the Group’s espoused culture
which is to have a customer-centric, open,
inclusive, risk integrated, growth culture
characterised by integrity innovation and
accountability. In this regard we have heard
from many of the Group’s colleagues and
held discussion and debate on matters
such as the execution of the Group’s
sustainability strategy, continuing to
review and embed a psychologically safe
environment for colleagues to ‘speak freely’
and moving towards the next stage of the
Group’s Diversity and Culture maturity
journey. The Committee has also actively
engaged in understanding and supporting
colleague wellbeing through attendance at
People Experience Council (representative
group on culture evolution and colleague
wellbeing) discussing feedback from
management on the outcome of the
Group’s Every Voice Counts colleague
surveys and visiting colleagues in their
work locations.
130
Permanent TSB Group Holdings plc - Annual Report 2022 Responsibilities of the Committee
The Board Nomination, Culture and Ethics
Committee is responsible for bringing
recommendations to the Board regarding
the appointment of new Directors and
of a new Board Chairman. The Board
Chairman does not attend the Committee
when it is dealing with the appointment
of a successor to the Board Chairman.
Decisions on Board appointments are taken
by the full Board. All Directors are subject
to re-appointment by election by the
shareholders at the first opportunity after
their appointment. The Committee keeps
under review the leadership needs of the
Group, both Executive and Non-Executive,
with a view to ensuring the continued
ability of the Group to compete effectively
in the marketplace. The Committee is also
responsible for reviewing the effectiveness
of the Board’s operations, including the
Chairmanship and composition of Board
Committees. The Committee also has
responsibilities for supporting the Board on
oversight on culture, ethics, and reputation
management and employee engagement.
Succession Planning
The Committee undertakes regular
reviews of both Board and Board
Committee composition and ensures there
is a comprehensive approach to ensuring
there is regular and planned refreshment of
Board and Board Committee membership.
Arising from succession planning reviews
in 2021 and 2022 the Committee agreed
the need to identify replacements for
Non-Executive Directors Andrew Power
and Ken Slattery whose terms of office
were provisionally intended to conclude
at the AGM in May 2023. The Committee
also agreed the need to identify a new
Board Chair and fill the vacant CFO role
on the Board. As referenced on page 97,
Ken Slattery will remain on the Board until
the end of 2023 until his replacement has
been appointed. A process to identify a
candidate to replace the knowledge and
experience vacated by Andrew Power
remains ongoing with an expectation of an
appointment in the second half of 2023. Mr
Power will step down from the Board at the
2023 AGM.
Executive Committee Appointments
The Committee oversaw the appointment
of Nicola O’Brien as Chief Finance Officer
and member of the Executive Committee.
In her new role, Nicola is responsible
for leading, managing and overseeing
all finance related matters of the Group
and growing the Company’s financial
planning and analysis function to import
the commercial and operational value
of management information and build a
culture of transparency and accountability.
The Committee also oversaw the
appointment of David Curtis to the role
of Interim Chief Risk Officer (CRO) and
member of the Executive Committee.
In his new role, David is responsible for
Risk including independent oversight
of the Group’s enterprise-wide risk
management activities across all risk
types, thereby ensuring the fulfilment
of CRO responsibilities as outlined in the
Corporate Governance Code (Central
Bank of Ireland Code) and relevant EBA
guidance. In particular, the CRO owns the
Group’s Risk Governance Framework and
reports all material risks to which the Group
is or may become exposed. The CRO is
accountable for the Risk and Compliance
Management Framework within the Group,
and challenging its implementation by the
First Line of Defence.
Nicola O’Brien was appointed to the
Board as an Executive Director in August
2022 and in January 2023 Julie O’Neill
was appointed as an Independent Non-
Executive Director and Chairperson
designate. Full details of the appointment
process for both positions are set out
below.
Director Appointments
Board Chairperson Designate
In January 2022, Recruitment specialists
Odgers Bernston (Odgers) were formally
engaged to support the candidate
identification process. Neither the
Company nor any of the Directors have
any commercial relationship with Odgers
outside of recruitment services that are
provided from time to time to fill designated
Board and Senior Management positions.
The current Chair of the Board was not
involved in the recruitment process for his
successor nor was he in attendance at the
Nomination, Culture and Ethics Committee
for matters concerning the identification
and appointment of his successor.
The Nomination, Culture and Ethics
Committee approved a role profile to
support the generation of a long list of
candidates by Odgers. The draft role
profile sought candidates with extensive
experience in the role of a Chair together
with a financial services background. A
long list of 22 candidates was identified
by Odgers which was initially assessed
by the Senior Independent Director,
Company Secretary and Chief HR Officer
and Corporate Development Director.
The output of this assessment was then
presented by Odgers to the Nomination
Culture and Ethics Committee. Following
assessment by the Committee, a candidate
short-list of six individuals (three male,
three female) was created. It was agreed
that each of the candidates would be
interviewed by the Senior Independent
Director and two Non-Executive Directors.
Thereafter, it was agreed that 2-3
candidates would be progressed to a
second round interview again with the
Senior Independent Director and a further
two (different) Non-Executive Directors.
Following the withdrawal of two candidates
from the process (one male, one female
citing a change in personal circumstances),
four candidates attended first round
interviews with Ronan O’Neill, Marian
Corcoran and Donal Courtney supported by
the Company Secretary. These interviews
tested the candidate’s knowledge,
experience and skills against the role
profile.
Three candidates (two female, one male)
were brought forward to second-round
interview with Ronan O’Neill, Ken Slattery
and Celine Fitzgerald, supported by
Company Secretary and Chief HR Officer
and Corporate Development Director. The
interview approach adopted was scenario
based to seek to understand how the
candidate would react/deal with certain
scenarios/challenges in the role as Chair.
Following detailed assessment of the
three candidates, a recommendation was
brought to the Committee who agreed that
Julie O’Neill was the candidate who best
met the requirements of the role profile.
This position was then endorsed by the
Board and, following regulatory, approval
the candidate was appointed to the Board
on the 17 January 2023 and will take over
as Board Chair on the 31 March 2023.
Chief Financial Officer
In May 2021, recruitment specialists
Spencer Stuart were formally engaged
to support the process to identify a
suitable candidate for the role of Chief
Financial Officer (CFO). Neither the
Company nor any of the Directors have
any commercial relationship with Spencer
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Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
• Review of the effectiveness of the
Directors, the Board and that of its
Committees;
• Approval of the 2021 Board Evaluation
action plan and 2022 approach;
• Review of the size and composition of
the Board and that of its Committees;
• Consideration of workforce engagement
mechanisms under the UK Code;
• Review of Diversity and Inclusion,
Learning and Talent and Employee
Survey updates;
• Reviewed progress on the Group’s
Diversity and Inclusion and Organisation
Culture programmes of work; Review of
Corporate Affairs, Reputation Audit and
Stakeholder Engagement updates;
• Review of the Group’s Citizenship and
Sustainability Reporting
• Reviewed progress on the Group’s
Sustainability Strategy
• Reviewed a proposed Special
Investigations Framework before
submission to the Board Audit
Committee.
• Consideration of the IBCB DECiDE
Framework and ethical decision making
• Review of the Board Suitability Matrix;
and
• Oversight of the Group’s preparations for
the Individual Accountability Regime.
Corporate Governance Statement
Nomination, Culture and Ethics Committee (continued)
Stuart outside of recruitment services
that are provided from time to time to fill
designated Board and Senior Management
positions. Initially, a long list of candidates
(33) was generated. Thereafter the
shortlisting process was progressed
and four candidates (three male, one
female) attended a first round interview.
Three candidates were thereafter
selected to attend final round interview
and psychometric assessment. The
selection panel for the first and final round
interviews included a Board Independent
Non-executive Director, the Board Senior
Independent Director, the Board Audit
Committee Chair, the CEO and the Bank’s
HR Director. Following detailed assessment
of the three candidates a recommendation
was brought to the Nomination Culture and
Ethics Committee who agreed that Nicola
O’Brien was the candidate who best met
the requirements of the role profile. This
position was then endorsed by the Board
and, following regulatory approval, the
candidate was appointed to the Board on
the 4 August 2022.
Committee Composition
During 2022 the Committee undertook a
review of Committee composition in light
of changes to the Board and the need to
refresh the knowledge and experience of
the Board’s Committees. It is expected that
a number of changes to Board committee
composition will be made in the second
half of 2023 when two further Board
appointments are expected to be made.
No Director is a member of more than two
Board standing Committees.
Board Performance Evaluations
In 2022, the Committee oversaw the annual
performance evaluation of the Board and
its Committees and individual Directors,
to understand how effectively they were
performing while providing assurance to
the regulatory authorities, stakeholders
and investors of our commitment to the
highest standards of governance and
probity. The process undertaken for the
2022 annual Board performance evaluation
and the resulting recommendations are set
out in page 115 of this report.
As required under the UK Corporate
Governance Code, an externally facilitated
Board performance evaluation will take
place every three years. The last externally
facilitated evaluation of performance took
place in 2021; and the next scheduled
external Board evaluation will be conducted
on 2024 performance.
Other Matters considered by the
Committee in 2022
• Review of the succession plan for Board
and Senior Management positions
across the Group;
• Review of Talent Acquisition
Management;
• Review of its own terms of reference;
• Provided oversight to the Sustainability
Committee as a sub-committee of
the Executive Committee on reporting
to the Nomination Culture and Ethics
Committee on Responsible and
Sustainable Business matters;
• Approval of the recruitment process
and appointment for a number of Senior
Management positions;
• Review of the Group’s updated Culture
Charter
• Review on reports concerning the
Group’s reputation;
• Colleague Wellbeing spotlights
(including review of new Smart working
arrangements)
• Review and approval of Board Policies
(Diversity, Conflict of Interest,
Assessment and Suitability, Induction
and Training);
• Review and approval of the Group’s
Fitness and Probity Policy;
• Review and approval of the Group’s
Speak Freely Policy;
• Review of Colleague compliance with the
Group’s Code of Ethics policy;
• Review and approval of Board training
schedules;
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Permanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Risk and Compliance Committee
The Committee supports the Board in ensuring
risks are properly identified, reported, assessed,
and controlled, and that the strategy is
consistent with risk appetite.
Dear Shareholders,
As Chair of the Board Risk and Compliance
Committee (the “Committee” or “BRCC”),
I am pleased to report on the Committee’s
activities for the year ended 31 December
2022. The Committee had a busy schedule
of meetings in 2022 meeting 14 times.
2022 was an exceptional year for the Group
as the transaction with Natwest to acquire
certain parts of the Ulster Bank business
(“Project Sun”) was progressed to Principal
Completion providing significant growth
opportunity for the Group and ensuring
continuity of service to Ulster Bank
customers. This significant transaction
was executed against a backdrop of intense
geopolitical and economic uncertainty,
and the Committee supported the Board
in overseeing the risks and ensuring
the appropriate controls and mitigating
actions were put in place. Cross committee
membership between the Committee
and Board Sun Committee (established
in 2021 to provide guidance and support
to the Board and Management) and
additional “leaning in” by individual
Directors on their areas of expertise,
ensured a robust governance framework
with proactive oversight. Areas of focus for
the Committee included the impact of the
Project Sun transaction on capital levels
over the Group’s five year planning period,
CTF and AML risk, material outsourcing,
resourcing and organisational capacity
(for the end state Bank), enterprise-wide
planning, dependency management and
prioritisation. The Committee played a
central role in assessing the programme
risks and how these would be mitigated
and received regular updates on risk
assessments and inflight reviews carried
out by the Three Lines of Defence.
The Committee was also focussed on
monitoring the impact of a number of
external factors such as the conflict
in Ukraine, the international financial
sanctions regime and elevated cyber
security alert status and oversaw the
work of management to ensure systems
and controls were in place to mitigate the
associated risks. A further area of focus for
the Committee was the Group’s customers;
both existing customers and new
customers transferring from Ulster Bank
and KBC. The Committee provided both
support and challenge to Management
on customer service levels, customer
impacting errors, wait times for customer
assistance and management of customer
complaints. The Committee was mindful
of rising consumer costs and interest rates
and the potential impact this could have
on the Group’s impairment line. While
the overall outlook for the Irish economy
remains broadly positive, customer loan
repayment behaviours will be a key are of
focus for the Committee in 2023.
Advising and supporting the Board in
monitoring Risk Governance and ensuring
the Group’s risks are properly identified,
reported and assessed continued to be a
key focus for the Committee during 2022.
This has included extensive oversight
on the embedding of a new automated
risk management system for the Group
which will enhance the process of risk
identification and control at the Group.
There was ongoing focus on the Group’s
Operational and IT resilience, its change
management capability and prioritisation
and planning of resources/skills against
the backdrop of increased demand on
resources and the need to ensure there
was an integrated planning approach.
Indeed a key focus in 2023 will be the
implementation of Central Bank Guidelines
on Operational Resilience together with
preparation for the implementation of the
Digital Operational Resilience Act (DORA).
The Committee has continued to oversee
and challenge First Line in the embedding of
operational risk and ensuring Second Line
provide effective oversight, guidance and
challenge to First Line in that regard. The
Committee requested updates from a number
of First Line functions on the embedding
of risk awareness and effective control
environment within business functions.
The Group has continued to strengthen the
control environment within the Group during
2022. The Committee carried out a 2022
review on the effectiveness of the Group’s
system of risk management and internal
control which is reported upon on page 118
to 119. While the review indicated there were
areas of the Group’s control environment that
required additional enhancement, the Group’s
control environment during 2022 overall
remained effective and the Board is satisfied
that it has complied with Principle C of the UK
Code which requires the Board to establish a
framework of prudent and effective controls,
which enable risk to be assessed and
managed.
During 2022, the Group’s CRO Mike Frawley
resigned from the Group to pursue another
career opportunity and I wish him well in that
regard. I would also like to thank David Curtis
who continues to hold the position of interim
CRO pending the appointment of a successor
which is well advanced.
On behalf of the Board Risk & Compliance
Committee
Donal Courtney
Chair, Board Risk & Compliance Committee
133
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Risk and Compliance Committee (continued)
Composition and Operation
The BRCC is composed of a majority of Independent Non-Executive Directors. Neither the
Board Chair nor the CEO is a member of the BRCC. The Board ensures that the Chair of
the Committee has relevant risk management and/or compliance experience. The Board
requires that at least one member of the Committee is common to each of the BAC and
the Board Remuneration Committee. On an annual basis, the Committee reviews its own
terms of reference and the Board Nomination, Culture and Ethics Committee conducts
a review of the Committee’s effectiveness and recommends changes considered
necessary to the Board. The Committee holds a member only session at the start of each
meeting following which the CRO subsequently attends for a private session with the
Committee. Thereafter other members of Senior Management are invited to attend, as
required.
2022 Committee Meeting Attendance
Member
Donal Courtney*
Ruth Wandhöfer
Marian Corcoran
Paul Doddrell
Anne Bradley
* Chair from 2 November 2021
Appointed
3 Oct 2018
30 Oct 2018
29 Oct 2019
26 Nov 2020
30 Mar 2021 -
Ceased
-
-
-
-
Number of
Years on the
Committee
4.3
4.2
3.3
2.1
1.8
2022 Meeting
Attendance
14/14
14/14
14/14
14/14
14/14
Responsibilities of the Committee
The Committee is responsible for
monitoring adherence to the Group
Risk Appetite Statement (RAS). Where
exposures exceed levels established in
the RAS, the Committee is responsible
for ensuring that appropriate remediation
plans are developed. This is facilitated by
the periodic review of a key risk indicators
report calibrated to the RAS.
The Committee is responsible for
monitoring compliance with relevant
laws, regulatory obligations and codes
of conduct. This is facilitated by regular
reporting on compliance risks to the
Committee. The Committee also spent a
substantial amount of time tracking the
continuing regulatory agenda and received
updates on Management’s activities to
implement new and updated regulation,
together with and on the on-going
engagement with the Group’s Regulators.
The Committee is also responsible for
oversight and advice to the Board on risk
governance, the current risk exposures
of the Group and future risk strategy,
including strategy for capital and liquidity
management, the setting of compliance
policies and principles and the embedding
and maintenance throughout the Group
of a supportive culture in relation to the
management of risk and compliance. The
BRCC supports the Board in carrying out
its responsibilities for ensuring that risks
are properly identified, reported, assessed
and controlled, and that the Group’s
strategy is consistent with the Group’s Risk
Appetite. It seeks to review key aspects
of the Group’s risk profile and provide
appropriate challenge on the adequacy
of their management. The Committee
continues to focus on the operational
resilience of the Group, the incidence
and management of material risk events
and the importance of having automated
processes, where practical and of effective
controls.
The Committee independently monitors
the extent to which the Group complies
with relevant rules and procedures. This
includes raising and maintaining awareness
of, for example, financial regulations,
compliance procedures and fraud and anti-
corruption measures. The Company has
internal policies, rules and procedures to
guarantee that Management complies with
relevant laws and regulations regarding
customers and business partners. External
aspects of the Committee are primarily
concerned with monitoring financial
transactions and preventing money
laundering. Internal aspects primarily
concern checking private transactions by
employees and directors, preventing and,
where necessary, transparently managing
conflicts of interest and safeguarding
confidential information.
In addition to meeting legal requirements,
the Committee reviews its own Terms
of Reference annually and its own
effectiveness, recommending any changes
considered necessary to the Board.
Matters considered by the
Committee in 2022
During 2022, the Committee continued
to focus considerable attention on the
Group’s systems of risk management
and internal control and supported work
undertaken by the Three Lines of Defence
to further embed the Group’s Internal
Control Framework. The Committee
undertook regular reviews of the Group’s
systems of risk management and internal
control during the year. In addition to the
monthly reporting from the CRO, Head of
Regulatory Compliance and Head of GIA,
the Committee also considered a wide
range of risk related frameworks and
reports. Among the matters considered by
the Committee during 2022 were:
• Ulster Bank transaction Risk and Capital
Assessments;
• Reviews of the Group’s Resolution
Planning capabilities and documentation;
• Oversight for the remediation of SREP
related Risk Mitigation Plans;
• Monthly monitoring of Technology
and Change Risk, including the Digital
Banking Programme;
134
Permanent TSB Group Holdings plc - Annual Report 2022 • AML Risk including Project Sun related
• Digital Transformation progress reports
risks;
and spotlights;
• Monitoring of upstream Regulatory
• Multiple Operational and IT Risk
developments;
Monitoring Reports;
• Risk Appetite reviews;
• Data Protection Officer’s Report;
• Oversight and approval of the Group’s
• Reviews of obligations and activity under
Non-Performing Asset Strategy;
• Recovery Planning Preparedness and
the CBI Code on Lending to Related
Parties;
Scenario Planning;
• Approval of a Climate Risk Framework;
• Spotlights on Cyber Security and IT
• Private sessions held separately
resilience;
• Climate and Environment Risk
Management;
• Review of Funding Plan and Deposit
Strategies;
• Monthly monitoring of Top Risks and
quarterly reviews thereto;
• Complaints Management Progress
reports;
• Reviews on Material Risk Events and
Customer Impacting Errors;
• Payments Strategy;
•
•
ICAAP and ILAAP design and approval;
ICAAP and ILAAP utilisation in decision
making;
• A review of the Group’s provision models
and expected credit loss outcomes;
• Updates on embedding of the Group’s
Risk and Control Self-Assessment;
• RAS breaches and remediation plans;
• Risks reviewed on Mortgage Loan Asset
Deleveraging;
with the CRO and Head of Regulatory
Compliance; and
• Approval of a Credit Risk Framework and
consideration on a number of SME credit
propositions.
Governance in Action: Climate Risk
In May 2022, the Committee approved
a Climate and Environmental Risk
implementation plan to address a request
for same by the Central Bank of Ireland.
The Committee in considering the plan,
stated the importance of satisfying this
regulatory requirement but also to ensure
the Group was adequately managing and
measuring Climate and Environmental
Risk and to incorporate these risks into
the Group strategy and business model to
ensure the Group played its part in Ireland’s
transition to a low-carbon economy.
135
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Remuneration Committee
Chair’s Overview
Dear Shareholders,
As Chair of the Board Remuneration
Committee, I am pleased to present the
Directors’ Remuneration Report for the
year ended 31 December 2022 which has
been prepared by the Committee and
approved by the Board.
The Committee’s report contains certain
regulatory information required under
the applicable legislation in respect of
the Group’s status as a listed company
and credit institution, as well as under the
EBA Guidelines on Internal Governance,
the amended EU Directive on the
encouragement of long-term shareholder
engagement, as transposed in Ireland
(the “Shareholder Rights Directive”, or
the “Directive”) and the UK Corporate
Governance Code.
Our Directors’ Remuneration Report
also provides further detail on the
composition of the Committee and its role
and responsibilities and a description of
the work undertaken by the Committee
during the year. We also include details of
the Remuneration Policy criteria and the
components of the Group’s reward offering,
with a focus on the Group’s Directors
(Executive and Non-Executive).
In 2022, the Committee continued to
oversee the way in which our Remuneration
policy, and its implementation, serves to
reward individual performance (what our
colleagues achieve but also the manner
in which they achieve their objectives). As
a Committee, we also reviewed how our
approach to pay and benefits contributes to
the strengthening of our culture, including
our risk culture. We also considered the
manner in which we reward the delivery of
the long-term sustainability of our business
and align remuneration with the long-
term interests of shareholders, investors
and other interested parties, and with
the public interest, as well as regulatory
requirements.
In line with its responsibilities under
the terms of the Shareholder Rights
Directive, the Group publishes its Directors’
Remuneration Policy (the “Policy”), as
applicable to the Board of Directors. The
Policy is published in full on the Group’s
website: www.permanenttsbgroup.ie.
During 2022, our Directors’ remuneration
was implemented in accordance with the
approved Policy, and no derogations from
the Policy were availed of during the year.
Since its original publication in 2020, the
Policy has remained unchanged. However,
following a market benchmarking review
and subject to shareholder approval on
an advisory basis at the 2023 AGM, we
intend to introduce certain amendments to
the Policy to facilitate enhanced pension
arrangements for our Executive Directors.
Details are provided in the Policy which is
published alongside this report.
In terms of the issues considered by
the Committee during 2022, it has been
another year of considerable change and
opportunity for the Group. In 2022, as the
economy emerged from the COVID-19
emergency, the Group was in a position
to reinstate the pay review process for
staff at all grades, including the Executive
Directors. This followed the partial pay
freeze applied in 2021 and allowed us
to negotiate an historic two-year pay
agreement that has provided pay certainty
for our colleagues. However, it is important
to acknowledge that economic factors
beyond the Group’s control have since
contributed to a significant inflationary
environment in the second half of 2022.
In recognition of this, in October 2022, the
Group took the decision to offer colleagues
a €1,000 gift voucher to assist them in
navigating cost of living pressures. With
the prior approval of the Department of
Finance, the gesture was extended to
eligible colleagues up to and including
‘Level 2’ managers i.e. excluding Heads
of Function, all Material Risk Takers and
the Executive Directors. In line with our
Community-based ethos, colleagues were
encouraged to use the voucher to support
local businesses and suppliers within
their locales. This gesture was provided in
addition to the two-year pay agreement
which, in 2022, provided increases ranging
from 0% - 8%, and an average increase
of 4.2% across the wider workforce. In
2022, none of the Executive Directors was
eligible for an increase under the terms of
the agreement. In 2023, the second and
final year of the agreement is scheduled
to deliver further increases ranging from
0% to 8%, with an average 3% award to be
paid in March 2023 and backdated to 1st
January 2023.
Alongside pay, the Committee also
sanctioned enhancements to colleague
pension arrangements for those
approaching retirement and oversaw
significant enhancements to our Maternity
Leave arrangements. The Group also
introduced improved leave and sick pay
arrangements to improve the level of
support we provide to colleagues as they
develop their careers with Permanent TSB.
In 2022, following a comprehensive
tendering process, the Remuneration
Committee and Board - working closely
with the Group’s Pension Scheme
Trustees – reviewed the administration
arrangements in place across both our
existing Defined Contribution Pension
schemes. It was agreed to combine both
schemes into a new, single consolidated
Defined Contribution scheme. The
programme of work supporting that
transition is due for completion in the
first half of 2023. The changed structure
will ensure that our colleagues’ pensions
remain subject to the highest standards
of oversight and governance, but also
presents a significantly enhanced
proposition for members as they save for
their retirement.
Separately, in relation to pension
arrangements, the Group completed
a market benchmarking exercise of
Executive Directors’ pension arrangements
in 2022. Based on the outcome of
136
Permanent TSB Group Holdings plc - Annual Report 2022 that exercise, enhancements applied
to the pension arrangements for the
broader colleague community, and the
requirement to ensure that our offering
remains competitive, we now propose
certain increases to Executive Directors’
employer pension contribution rates.
These amendments have been designed to
bring the Executive Directors’ entitlements
in line with those of the wider Executive
Committee, and to align our CEO’s
pension entitlements with equivalent
arrangements available across the
market. In reviewing the arrangements,
the Remuneration Committee was also
mindful of the restrictions on variable
pay and the €500,000 ‘Pay Cap’ which
continue to impact the competitiveness
of our total remuneration package in the
round. Full details of the proposed revised
entitlements are provided in the Directors’
Remuneration Policy.
2022 represented a period of significant
change across the retail banking industry.
The Group continues to transform itself via
the Ulster Bank transaction. Throughout
2022, the Remuneration Committee was
closely involved in the oversight of the
programme of work underpinning that
acquisition. In particular, the Committee
reviewed the design and implementation
of certain ‘measures’ aimed at replicating
the reward and benefit entitlements in
place for employees of the Ulster Bank.
These measures were required to satisfy
the (Transfer of Undertakings (Protection
of Employment) Regulations (TRUE)
attaching to the transfer, but also to help
motivate colleagues to join Permanent
TSB. Finally, the measures also served to
align working arrangements between both
institutions, and thus smooth the transition
of our new colleagues. I am happy to advise
that the measures met with the approval
of all parties; gained the support of the
Department of Finance as required under
the terms of State Agreements; and have
proven successful in supporting efforts to
make our new colleagues feel part of the
Permanent TSB employee community.
I’d like to take this opportunity to issue a
warm welcome to all our new colleagues,
including those who have already
transferred to Permanent TSB, and those
who are due to join us later in 2023.
Finally, I would like to thank my fellow
Board and Committee members, our
colleagues across the Bank, and our
shareholders for their support during
another extremely busy period.
On behalf of the Board Remuneration
Committee:
Ken Slattery,
Chair, Board Remuneration Committee.
At this point, it is appropriate to reference
recent changes to the terms of State
agreements on reward and remuneration.
In December 2022, the Minister approved
the relaxation of certain restrictions
which had applied to the manner in which
we reward our colleagues. Over the past
number of years, those restrictions have
impacted our ability to offer variable
pay, and in doing so inhibited our ability
to link colleague performance to the
growth of a sustainable business. In
2023, a key task of the Remuneration
Committee will be to oversee the
redesign of the Group’s remuneration
framework. Subject to affordability, and
within the bounds of the revised State
Agreements, the framework’s redesign
will support Permanent TSB in offering a
remuneration opportunity which is more
appropriate to the size and complexity of
the Group's operations. Any new scheme
will be designed to ensure that our offer to
colleagues remunerates them more fairly
for strengthening our corporate values and
our risk culture. Our aim is to improve the
linkages between remuneration and the
delivery of optimal customer outcomes.
We will also use the opportunity to drive
our ESG agenda, and ensure that individual,
team and Group-wide performance is
geared towards fulfilling our responsibilities
to our customers, colleagues and our
communities.
Annual Report on Remuneration - 2022
Remuneration Committee Composition and Operation
The members of the Board Remuneration Committee are experienced in the management
and oversight of large organisations where the remuneration and motivation of staff and
executives is of crucial importance.
The Committee had six meetings during 2022.
2022 Committee Meeting Attendance
Appointed
28 Jan 2014
31 Mar 2017
26 Sept 2016
01 Feb 2019
30 Mar 2021
Number of Full
Years on the
Committee
8
5
6
3
1
2022 Meeting
Attendance (of
which eligible to
attend)
6/6
6/6
6/6
5/6
6/6
Ceased
-
-
-
-
-
Member
Ken Slattery*
Robert Elliott
Andrew Power
Ruth Wandhöfer
Celine Fitzgerald
*Chair
137
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Remuneration Committee (continued)
Remuneration Committee Role and
Responsibilities
The purpose, duties and membership
of the Committee are set out in the
Committee’s Terms of Reference, which
can be found on the Group’s website www.
permanenttsbgroup.ie. The Terms of
Reference are reviewed by the Committee
on an annual basis. No material changes
were enacted following a review of the
Committee’s Terms of Reference in 2022.
The main roles and responsibilities of the
Committee include:
• Recommending the Group’s
remuneration policies, including that
applicable to the Board of Directors,
to the Board for approval on an annual
basis and ensuring they comply
with applicable regulatory and legal
requirements and remain free from any
form of bias relating to gender, age or
social or ethnic background.
• Supporting the Board in overseeing
remuneration policies, practices and
processes and compliance with the
Group’s Remuneration Policy (both as
applicable to the Directors and the wider
population);
• Ensuring the remuneration policies and
procedures do not promote excessive
risk taking and are aligned with the
Company’s overall corporate governance
framework, corporate culture, risk
culture and attitude to and appetite for
risk and related governance processes,
and takes into account the need to
maintain all capital and liquidity ratios
including buffer requirements;
• Recommending the design, eligibility and
performance measures for any incentive
schemes to the Board for approval;
• Setting and assessing performance
targets for any incentive schemes;
• Recommending remuneration proposals
(including joining and termination
of arrangements) in respect of the
Chairman, CEO, Executive Directors,
Company Secretary, Executive
Committee, Group Treasurer, Chief
Credit Officer, and Heads of Control
Functions for approval by the Board;
• Overseeing remuneration proposals
in respect of any other identified staff
(Material Risk Takers) as defined under
the fifth Capital Requirements Directive
(CRD V) ; and
• Overseeing the annual review of the
implementation of the Remuneration
Policy applicable across the Group.
Remuneration Committee Advisers
During 2022, the Committee used the
services of its external consultant, Deloitte
LLP, for advice on remuneration trends in
the external market and for perspective
on remuneration regulatory compliance
matters. During the year, Deloitte also
provided support to the Group in relation to
PSD2 and other risk related matters.
The Committee also utilised the services of
Willis Towers Watson who provided market
benchmarking data and remuneration
trend analysis, and consultancy services
in support of the remuneration related
aspects of the Ulster Bank transaction.
In addition to the use of external advice,
in designing its approach to pay the
Committee also takes account of
appropriate input from the Group’s HR,
Risk, Compliance, Finance and Internal
Audit functions to ensure that the decision
making process is aligned with the Group’s
financial performance, risk appetite,
regulatory guidelines and stakeholder
interests.
Matters considered by the
Committee in 2022
The Committee performed an annual
review of its own Terms of Reference, as
well as reviewing its own effectiveness,
and recommended the output of that
review to the Board.
During 2022, and within the terms of
State agreements, the Remuneration
Committee kept the impact of the
Group’s Remuneration Policy (including
that applicable to the Directors), and
movements in the external market,
under review. As part of this process,
the Committee reviewed the Group’s
Remuneration Policy and strategy
to assess the appropriateness of
the approach to reward and the
competitiveness of current arrangements,
and future direction, to take account of
market developments including amongst
the Group’s peer group.
The Committee also considered
whether the Directors’ Remuneration
Policy operated as intended in terms of
company performance and quantum.
The Committee also kept under review
all aspects of remuneration for the Board
Chairman, CEO, Executive Directors,
members of the Executive Committee and
the wider employee population.
In determining remuneration arrangements
for Executive Directors, the Committee
takes account of the pay and employment
conditions of the wider workforce to ensure
consistency. Wider workforce engagement
on pay arrangements at the Group took
place with the Group’s Staff Representative
Bodies during 2022.
It remains the policy of the Group to
reward our colleagues appropriately as
we work together to build a valuable and
sustainable business, operating within the
Group’s Risk Appetite and underpinned by
a strong culture which manifests itself in
responsible and accountable behaviours in
our day-to-day interactions and decision
making with our customers and each other.
To this end, the Policy has been designed
based upon a number of principles
including the linking of pay levels against
median base pay available across market
peer groups, and to ensure that the Group’s
offering is sufficiently competitive so as to
attract and retain the required talent and
skills to deliver the return of value to the
Company’s shareholders.
In 2022, the Committee reviewed the
Group’s approach to remuneration from the
perspective of ensuring that all employees,
regardless of gender, age or social or ethnic
background are remunerated fairly. In that
regard, it is of note that 2022 was the third
year in which the Group published details of
its gender pay gap; albeit the 2022 gender
pay gap was the first year in which the
Group reported in line with newly published
Irish legislation. The Group’s gender pay
gap stood at 17.5% at our chosen snapshot
date of 30 June 2022. Further details of the
gap and our commitment to reducing same
are provided in the separate section of the
Group’s Annual Report which details the
Group’s Diversity and Inclusion strategy.
During 2022, the Committee with the
supporting perspective of its external
independent advisors, performed a review
of pay and benefits packages available
across the Group. As part of that review,
and as the economy emerged from the
138
Permanent TSB Group Holdings plc - Annual Report 2022 COVID-19 emergency, the Group took
the decision to re-instate the pay review
process for staff at all grades, including
the Executive Directors. An historic two-
year pay agreement was entered-into
for 2022 and 2023 that has provided pay
certainty for our colleagues for that period.
The granting of increases to staff was,
as in previous years, based on individual
staff members’ performance and their
salary position versus the relevant market
median.
Alongside the reintroduction of the pay
review cycle, the Group also introduced
significant enhancements to its Maternity
Leave arrangements and to our Illness
Leave Policies which serve to emphasise
our commitment to supporting our
colleagues at all stages of their careers
with Permanent TSB.
In the second half of 2022, as a result of the
extraordinary inflationary situation which
prevailed across the economy and the
impact of cost of living increases for our
colleagues, the Group took the decision to
offer a gesture to colleagues in the form of
a €1,000 gift voucher to assist them with
their increased household expenditure.
With the prior approval of the Department
of Finance - as was required by the terms
of State Agreements - the gesture was
extended to eligible colleagues up to and
including ‘Level 2’ managers i.e. excluding
Heads of Function and Material Risk Takers
including the Executive Directors), and
colleagues were encouraged to use the
voucher to support local businesses and
suppliers within their community.
The Committee also reviewed our
colleagues’ pension arrangements and in
2022 the Committee recommended to the
Board further enhancements in pension
contribution rates for those members
of the workforce who are approaching
retirement.
Subject to shareholder approval on an
advisory basis at the 2023 AGM, the
Committee also recommended that the
Board approve certain amendments to our
Directors’ Remuneration Policy to facilitate
enhanced pension arrangements for our
Executive Directors. These amendments
have been designed to bring the Executive
Directors’ maximum contribution rates in
line with the wider Executive Committee;
and, following a benchmarking exercise
undertaken in 2022, to align our CEO’s
pension entitlements with equivalent
arrangements in place across our peers.
Details of the proposed entitlements are
provided in the Policy which forms part of
these statements.
Throughout 2022, the Committee oversaw
key aspects of the programme of work
underpinning the Ulster Bank transaction.
In particular, the Committee reviewed
the design and implementation of certain
‘measures’ aimed at replicating the reward
and benefit entitlements in place for
employees of the Ulster Bank in order to
satisfy TUPE Regulations attaching to the
transfer, but also to help motivate our new
colleagues to exercise their right to join
Permanent TSB.
During 2022, the Committee maintained
significant oversight to ensure compliance
with the UK Corporate Governance Code,
CRD V related regulations and guidelines,
including focussing on reviewing the
remuneration arrangements in place for
Material Risk Takers. The Committee re-
approved the process and approach for the
identification of Material Risk Takers in line
with these requirements.
During the year, the Committee also
reviewed the Group’s established variable
commission scheme, as well as principles
and practices to ensure full alignment
with regulatory requirements, particularly
the CRD V, the EBA’s Guidelines on sound
remuneration policies and practices
related to the sale and provision of retail
banking products and services, the Central
Bank of Ireland’s Guidelines on Variable
Remuneration Arrangements for Sales
Staff, and relevant market practice. On
foot of this review, it was agreed to extend
the operation of the scheme for a further
year, subject to certain enhancements
designed to reflect the Group’s increasing
capabilities in respect of customer and
conduct management and to increase
governance and oversight of scheme-
related performance data.
The Group’s Directors’ Remuneration
Policy was approved by our shareholders
on an advisory basis at our 2020 AGM.
The Committee is satisfied that the
Group has continued to operate within its
Remuneration Policy (both as applicable to
the Directors and the wider population) and
in line with the remuneration requirements
of the framework agreement between the
Minister for Finance and the Group, and
that the Directors’ Remuneration Policy
operated as intended in terms of company
performance and quantum. Other than as
set out elsewhere in the Annual Report
on page 97, the Committee is satisfied
that the Group is in compliance with the
provisions of the UK Corporate Governance
Code and the Shareholder Rights Directive.
With specific reference to the UK Code,
the table on page 140 sets out how the
Remuneration Committee has addressed
the principles set out in the Code.
Additional regulatory disclosures in relation
to Remuneration Policy and strategy are
set out in the Group’s Pillar 3 Report.
Directors’ Remuneration Policy
This section sets outs the Directors’
Remuneration Policy proposed for
shareholders’ approval via an advisory note
at the 2023 AGM.
The Directors’ Remuneration Policy has
remained unchanged since approved at
the 2020 AGM. However, we now intend
to introduce certain amendments to the
Policy to allow for enhanced pension
arrangements for our Executive Directors.
These amendments have been designed
to bring the CRO and CFO’s maximum
contribution rates in line with the wider
Executive Committee; and, following
a benchmarking exercise undertaken
in 2022, to align our CEO’s pension
entitlements with equivalent arrangements
in place across the wider market.
Subject to receiving shareholder approval,
the policy is intended to apply immediately
for three years to the end of the AGM in
2026, although we may seek shareholders’
approval for a new policy during the period
depending on regulatory developments,
changes to our strategy or competitive
pressures.
The Bank publishes its Directors’
Remuneration Policy (the “Policy”), as
applicable to the Board of Directors. The
Policy is published in full on the Bank’s
website: www.permanenttsbgroup.ie.
Directors’ remuneration for 2022 was
implemented in accordance with the
Bank’s Directors’ Remuneration Policy,
as approved by shareholders at the 2020
AGM.
139
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Corporate Governance Statement
Remuneration Committee (continued)
The Policy, in alignment with the
Remuneration Policy applicable across
the Group, is based on a set of agreed
basic principles which are applied to all
employees:
term Group and stakeholder objectives
and interests;
• Focusing on the attraction, engagement
and retention of key talent of the calibre
required;
• Aligning remuneration with the
Group’s risk appetite, approaches and
governance framework;
• Ensuring our approach is in compliance
• Ensuring that our Policy and each
element of Directors’ remuneration is
as transparent, simple and clear as is
possible.
with all applicable regulatory
requirements;
• Aligning remuneration with our business
strategy, objectives, purpose and values,
and promoting the achievement of long-
A summary of the key components of
the Policy as it relates to the Executive
Directors is set out below:
Remuneration Component
Summary of Policy
Basic Salary
Basic salaries are set so as to attract and retain key talent of the calibre required to develop, lead
and deliver the Group’s long-term strategy.
Basic salaries are normally reviewed by the Remuneration Committee annually, taking into
consideration:
the individual’s skills, responsibilities and experience;
the scope of the role;
pay and conditions elsewhere in the Group;
overall business performance and affordability; and
market competitiveness by reference to relevant comparator groups.
Any increases for Executive Directors will normally be in line with the range of increases for other
employees in the wider Group.
Benefits
Benefits are provided to ensure the overall package is competitive and in accordance with local
market practice.
The Committee’s policy is to provide Executive Directors with a market competitive level
of benefits, taking into consideration benefits offered to other employees in the Group, the
individual’s circumstances and market practice at similar companies.
Benefits may include, but are not limited to, the provision of a car allowance (or cash allowance in
lieu) and subsidised house purchase loans provided on the same terms and conditions as loans to
other eligible PTSB employees.
Pensions
Pension arrangements are intended to provide competitive post-retirement benefits aligned with
market practice.
Executive Directors are eligible to participate in the PTSB Defined Contribution Pension Scheme.
Executive Directors may receive a maximum allowance of 16% of basic salary; or, 20% of basic
salary in the case of the Chief Executive Officer. Maximum contribution rates are consistent
across the Group. However, in recognition of the remuneration restrictions currently in place as
a result of the agreements and commitments in place with the Irish State, in order to ensure a
competitive overall package, Executive Directors are not subject to certain age-related eligible
criteria which apply to the availability of the maximum contribution rate for the wider workforce.
140
Permanent TSB Group Holdings plc - Annual Report 2022 The following section sets out how the Remuneration Committee addresses the principles set out in the UK Corporate Governance Code
in respect of the Directors’ Remuneration Policy.
Provision
Approach
Clarity
Remuneration arrangements should
be transparent and promote effective
engagement with shareholders and the
workforce.
Simplicity and predictability
Remuneration structures should avoid
complexity and their rationale and
operation should be easy to understand.
The range of possible values of rewards
to individual directors and any other limits
or discretions should be identified and
explained at the time of approving the
policy.
Risk
Remuneration arrangements should
ensure reputational and other risks from
excessive rewards, and behavioural risks
that can arise from target-based incentive
plans, are identified and mitigated.
Proportionality and alignment to culture
The link between individual awards, the
delivery of strategy and the long-term
performance of the company should be
clear. Outcomes should not reward poor
performance.
Incentive schemes should drive
behaviours consistent with company
purpose, values and strategy.
The Committee regularly engages and consults with key stakeholders to take
feedback into account and to ensure that our approach to Executive Remuneration is
as transparent, simple and clear as is possible.
Our employees are informed about our approach to remuneration. Our Remuneration
Policy, applicable throughout the Group and which includes details of the approach
to Director remuneration, is published internally for all staff to view and our approved
Directors’ Remuneration Policy is published in full on the Group’s website www.
permanenttsbgroup.ie.
Due to certain agreements and commitments in place with the Irish State, the Group
currently only operates fixed remuneration among Executive Directors, consisting
of basic salary, pension and benefits. As a result, the Committee’s ability to apply
discretion with respect to outcomes for this population is limited, however, the
simplicity of our approach enhances its predictability.
Should the Group reintroduce variable remuneration plans in future, the Group will
review Executive Director remuneration arrangements from the perspective of
ensuring that our approach continues to avoid complexity, and is predictable in its
nature, as well as reviewing the Committee’s powers of discretion over remuneration
outcomes.
Remuneration arrangements are designed to align pay with the Group’s risk culture,
attitude to and appetite for risk and our governance and regulatory framework.
While the Group currently only operates fixed remuneration among the Executive
Directors, it is committed to ensuring the ongoing alignment of remuneration with
strategy and long-term sustainable performance and the recognition of positive
behaviours.
Should the Group reintroduce variable remuneration plans in future, the Group will
review Executive Director remuneration arrangements from the perspective of
ensuring that any awards are designed to promote the achievement of our long-term
strategic ambitions while driving behaviours consistent with our purpose, values and
strategy
141
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Director’s report on remuneration
Executive Directors’ Remuneration and Pension Benefits
Directors’ remuneration for 2022 was implemented in accordance with the Bank’s Directors’ Remuneration Policy, as approved by
shareholders at the 2020 AGM. No derogations from the Policy were availed of during the year. The Policy was designed – to the extent
possible given the remuneration restrictions in place as a result of the agreements and commitments in place with the Irish State – to
ensure alignment between our approach to reward and our business strategy and to promote long-term sustainable success. However,
the nature and scope of those State agreements and commitments limit to a significant degree our ability to apply the Policy as intended
and challenge our capacity to achieve the required linkage between reward and performance. Within those constraints, it remains our
Policy to ensure that the Bank rewards and retains key talent of the calibre required to develop, lead and deliver the Bank’s long-term
strategy.
In line with certain agreements and commitments in place with the Irish State, during 2022 all Bank employees were subject to a salary
cap of €500,000 per annum. In addition, the Bank did not operate any variable remuneration arrangements for its Executive Directors.
No bonus payments and long term incentive arrangements were made to Executive Directors during 2021 or 2022.
In December 2022, the aforementioned State Agreements were amended such that bonuses are now no longer prohibited, subject to
the amount of any such remuneration in any 12 month period not exceeding €20,000 in the aggregate. It is the policy of the Bank that
any future bonus schemes and future long term incentives plans, for which the Executive Directors may prove eligible, will adhere to the
terms of the State Agreements, relevant regulatory requirements on variable pay and applicable Irish legislation, and will be subject to
approval by shareholders.
The two tables covering 2022 and 2021 and the share option schemes paragraph below identified as audited form an integral part of
the audited financial statements as described in the basis of preparation on page 165. All other information in the Directors Report on
Remuneration is unaudited.
Executive Director Remuneration and Pension Benefits
2022 remuneration for Executive Directors who held office for any part of the 2022 financial year was entirely fixed in nature, consisting
of basic salary, certain benefits and defined contribution pension entitlements as follows:
1.
Fixed Remuneration
2.
Variable Remuneration
2022 (Audited)
Note
Base Salary
Fees
Fringe
Benefits
One-year
variable
Multi-year
variable
3. Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
1 €480,000 €0 €20,000
€8,172
2 €145,054 €0
3 €83,944 €0
€5,000
€0
€0
€0
€0
€0
€0
€0
€0
€72,000
€21,758
€572,000
€174,984
100% Fixed
100% Fixed
€0
€12,592
€101,536
100% Fixed
Name of Executive
Director, Position
Eamonn Crowley,
CEO
Nicola O’Brien CFO
Michael Frawley,
CRO
Notes:
1. Fringe Benefits consist of Car Allowance Benefits (€20k)
2. Nicola O'Brien was appointed CFO on the 4 August 2022. Fringe Benefits consist of Car Allowance (€17k).
3. Mike Frawley ceased to be a Director on 31 March 2022 and his remuneration detailed above is for the three months ended on that date.' Fringe benefits consist of Car
Allowance (€10k) and Benefit In Kind (€0.3k).
For comparison, 2021 Remuneration for Executive Directors who held office for any part of the 2021 financial year was entirely fixed in
nature, consisting of basic salary, certain benefits and defined contribution pension entitlements as follows:
1.
Fixed Remuneration
2.
Variable Remuneration
Note
Base Salary
Fees
Fringe
Benefits
One-year
variable
Multi-year
variable
3. Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion of
Fixed and Variable
Remuneration
2021 (Audited)
1 €480,000 €0 €20,120
2 €335,775 €0 €20,000
€0
€0
€0
€0
€0
€72,000
€572,120
100% Fixed
€0 €50,366
€406,141
100% Fixed
Name of Executive
Director, Position
Eamonn Crowley,
CEO
Michael Frawley,
CRO
Notes:
1. Fringe Benefits consist of Car Allowance Benefits (€20k) and Benefit in Kind of (€0.1k)
2. Fringe Benefits consist of Car Allowance Benefits (€20k).
Aggregate Executive Director Compensation (excluding Extraordinary items) stood at €848,520 in 2022, down from €978,261 in 2021 as
a result of changes to the Executive Director membership during the period.
No Executive Director was in receipt of any remuneration from any undertaking within the Group other than Permanent TSB Group
Holdings plc.
142
Permanent TSB Group Holdings plc - Annual Report 2022 Components of Executive Director Remuneration - 2022
Basic salary
As in previous years, pay increases to eligible staff were based on each individual staff member’s performance and salary position
versus the relevant market median. The increases ranged from 0% up to 8% with an average increase of 4.2% and all increases were
effective from 1 January 2022. In 2022, none of the Executive Directors were eligible for an increase under the terms of the agreement.
2023 represents the second year of the current 2 year Pay Agreement and scheduled increases will again range from 0% to 8% with
average increases of 3% to be paid in March 2023 and backdated to 1st January 2023. The 2023 salary review for Executive Directors
has not yet concluded and further details of any increases granted will be included within next year’s report.
Pensions
The current Executive Directors are members of the PTSB Defined Contribution Pension Scheme. During 2022, the Bank contributed up
to 15% of basic salary into this pension scheme.
Effective 1st January 2023, the contribution rate will increase to 20% in the case of the Chief Executive Officer, and increase to 16% in
the case of the other Executive Directors.
Other than basic salary, there are no other elements of Director’s remuneration which are pensionable.
Benefits
During 2022, Executive Directors received benefits in line with Policy. This included an allowance of €20,000 in lieu of a company car and
eligibility for subsidised house purchase loans provided on the same terms and conditions as loans to other eligible PTSB employees.
Bonus and Long-term Incentive Plans
In line with the terms of certain agreements in place with the State during 2022, the Remuneration Policy did not provide for the payment
of variable remuneration to Executive Directors. No bonus payments were made to Executive Directors during 2022 or 2021. Neither were
there any long term incentive arrangements in place for Executive Directors in 2022 or 2021.
Share option schemes - Audited
No share options were granted in 2022 or 2021. There were no share options in existence at the end of the period and the Bank’s sole
remaining share option scheme is now closed.
Loss of Office Payments
The Remuneration Policy requires that any payments on termination of employment are made in accordance with the provisions of CRD
V and applicable Irish legislation. Any payments in relation to termination reflect performance achieved over time and will not reward
failure or misconduct. Leavers will receive any payments required under the terms of their contract.
Payments to Former Directors
No such payments were made to former Executive Directors during 2022.
Directors’ Fees from another Company
The Bank operates established polices, practices and procedures that are designed to identify, document and manage conflicts of
interest. It is the policy of the Bank that where an Executive Director of the Bank is remunerated for service as a Non-Executive Director
of a non-Bank company and retains such remuneration, the amount of this remuneration is disclosed. No Executive Director was in
receipt of fees from external appointments during the period.
143
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Director’s report on remuneration
(continued)
Non-Executive Director Remuneration
The level of fees paid to the Chairman and Non-Executive Directors in 2022 is outlined in the table below. The base fees and further
fees for additional Board duties such as chairmanship or membership of a committee, which had remained unchanged since 2017,
were increased by 10% on the 1st July 2022. In arriving at this level of increase, the Board considered the output of a robust market
benchmarking exercise, and took account of the increased time commitment required of Board members. The increases were also
calculated to take account of base pay increases across the wider workforce since the date of the last fee review in 2017. Aggregate
fees paid to Non-Executive Directors increased from €947,993 (2021) to €1,046,218 (2022) as a consequence of the changes to the fee
structure.
1.
Fixed Remuneration
2022 (Audited)
2.
Variable Remuneration
Name of
Director,
Position
Note
Base
Salary
Basic Fees
Fees Paid
Fringe
Benefits
One-year
variable
Multi-year
variable
3.
Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
Robert Elliott
Ken Slattery 1
Andrew
Power
2
Ronan O’Neill 3
Donal
Courtney
Ruth
Wandhöfer
Marian
Corcoran
4
5
6
Paul Doddrell 7
Celine
Fitzgerald
8
Anne Bradley 9
€0
€0
€0
€0
€320,000 €305,000 €0
€60,000 €73,088 €375
€60,000 €70,463 €0
€60,000 €117,713
€375
€0
€60,000 €99,337 €0
€0
€0
€0
€0
€0
€0
€60,000 €70,463 €435
€0
€0
€0
€0
€0
€60,000 €78,338 €435
€60,000 €80,963 €435
€60,000 €67,837
€0
€60,000 €80,963 €0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€305,000
100% Fixed
€73,463
100% Fixed
€70,463
100% Fixed
€118,088
100% Fixed
€0
€99,337
100% Fixed
€0
€70,898
100% Fixed
€0
€0
€0
€0
€78,773
100% Fixed
€81,398
100% Fixed
€67,837
100% Fixed
€80,963
100% Fixed
Notes:
1. Additional fees paid as chair of the Remuneration Committee, and member of the Nomination, Culture and Ethics Committee. Fringe benefits comprise Benefit in Kind €375
relating to the payment of professional body subscriptions.
2. Additional fees paid as member of the Board Audit Committee and member of the Remuneration Committee.
3. Additional fees paid as chair of the Board Audit Committee, member of the Board Nomination, Culture and Ethics Committee and Senior Independent Director and member
of Project Sun Oversight Committee. Fringe benefits comprise Benefit in Kind €375 relating to the payment of professional body subscriptions.
4. Additional fees paid as chair of the Board Risk and Compliance Committee, member of Board Audit Committee, and member of Project Sun Oversight Committee.
5. Additional fees paid as member of the Board Risk and Compliance Committee and member of the Remuneration Committee. Fringe benefits comprise Benefit in Kind €435
relating to the payment of professional body subscriptions.
6. Additional fees paid as member of the Board Risk and Compliance Committee, member of the Board Nomination, Culture and Ethics Committee and member of Project Sun
Oversight Committee. Fringe benefits comprise Benefit in Kind €435 relating to the payment of professional body subscriptions.
7. Additional Fees paid as member of the Board Risk and Compliance Committee, Board Audit Committee and Project Sun Oversight Committee. Fringe benefits comprise
Benefit in Kind €435 relating to the payment of professional body subscriptions.
8. Additional fees paid as member of the Remuneration Committee and Nomination, Culture and Ethics Committee.
9. Additional fees paid as member of the Board Audit Committee and Board Risk and Compliance Committees and member of Project Sun Oversight Committee..
144
Permanent TSB Group Holdings plc - Annual Report 2022 For comparison, the level of fees paid to the Chairman and Non-Executive Directors in 2021 is outlined in the table below.
1.
Fixed Remuneration
2021 (Audited)
2.
Variable Remuneration
Name of
Director,
Position
Note
Base
Salary
Basic Fees
Fees Paid
Fringe
Benefits
One-year
variable
Multi-year
variable
3.
Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
Robert Elliott
€0 €290,000 €290,000
€0
Ken Slattery
Andrew
Power
Ronan O’Neill
Donal
Courtney
Ruth
Wandhöfer
Marian
Corcoran
Paul Doddrell
Celine
Fitzgerald
Anne Bradley
1
2
3
4
5
6
7
8
9
€0 €54,675
€75,510
€375
€0 €54,675
€67,175
€0
€0 €54,675 €109,050
€375
€0 €54,675
€92,773
€435
€0 €54,675
€67,175
€435
€0 €54,675
€71,550
€355
€0 €54,675
€70,925
€0 €54,675 €48,854
€0 €54,675
€57006
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€0
€290,000 100% Fixed
€71,885 100% Fixed
€67175 100% Fixed
€109,425 100% Fixed
€0
€0
€93,208 100% Fixed
€0
€0
€67,610 100% Fixed
€0
€0
€0
€0
€0
€0
€0
€0
€71,905 100% Fixed
€70,925 100% Fixed
€48,854 100% Fixed
€57,006 100% Fixed
Notes:
1. Additional fees paid as chair of the Remuneration Committee, member of the Board Audit Committee (ceased 30 March 2021) and member of the Nomination, Culture and
Ethics Committee. Fringe benefits comprise Benefit in Kind €375 relating to the payment of professional body subscriptions.
2. Additional fees paid as member of the Board Audit Committee and member of the Remuneration Committee.
3. Additional fees paid as chair of the Board Risk and Compliance Committee (ceased 2 November 2021), chair of the Board Audit Committee (appointed 2 November 2021),
member of the Board Nomination, Culture and Ethics Committee and Senior Independent Director and member of Project Sun Oversight Committee (appointed 1 June 2021).
Fringe benefits comprise Benefit in Kind €375 relating to the payment of professional body subscriptions.
4. Additional fees paid as chair of the Board Audit Committee (ceased 2 November 2021), member of the Board Risk and Compliance Committee (ceased 2 November 2021),
chair of the Board Risk and Compliance Committee (appointed 2 November 2021), member of the Board Nomination, Culture and Ethics Committee (ceased 30 March 2021)
and member of Project Sun Oversight Committee (appointed 1 June 2021). Fringe benefits comprise Benefit in Kind €435 relating to the payment of professional body
subscriptions.
5. Additional fees paid as member of the Board Risk and Compliance Committee and member of the Remuneration Committee. Fringe benefits comprise Benefit in Kind €435
relating to the payment of professional body subscriptions.
6. Additional fees paid as member of the Board Risk and Compliance Committee, member of the Remuneration Committee (ceased 30 March 2021), member of the Board
Nomination, Culture and Ethics Committee (appointed 30 March 2021) and member of Project Sun Oversight Committee (appointed 1 June 2021). Fringe benefits comprise
Benefit in Kind €355 relating to the payment of professional body subscriptions.
7. Additional Fees paid as member of the Board Risk and Compliance Committee, Board Audit Committee and Project Sun Oversight Committee (Appointed 1st November
2021)
8. Appointed on 30 March 2021. Additional fees paid as member of the Remuneration Committee and Nomination, Culture and Ethics Committee.
9. Appointed on 30 March 2021. Additional fees paid as member of the Board Audit Committee and Board Risk and Compliance Committees (appointed 30 March 2021) and
member of Project Sun Oversight Committee (Appointed 1 June 2021).
The base fee and further fees for additional Board duties such as chairmanship of membership of a committee received by the directors
were increased as outlined below on the 1st July 2022 following a market benchmarking exercise:
Position:
Chairman
Non-Executive Director (Base Fee)
Senior Independent Director
Board Audit Committee and Board Risk & Compliance Committee
Remuneration Committee
Remuneration Committee and Nomination, Culture & Ethics Committee
Project Sun Oversight Committee
2022 Fees
€320,000
€60,000
€22,000
€27,500
€8,250
€11,000
€5,500
€8,250
Chair
Member
Chair
Member
Member
145
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Director’s report on remuneration
(continued)
Comparison of Directors’ and Employees’ pay
The following table provides information regarding the annual change in the total remuneration of members of the Bank’s Board of
Directors, as well the average change in remuneration, on a full-time equivalent basis, of our employees as compared with our Company
performance between 2020 and 2022.
Annual Change
Directors’ Remuneration – Executive Directors
Eamonn Crowley, CEO
Nicol O’Brien CFO
Michael Frawley, CRO
Directors’ Remuneration – Non-Executive Directors (NEDs)
Robert Elliot, Chairman
Ken Slattery, Independent NED
Andrew Power, Independent NED
Ronan O’Neill, Independent NED
Donal Courtney, Independent NED
Ruth Wandhöfer, Independent NED
Marian Corcoran, Independent NED
Paul Doddrell, Independent NED
Celine Fitzgerald, Independent NED
Anne Bradley, Independent NED
Average remuneration on a full-time equivalent basis of employees
Employees of the company
Company performance
Underlying profit/(loss)
Adjusted cost to income ratio
Note
Percentage
change in 2022
Percentage
change in 2021
Percentage
change in 2020
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
0.0%
N/A
N/A
5.2%
1.7%
4.9%
7.6%
6.6%
4.2%
8.9%
14.2%
4.1%
6.5%
(0.8%)
2022
€45m
84%
5.1%
0.0%
0.0%
2.3%
0.0%
21.3%
1.1%
0.6%
7.0%
1.8%
N/A
N/A
1.7%
2021
€17m
82%
6.6%
0.7%
0.0%
4.6%
0.0%
6.5%
0.0%
0.0%
0.0%
N/A
N/A
N/A
2.6%
2020
(€109m)
75%
Notes:
1. Mr Crowley served as CFO up to 1st July 2020 at which point he was appointed as CEO. The year on year increase in 2021 reflects this appointment to CEO.
2. Ms. O’Brien was appointed to the Board on 04 August 2022 and therefore no pre-2022 data is available for comparative purposes.
3. Mr Frawley resigned from the Board on 30 March 2022.
4. Mr. Elliot’s increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022.
5. Mr. Slattery was appointed as Chair of Remuneration Committee on 8th September 2020. The year on year increase in 2021 reflects this appointment and the payment of
fringe benefits during 2021. The year on year increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022.
6. Mr Power’s increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022.
7. Mr O’Neill was appointed as Senior Independent Director on 6th August 2020. The year on year increase in 2021 reflects this appointment, and other committee membership
changes during 2021. The year on year increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022.
8. Mr Courtney’s increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022.
9. Ms Wandhöfer’s year on year increase in 2021 reflects payment of fringe benefits during 2021. The year on year increase in 2022 is reflective of the increase in board
remuneration fees which were approved in July 2022.
10. Ms Corcoran’s year on year increase in 2021 reflects committee membership changes during 2021. The year on year increase in 2022 is reflective of the increase in board
remuneration fees which were approved in July 2022.
11. Mr Doddrell was appointed as a member of the Board on 26th November 2020 and therefore no pre-2020 data is available for comparative purposes. Remuneration for 2020
was annualised for the purposes of the above. The year on year increase in 2021 reflects committee membership changes during 2021. The year on year increase in 2022 is
reflective of the increase in board remuneration fees which were approved in July 2022.
12. Ms. Fitzgerald was appointed as a member of the Board on 30th March 2021 and therefore no pre-2021 data is available for comparative purposes. Remuneration for 2021
was annualised for the purposes of the above. The year on year increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022.
13. Ms. Bradley was appointed as a member of the Board on 30th March 2021 and therefore no pre-2021 data is available for comparative purposes. Remuneration for 2021 was
annualised for the purposes of the above. The year on year increase in 2022 is reflective of the increase in board remuneration fees which were approved in July 2022
14. The change in average remuneration is based on the annual employee costs (excluding social welfare and directors remuneration) divided by the average number of
employees.
15. Operating profit/loss before exceptional items. See table 8 on page 52 for a reconciliation of underlying loss to operating profit on an IFRS basis.
16. Defined as total operating expenses (excluding exceptional, other non-recurring items, bank levy and regulatory charges) divided by total operating income.
Voting Results from the Annual General Meeting
At the 2022 AGM, shareholder approval on an advisory basis was sought for the 2022 Directors’ Report on Remuneration. At the AGM in
2022, 99.9% of votes cast were in favour of the resolution.
Also, in accordance with the Shareholder Rights Directive, every four years, shareholder approval on an advisory basis is sought on the
Directors’ Remuneration Policy. Shareholder approval for the Directors’ Remuneration Policy was last granted at the AGM in 2020 which
was approved by 99.9% of shareholders at that time.
The Bank takes the views of shareholders on our approach to remuneration into account on an ongoing basis and welcomed the strong
support received for both of these resolutions.
146
Permanent TSB Group Holdings plc - Annual Report 2022 • the Annual Report and the financial
statements, taken as a whole, is
fair, balanced, understandable and
provides the information necessary for
shareholders to assess the Group and
Company’s position and performance,
business model and strategy.
On behalf of the Board
Robert Elliott
Chairman
Eamonn Crowley
Chief Executive
Conor Ryan
Company Secretary
Nicola O’Brien
Chief Financial
Officer
28 February 2023
Statement of Directors’ Responsibilities
The Directors are responsible for
preparing the Annual Report and the
financial statements in accordance with
International Financial Reporting Standards
(IFRS) adopted by the European Union (EU)
and with those parts of the Companies
Act 2014 applicable to companies
reporting under IFRS and in respect of the
consolidated financial statements, Article 4
of the IAS Regulation.
Under Irish law the Directors shall not
approve the Group’s and Company’s
financial statements unless they are
satisfied that they give a true and fair view
of the Group’s and the Company’s assets,
liabilities and financial position as at the
end of the financial year and of the profit or
loss of the Group for the financial year.
In preparing these financial statements,
the Directors are required to:
• select suitable accounting policies and
then apply them consistently;
• make judgements and estimates that are
reasonable and prudent;
• state whether the financial statements
have been prepared in accordance with
IFRS adopted by the EU and ensure that
they contain the additional information
required by the Companies Act 2014; 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 responsible for keeping
adequate accounting records that are
sufficient to:
• correctly record and explain the
transactions of the Company;
• enable, at any time, the assets, liabilities,
financial position of the Company to be
determined with reasonable accuracy;
and
• enable the Directors to ensure that the
financial statements comply with the
Companies Act 2014, and as regards
the Group financial statements, article 4
of the IAS Regulation and enable those
financial statements to be audited.
The Directors are also responsible for
safeguarding the assets of the Group
and the Company and hence for taking
reasonable steps for the prevention and
detection of fraud and other irregularities.
Under applicable law and the requirements
of the Listing Rules issued by the Irish and
London Stock Exchanges, the Directors are
also responsible for preparing a Directors’
Report and reports relating to Directors’
remuneration and Corporate Governance.
The Directors are also required by the
Transparency (Directive 2004/109/EC)
Regulations 2007 and the Transparency
Rules to include a management report
containing a fair review of the business
and a description of the Principal Risks and
Uncertainties facing the Group.
The Directors are responsible for the
maintenance and integrity of the corporate
and financial information included on the
Company’s website www.permanenttsb.
ie. Legislation in the Republic of
Ireland governing the preparation and
dissemination of financial statements may
differ from legislation in other jurisdictions.
The Directors confirm that, to the best of
each Director’s knowledge and belief:
• they have complied with the above
requirements in preparing the financial
statements;
• the financial statements, prepared in
accordance with IFRS as adopted by the
European Union, give a true and fair view
of the assets, liabilities, financial position
of the Group and the Company and of the
loss of the Group;
• the Group’s Chairman Statement, the
Group’s Chief Executives Review and
the Operating and Financial Review set
out in the Strategic Report includes
a fair review of the development and
performance of the business and
the position of the Group and the
Company, together with a description
of the Principal Risks and Uncertainties
that they face as set out in the Risk
Management Section of the Strategic
Report; and
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of Permanent TSB Group Holdings plc
Report on the audit of the financial statements
Opinion
In our opinion, Permanent TSB Group Holdings plc’s Consolidated Financial Statements and Company Financial Statements (the
“financial statements”):
• give a true and fair view of the Group’s and the Company’s assets, liabilities and financial position as at 31 December 2022 and of the
Group’s profit and the Group’s and Company’s cash flows for the year then ended;
• have been properly prepared in accordance with International Financial Reporting Standards (“IFRSs”) as adopted by the European
Union and, as regards the Company’s financial statements, as applied in accordance with the provisions of the Companies Act 2014;
and
• have been properly prepared in accordance with the requirements of the Companies Act 2014 and, as regards the Group financial
statements, Article 4 of the IAS Regulation.
We have audited the financial statements, included within the Annual Report, which comprise:
• the Consolidated and Company Statements of Financial Position as at 31 December 2022;
• the Consolidated Income Statement and Consolidated Statement of Comprehensive Income for the year then ended;
• the Consolidated and Company Statements of Cash Flows for the year then ended;
• the Consolidated and Company Statements of Changes in Equity for the year then ended; and
• the notes to the financial statements, which include a description of the significant accounting policies.
Certain required disclosures have been presented elsewhere in the Annual Report, rather than in the notes to the financial statements.
These are cross-referenced to and from the financial statements and are identified as audited.
Our opinion is consistent with our reporting to the Audit Committee.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (Ireland) (“ISAs (Ireland)”) and applicable law. Our
responsibilities under ISAs (Ireland) are further described in the Auditors’ responsibilities for the audit of the financial statements section
of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence
We remained independent of the Group in accordance with the ethical requirements that are relevant to our audit of the financial
statements in Ireland, which includes IAASA’s Ethical Standard as applicable to listed public interest entities, and we have fulfilled our
other ethical responsibilities in accordance with these requirements.
To the best of our knowledge and belief, we declare that non-audit services prohibited by IAASA’s Ethical Standard were not provided to
the Group or the Company.
Other than those disclosed in note 9 to the financial statements, we have provided no non-audit services to the Group or the Company in
the period from 1 January 2022 to 31 December 2022.
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Permanent TSB Group Holdings plc - Annual Report 2022 Our audit approach
Overview
Overall materiality
• €13.0 million (2021: €10.0 million) - Consolidated financial statements
• Based on c. 0.56% of net assets.
Materiality
• €13.0 million (2021: €9.5 million) - Company financial statements
• Based on c. 0.56% of net assets (2021: c. 1% of net assets).
Performance materiality
Audit scope
• €9.75million (2021: €7.5 million) - Consolidated financial statements.
• €9.75 million (2021: €7.1 million) - Company financial statements.
Audit scope
Key audit
matters
• We have conducted an audit of the complete financial information of Permanent TSB plc
which is the main trading entity of the Group and accounts for in excess of 95% of the net
assets of the Group and in excess of 95% of total operating income of the Group.
Key audit matters
• Expected Credit Loss (ECL) provision for residential mortgages (Group).
• Recoverability of deferred tax assets (Group).
•
IT controls (Group).
• Business combination accounting, Purchase Price allocation and resulting gain on bargain
purchase (“GOBP” ) (Group).
•
Impairment assessment in respect of the investment in Permanent TSB plc (Company only).
The scope of our audit
As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial statements.
In particular, we looked at where the directors made subjective judgements, for example in respect of significant accounting estimates
that involved making assumptions and considering future events that are inherently uncertain. As in all of our audits we also addressed
the risk of management override of internal controls, including evaluating whether there was evidence of bias by the directors that
represented a risk of material misstatement due to fraud.
Key audit matters
Key audit matters are those matters that, in the auditors’ professional judgement, were of most significance in the audit of the financial
statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to fraud)
identified by the auditors, including those which had the greatest effect on: the overall audit strategy; the allocation of resources in the
audit; and directing the efforts of the engagement team. These matters, and any comments we make on the results of our procedures
thereon, were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do
not provide a separate opinion on these matters. This is not a complete list of all risks identified by our audit.
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Independent auditors’ report to the members
of permanent tsb Group Holdings plc
(continued)
Key audit matter
How our audit addressed the key audit matter
Expected Credit Loss (ECL) provision for residential
mortgages (Group)
Refer to note 1 (Summary of significant accounting policies),
note 2 (Critical accounting estimates and judgements) and
note 23 (Impairment provisions) to the Consolidated financial
statements.
IFRS 9 requires impairment models where losses are recognised
on an expected, forward-looking basis including reflecting the
Group’s view of potential future economic events.
We determined the ECL calculation to be a key audit matter as it
is a complex estimation which requires significant management
judgement.
We focussed on the areas which required the greatest level of
management judgement in relation to residential mortgages as
detailed below:
1. The application of forward-looking information is a critical
part of the determination of ECL. The consideration and
selection of appropriate macroeconomic variables and in
particular determining the appropriate economic scenarios
(base, downside and upside) and their associated probability
weightings is a key driver of the overall ECL provision.
2. The determination of when there has been a significant
increase in credit risk (SICR) is one of the key judgements
in the ECL process because a SICR requires the related
impairment provision to be measured using a lifetime
ECL rather than 12-month ECL. The completeness of the
identification of SICR triggers and their correct application
has a significant impact on the overall provision.
3. The consideration of the need for post model adjustments to
address known model limitations, latent risks and emerging
trends. These adjustments are by their nature inherently
uncertain and require significant judgement.
With the assistance of our internal credit modelling specialists,
we understood and critically assessed the overall methodology
applied, including individual models used, in the measurement
of ECL for the residential mortgage portfolio to ensure that the
provision was in accordance with IFRS 9. This included an end-
to-end review to understand the key systems and controls in
the process.
We tested the accuracy of critical data inputs used in the
impairment models on a sample basis by agreeing inputs to
source systems and supporting documentation.
We considered the overall control framework and tested key
controls including controls relating to model performance,
approval of model changes, approval of SICR triggers, approval
of material macroeconomic variables for forward looking
information and approval of post model adjustments.
We compared the base case forward looking macroeconomic
assumptions, provided by management’s external economic
consultant, to publicly available information where applicable.
We also considered the reasonableness of management’s
downside and upside assumptions.
We assessed the SICR triggers identified by management for
appropriateness and completeness and we re-performed key
aspects of the SICR calculation. We also selected a sample
of loans to ensure that they were allocated to the appropriate
stage.
We understood and assessed the appropriateness of material
post model adjustments made by management to adjust their
model output for known limitations and specific risk aspects of
the portfolio, including those which were applied as a result of
increased uncertainty in respect of the current macroeconomic
environment.
We concluded that the ECL provision for residential mortgages
is within an acceptable range of reasonable estimates.
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Key audit matter
How our audit addressed the key audit matter
Recoverability of deferred tax assets (Group)
Refer to note 1 (Significant accounting policies), note 2 (Critical
accounting estimates and judgements) and note 27 (Deferred
taxation) to the Consolidated financial statements.
Management prepares a Medium-Term Plan to forecast
financial performance over a five-year period. We understood
and tested key controls over the production and approval of the
Group’s Medium-Term Plan.
The Group has net deferred tax assets of €309 million that
primarily arise due to historical operating losses. A key
judgement in the recognition of these net deferred tax assets
is whether there is convincing evidence of sufficient future
taxable profits against which those losses can be utilised.
This judgement relies on the assessment of the probability and
the sufficiency of future taxable profits, which in turn is based
on assumptions concerning future economic conditions and
business performance.
The Group’s considerations in respect of the recognition of the
net deferred tax assets are outlined in the financial statements,
which also provides an overview of the key assumptions
underpinning the financial projections.
We determined this to be a key audit matter due to the level of
judgement involved.
We assessed the forecast of taxable profits which informed
management’s decision to recognise a deferred tax asset in
respect of tax losses arising from historic operating losses.
We considered whether the forecast of taxable profits provides
convincing evidence that sufficient taxable profits will be
available to utilise unused tax losses. We assessed the relevant
macroeconomic assumptions and growth assumptions
underlying the projections in the context of economic
consensus forecasts.
We also evaluated the growth assumptions for reasonableness
by reference to historic performance, future plans and external
data as appropriate. We also considered the appropriateness of
the growth rate used to extrapolate the forecast profits over the
period beyond the detailed plan.
We concluded that the Group’s net deferred tax assets meet the
requirements for recognition under IAS 12.
We have also considered the disclosures included in the
financial statements and concluded that they were appropriate.
IT controls (Group)
The IT framework of the Group incorporates a number of IT
systems which have been in place for many years.
We involved our IT audit specialists to update our understanding
of the Group’s IT environment and of changes made to it during
2022.
We determined IT controls to be a key audit matter due to their
pervasiveness to the financial reporting controls and systems.
To the extent required for our audit, we assessed and tested the
design and operating effectiveness of IT controls over financial
reporting systems relating to access security, IT operations and
change control management, including assessing and testing
mitigating controls where relevant.
We performed other procedures as we considered necessary
for the purposes of our audit where deficiencies were identified.
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Independent auditors’ report to the members
of permanent tsb Group Holdings plc
(continued)
Key audit matter
How our audit addressed the key audit matter
The directors appointed a number of experts to assist them in
their determination of the significant accounting judgement and
estimates. We have evaluated the competence, objectivity and
independence of these experts.
We critically assessed the rationale for the directors’
determination that the transaction is a business combination
under IFRS 3.
We reviewed the detailed valuation reports supporting the
calculation of the final fair values of the net assets acquired to
assess whether the valuation methodology is appropriate and in
accordance with IFRS.
We agreed the overall loan book balances to the data tapes
received by the Group from Ulster Bank. We identified the
key data elements in the data tapes which were used in the
valuation model and tested these data inputs on a sample basis.
We built a challenger model to assess the valuation of the
loan books and related derivatives with the assistance of
our market risk specialists and compared our values to the
directors’ valuation reports to assess the reasonableness of the
estimates.
We recalculated the GOBP.
We concluded that business combination accounting under
IFRS 3 is appropriate, and that the fair value of the net assets
acquired and resulting GOBP are materially within an acceptable
range of reasonable estimates.
Business combination accounting, Purchase Price allocation
and resulting gain on bargain purchase (“GOBP” ) (Group)
Refer to note 1 (Significant accounting policies), note 2 (Critical
accounting estimates and judgements) and note 3 (Business
combination) to the Consolidated financial statements.
As set out in note 2, on 17 December 2021, Permanent TSB plc
(the “Bank” or “PTSB”), a wholly owned subsidiary of Permanent
TSB Group Holdings plc (the “Group” or “PTSBGH”), entered into
a conditional agreement to acquire a business from Ulster Bank
consisting of certain elements of its non-tracker residential
mortgage portfolio, SME portfolio and Asset Finance portfolio
(the “loan books”). The acquisition also included 25 branches
and the workforce associated with the various businesses and
branches. The agreement became unconditional on 7 November
2022 and the Group took possession of the majority of the
mortgage book and its associated workforce on this date with
the remaining assets anticipated to be transferred at various
dates after the year end in 2023.
The agreement was accounted for as a business combination
on 7 November 2022 with the remaining assets transferring in
2023 under the agreement being accounted for as derivatives
in the Consolidated financial statements. The directors
determined the final fair values and recognised a gain on bargain
purchase (“GOBP”) of €362m in the income statement under
IFRS 3. This amount was transferred to the share premium
account in accordance with the requirements of the Companies
Act 2014.
We determined this to be a key audit matter as:
• this is a significant transaction to the Group and is material
in the context of the profit before tax for the year and total
assets of the Group;
• the determination of whether this transaction is a business
combination is a significant accounting judgement; and
• the estimation of fair values of net assets acquired and the
resulting GOBP are significant accounting estimates.
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Permanent TSB Group Holdings plc - Annual Report 2022
Key audit matter
How our audit addressed the key audit matter
Impairment assessment in respect of the investment in
Permanent TSB plc (Company only)
Refer to note 1 (Significant accounting policies), note 2 (Critical
accounting estimates and judgements) to the Consolidated
financial statements and note C to the Company financial
statements.
The investment in the subsidiary is shown at cost in the
Company financial statements unless there is evidence of
impairment, in which case it is shown at the lower of cost and
recoverable amount.
As set out in note C, impairment provisions of €697 million
recognised in previous years were reversed in the current
year as the estimated recoverable amount of the investment
exceeded the carrying amount before impairment provisions.
We determined this to be a key audit matter given the scale
of the investment and because the determination of whether
an impairment reversal is appropriate involves significant
judgement in estimating the future results of the business and
determining the appropriate discount rate to use.
We evaluated management’s assessment of the recoverable
amount of the investment and the resulting impairment reversal
of €697 million at 31 December 2022.
The assessment of the recoverable amount of the investment
was based on the Company’s value in use calculation. We
assessed the forecast of free cash flows which informs
management’s calculations and concluded that they were
consistent with the Group’s Medium Term Plan. We assessed
the relevant macroeconomic assumptions underlying the
projections in the context of economic consensus forecasts.
We evaluated the growth assumptions by reference to historic
performance, future plans and external data as appropriate.
We considered the appropriateness of the growth rate used
to extrapolate the forecast profits over the period beyond the
detailed plan.
We challenged management’s calculation of the discount rate
used by recalculating an acceptable range of discount rates
using observable inputs from independent external sources and
concluded the discount rate used by management fell within
that range.
We concluded that the impairment release in respect of the
investment in Permanent TSB plc is acceptable.
How we tailored the audit scope
We tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the financial statements
as a whole, taking into account the structure of the Group, the accounting processes and controls, and the industry in which the Group
operates.
Permanent TSB plc is the main trading entity of the Group. The Group has no other significant subsidiaries. We determined that an audit
of the full financial information of Permanent TSB plc should be performed, which represents in excess of 95% of the net assets of the
Group and in excess of 95% of the total operating income of the Group. The nature and extent of audit procedures was determined by our
risk assessment for each account balance.
Materiality
The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for materiality. These,
together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit
procedures on the individual financial statement line items and disclosures and in evaluating the effect of misstatements, both
individually and in aggregate on the financial statements as a whole.
Based on our professional judgement, we determined materiality for the financial statements as a whole as follows:
Overall materiality
How we determined it
Rationale for benchmark applied
Consolidated financial statements
Company financial statements
€13.0 million (2021: €10.0 million).
€13.0 million (2021: €9.5 million).
c. 0.56% of net assets (2021: c. 0.56% of
net assets)
c. 0.56% of net assets (c. 1% of net
assets)
Given the volatility in profit / loss before
taxation arising over recent years from
elevated impairments and reductions
and the scale of losses arising from
exceptional activities, we believe that
net assets, rather than profitability,
provide us with a more appropriate
and consistent year on year basis for
determining materiality.
Given the activity of the Company is
mainly limited to its investment in PTSB
plc, a benchmark based on net assets
rather than profitability is considered
more appropriate.
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Independent auditors’ report to the members
of permanent tsb Group Holdings plc
(continued)
We use performance materiality to reduce to an appropriately low level the probability that the aggregate of uncorrected and undetected
misstatements exceeds overall materiality. Specifically, we use performance materiality in determining the scope of our audit and the
nature and extent of our testing of account balances, classes of transactions and disclosures, for example in determining sample sizes.
Our performance materiality was 75% of overall materiality, amounting to €9.75 million (Group audit) and €9.75 million (Company audit).
In determining the performance materiality, we considered a number of factors - the history of misstatements, risk assessment and
aggregation risk and the effectiveness of controls - and concluded that an amount at the upper end of our normal range was appropriate.
We agreed with the Audit Committee that we would report to them misstatements identified during our audit above €650,000 (group
audit) (2021: €504,280) and €650,000 (Company audit) (2021: €476,500) as well as misstatements below that amount that, in our view,
warranted reporting for qualitative reasons.
Conclusions relating to going concern
Our evaluation of the directors’ assessment of the Group and Company’s ability to continue to adopt the going concern basis of
accounting included:
• Performing a risk assessment to identify factors that could impact the going concern basis of accounting.
• Understanding and evaluating the Group’s financial forecasts and the Group’s stress testing of liquidity and regulatory capital. In
evaluating these forecasts we considered the Group’s financial position, historic performance, its past record of achieving strategic
objectives and management’s assessment of the financial performance, capital and liquidity for a period of 12 months from the date
on which the financial statements are authorised for issue.
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 or the Company’s ability to continue as a going concern for a period of at least
twelve months from the date on which the financial statements are authorised for issue.
In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of accounting in the
preparation of the financial statements is appropriate.
However, because not all future events or conditions can be predicted, this conclusion is not a guarantee as to the Group’s or the
Company’s ability to continue as a going concern.
In relation to the Company’s reporting on how they have applied the UK Corporate Governance Code, we have nothing material to add or
draw attention to in relation to the directors’ statement in the financial statements about whether the directors considered it appropriate
to adopt the going concern basis of accounting.
We are required to report if the directors’ statement relating to going concern in accordance with Rule 6.1.82 (3) (a) of the Listing Rules
for Euronext Dublin is materially inconsistent with our knowledge obtained in the audit. We have nothing to report in respect of this
responsibility.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this
report.
Reporting on other information
The other information comprises all of the information in the Annual Report other than the financial statements and our auditors’ report
thereon. The directors are responsible for the other information. Our opinion on the financial statements does not cover the other
information and, accordingly, we do not express an audit opinion or, except to the extent otherwise explicitly stated in this report, any
form of assurance thereon.
In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider
whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit, or
otherwise appears to be materially misstated. If we identify an apparent material inconsistency or material misstatement, we are
required to perform procedures to conclude whether there is a material misstatement of the financial statements or a material
misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of
this other information, we are required to report that fact. We have nothing to report based on these responsibilities.
With respect to the Directors’ Report, we also considered whether the disclosures required by the Companies Act 2014 (excluding the
information included in the “Non Financial Statement” as defined by that Act on which we are not required to report) have been included.
Based on the responsibilities described above and our work undertaken in the course of the audit, ISAs (Ireland) and the Companies Act
2014 require us to also report certain opinions and matters as described below.
•
In our opinion, based on the work undertaken in the course of the audit, the information given in the Directors’ Report (excluding the
information included in the “Non Financial Statement” on which we are not required to report) for the year ended 31 December 2022 is
consistent with the financial statements and has been prepared in accordance with the applicable legal requirements.
154
Permanent TSB Group Holdings plc - Annual Report 2022 • Based on our knowledge and understanding of the Group and Company and their environment obtained in the course of the audit,
we did not identify any material misstatements in the Directors’ Report (excluding the information included in the “Non Financial
Statement” on which we are not required to report).
•
In our opinion, based on the work undertaken in the course of the audit of the financial statements,
- the description of the main features of the internal control and risk management systems in relation to the financial reporting
process; and
- the information required by Section 1373(2)(d) of the Companies Act 2014;
included in the Corporate Governance Statement, is consistent with the financial statements and has been prepared in accordance
with section 1373(2) of the Companies Act 2014.
• Based on our knowledge and understanding of the Company and its environment obtained in the course of the audit of the financial
statements, we have not identified material misstatements in the description of the main features of the internal control and
risk management systems in relation to the financial reporting process and the information required by section 1373(2)(d) of the
Companies Act 2014 included in the Corporate Governance Statement.
•
In our opinion, based on the work undertaken during the course of the audit of the financial statements, the information required
by section 1373(2)(a),(b),(e) and (f) of the Companies Act 2014 and regulation 6 of the European Union (Disclosure of Non-Financial
and Diversity Information by certain large undertakings and groups) Regulations 2017 is contained in the Corporate Governance
Statement.
Corporate Governance Statement
The Listing Rules and ISAs (Ireland) require us to review the directors’ statements in relation to going concern, longer-term viability
and that part of the Corporate Governance Statement relating to the Company’s compliance with the provisions of the UK Corporate
Governance Code and the Irish Corporate Governance Annex (the “Code”) specified for our review. Our additional responsibilities with
respect to the Corporate Governance Statement as other information are described in the Reporting on other information section of this
report.
Based on the work undertaken as part of our audit, we have concluded that each of the following elements of the Corporate Governance
Statement is materially consistent with the financial statements and our knowledge obtained during the audit and we have nothing
material to add or draw attention to in relation to:
• The directors’ confirmation that they have carried out a robust assessment of the emerging and principal risks;
• The disclosures in the Annual Report that describe those principal risks, what procedures are in place to identify emerging risks and an
explanation of how these are being managed or mitigated;
• The directors’ statement in the financial statements about whether they considered it appropriate to adopt the going concern basis of
accounting in preparing them, and their identification of any material uncertainties to the Group’s and Company’s ability to continue to
do so over a period of at least twelve months from the date of approval of the financial statements;
• The directors’ explanation as to their assessment of the Group’s and Company’s prospects, the period this assessment covers and why
the period is appropriate; and
• The directors’ statement as to whether they have a reasonable expectation that the Company will be able to continue in operation
and meet its liabilities as they fall due over the period of its assessment, including any related disclosures drawing attention to any
necessary qualifications or assumptions.
Our review of the directors’ statement regarding the longer-term viability of the Group was substantially less in scope than an audit and
only consisted of making inquiries and considering the directors’ process supporting their statement; checking that the statement is in
alignment with the relevant provisions of the UK Corporate Governance Code; and considering whether the statement is consistent with
the financial statements and our knowledge and understanding of the Group and Company and their environment obtained in the course
of the audit.
In addition, based on the work undertaken as part of our audit, we have concluded that each of the following elements of the Corporate
Governance Statement is materially consistent with the financial statements and our knowledge obtained during the audit:
• The directors’ statement that they consider the Annual Report, taken as a whole, is fair, balanced and understandable, and provides the
information necessary for the members to assess the Group’s and Company’s position, performance, business model and strategy;
• The section of the Annual Report that describes the review of effectiveness of risk management and internal control systems; and
• The section of the Annual Report describing the work of the Audit Committee.
We have nothing to report in respect of our responsibility to report when the directors’ statement relating to the Company’s compliance
with the Code does not properly disclose a departure from a relevant provision of the Code specified under the Listing Rules for review by
the auditors.
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of permanent tsb Group Holdings plc
(continued)
Responsibilities for the financial statements and the audit
Responsibilities of the directors for the financial statements
As explained more fully in the Statement of Directors’ Responsibilities set out on page 147, the directors are responsible for the
preparation of the financial statements in accordance with the applicable framework and for being satisfied that they give a true and fair
view.
The directors are also responsible for such internal control as they determine is necessary to enable the preparation of financial
statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the directors are responsible for assessing the Group’s and the Company’s ability to continue as
a going concern, disclosing as applicable, matters related to going concern and using the going concern basis of accounting unless the
directors either intend to liquidate the Group or the Company or to cease operations, or have no realistic alternative but to do so.
Auditors’ responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material
misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinion. Reasonable assurance is a
high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (Ireland) 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.
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our
responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our
procedures are capable of detecting irregularities, including fraud, is detailed below.
Based on our understanding of the Group and industry, we identified that the principal risks of non-compliance with laws and regulations
related to breaches of banking laws and regulations and in particular the regulations related to the consumer protection codes, and we
considered the extent to which non-compliance might have a material effect on the financial statements. We also considered those laws
and regulations that have a direct impact on the preparation of the financial statements such as the Companies Act 2014 and Irish tax
legislation. We evaluated management’s incentives and opportunities for fraudulent manipulation of the financial statements (including
the risk of override of controls), and determined that the principal risks were related to the potential for manual journal entries being
recorded in order to affect performance and management bias through judgement and assumptions in significant accounting estimates.
Audit procedures performed by the engagement team included:
• Enquiries of management including the Head of Legal, Chief Risk Officer, the Head of Compliance, the Head of Tax and those charged
with governance as to any known or suspected instances of non-compliance with laws and regulations, fraud or significant open tax
matters in relation to the financial statements.
•
•
Inspection of board minutes;
Inspection of selected correspondence with the Central Bank of Ireland;
• Challenging assumptions and judgements made by management in their significant accounting estimates,
•
Incorporating an element of unpredictability into the nature, timing and/or extent of our testing; and
• Applying risk-based criteria to journal entries posted in the audit period to determine journal entries for testing purposes.
There are inherent limitations in the audit procedures described above. We are less likely to become aware of instances of non-
compliance with laws and regulations that are not closely related to events and transactions reflected in the financial statements. Also,
the risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting from error, as fraud
may involve deliberate concealment by, for example, forgery or intentional misrepresentations, or through collusion.
Our audit testing might include testing complete populations of certain transactions and balances, possibly using data auditing
techniques. However, it typically involves selecting a limited number of items for testing, rather than testing complete populations. We
will often seek to target particular items for testing based on their size or risk characteristics. In other cases, we will use audit sampling to
enable us to draw a conclusion about the population from which the sample is selected.
A further description of our responsibilities for the audit of the financial statements is located on the IAASA website at:
https://www.iaasa.ie/getmedia/b2389013-1cf6-458b-9b8f-a98202dc9c3a/Description_of_auditors_responsibilities_for_audit.pdf
This description forms part of our auditors’ report.
156
Permanent TSB Group Holdings plc - Annual Report 2022 Use of this report
This report, including the opinions, has been prepared for and only for the Company’s members as a body in accordance with section 391
of the Companies Act 2014 and for no other purpose. We do not, in giving these opinions, accept or assume responsibility for any other
purpose or to any other person to whom this report is shown or into whose hands it may come save where expressly agreed by our prior
consent in writing.
Other required reporting
Companies Act 2014 opinions on other matters
• We have obtained all the information and explanations which we consider necessary for the purposes of our audit.
•
In our opinion the accounting records of the Company were sufficient to permit the Company financial statements to be readily and
properly audited.
• The Company Statements of Financial Position is in agreement with the accounting records.
Other exception reporting
Directors’ remuneration and transactions
Under the Companies Act 2014 we are required to report to you if, in our opinion, the disclosures of directors’ remuneration and
transactions specified by sections 305 to 312 of that Act have not been made. We have no exceptions to report arising from this
responsibility.
We are required by the Listing Rules to review the six specified elements of disclosures in the report to shareholders by the Board on
directors’ remuneration. We have no exceptions to report arising from this responsibility.
Prior financial year Non Financial Statement
We are required to report if the Company has not provided the information required by Regulation 5(2) to 5(7) of the European Union
(Disclosure of Non-Financial and Diversity Information by certain large undertakings and groups) Regulations 2017 in respect of the prior
financial year. We have nothing to report arising from this responsibility.
Prior financial year Remuneration Report
We are required to report if the Company has not provided the information required by Section 1110N of the Companies Act 2014 in
respect of the prior financial year. We have nothing to report arising from this responsibility.
Appointment
We were appointed by the members on 23 May 2013 to audit the financial statements for the year ended 31 December 2013 and
subsequent financial periods. The period of total uninterrupted engagement is 10 years, covering the years ended 31 December 2013 to
31 December 2022.
John McDonnell
for and on behalf of PricewaterhouseCoopers
Chartered Accountants and Statutory Audit Firm
Dublin
28 February 2023
157
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Consolidated Income Statement
For the year ended 31 December 2022
Interest income
Interest expense
Net interest income
Fees and commission income
Fees and commission expense
Net trading income
Net other operating income
Exceptional items
Gain on bargain purchase
Total operating income
Administrative, staff and other expenses (excluding exceptional items)
Bank levy and other regulatory charges
Depreciation of property and equipment
Amortisation of intangible assets
Reversal of impairment of property and equipment
Exceptional items
Restructuring and other costs
Costs incurred in relation to the Ulster Bank transaction
Total operating expenses
Operating profit/(loss) /profit/(loss) before credit impairment and taxation
Credit impairment
Loans and advances to customers
Exceptional impairment arising from deleveraging of loans
Total credit impairment write-back
Operating profit/(loss) / profit/(loss) before taxation
Taxation
Profit/(loss) / profit/(loss) for the year
Attributable to:
Equity holders of the parent
Earnings/(loss) per ordinary share
Basic earnings/(loss) per share of €0.5 ordinary share
Diluted earnings/(loss) per share of €0.5 ordinary share
Year ended
Year ended
Note
31 December
2022
31 December
2021
€m
417
(55)
362
75
(33)
3
6
362
775
(302)
(51)
(21)
(31)
1
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(92)
(509)
266
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223
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354
(41)
313
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2
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361
(263)
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(26)
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(28)
(402)
(41)
1
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20
(21)
1
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€ Cent
45.4
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(9.0)
5
5
6
6
7
8
11
9
10
25
26
25
11
11
23
11
12
13
13
158
Permanent TSB Group Holdings plc - Annual Report 2022
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Consolidated Statement of Comprehensive Income
For the year ended 31 December 2022
Profit/(loss) / profit/(loss) for the year
Items that will not be reclassified to the income statement in subsequent periods
Fair value reserve (equity instruments)
Change in fair value of equity instruments
Revaluation of property
Tax relating to items that will not be reclassified to the income statement
Items that may be reclassified to the income statement in subsequent periods
Change in fair value of debt instruments
Tax relating to items that may be reclassified to the income statement
Other comprehensive (expense)/income, net of tax
Total comprehensive income/(expense) for the year, net of tax
Attributable to:
Equity holders of the parent
Year ended
Year ended
Note
31 December
2022
31 December
2021
36
12
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12
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223
3
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219
219
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(20)
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4
(16)
(16)
Permanent TSB Group Holdings plc - Annual Report 2022
159
Consolidated Statement of Financial Position
As at 31 December 2022
Assets
Cash at bank
Items in the course of collection
Loans and advances to banks
Derivative financial instruments
Other assets
Assets classified as held for sale
Debt securities
Equity securities
Prepayments and accrued income
Loans and advances to customers
Interest in associated undertakings
Property and equipment
Intangible assets
Deferred taxation
Total assets
Liabilities
Deposits by banks
Customer accounts
Derivative financial instruments
Debt securities in issue
Other liabilities
Accruals
Current tax liability
Provisions
Subordinated liabilities
Total liabilities
Equity
Share capital
Share premium
Other reserves
Retained earnings
Shareholders’ equity
Other equity instruments
Total equity
Total liabilities and equity
On behalf of the Board:
Note
31 December
2022
31 December
2021
€m
€m
14
14
15
16
17
18
19
20
21
22
24
25
26
27
28
29
16
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31
32
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35
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13
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160
309
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1,666
123
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25,933
22,235
Robert Elliott
Chairman
Eamonn Crowley
Chief Executive
Nicola O’Brien
Chief Financial Officer
Conor Ryan
Company Secretary
160
Permanent TSB Group Holdings plc - Annual Report 2022
Consolidated Statement of Changes in Equity
For the year ended 31 December 2022
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Permanent TSB Group Holdings plc - Annual Report 2022
161
Consolidated Statement of Cash Flows
For the year ended 31 December 2022
Cash flows from operating activities
Operating profit/(loss) / profit/(loss) before taxation
Adjusted for non-cash items and other adjustments:
Depreciation, amortisation and impairment of property, equipment and intangibles
(Gain)/loss on revaluation of property
Impairment (write-back)/charge on:
- Loans and advances to customers
Unrealised (gains)/losses on financial assets
Other income
Other mortgage related adjustments
Other provisions
Gain on bargain purchase
Other non-cash items
(Increase)/decrease in operating assets:
Derivative financial instruments
Other assets
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Prepayments and accrued income
Loans and advances to customers
Increase/(decrease) in operating liabilities:
Deposits by banks
Customer accounts
Debt securities in issue
Derivative liabilities
Other liabilities and accruals
Provisions
Net cash (outflow)/inflow from operating activities before tax
Tax paid
Net cash (outflow)/inflow from operating activities
31 December
31 December
2022
€m
267
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720
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719
162
Permanent TSB Group Holdings plc - Annual Report 2022
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Consolidated Statement of Cash Flows
For the year ended 31 December 2022 (continued)
Cash flows from investing activities
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Purchase of property and equipment
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Interest paid on T2 capital notes
AT1 coupon payment
Issuance of T2 capital notes (including interest)
Net cash flows from financing activities
(Decrease)/increase in cash and cash equivalents
Analysis of changes in cash and cash equivalents
Cash and cash equivalents as at 1 January
Increase/(decrease) in cash and cash equivalents
Cash and cash equivalents as at 31 December
31 December
31 December
2022
€m
251
(972)
(31)
(30)
(4,816)
-
(11)
(5,609)
245
-
(6)
(8)
(10)
-
221
(2,030)
4,251
(2,030)
2,221
2021
€m
49
-
(13)
(11)
-
3
(2)
26
-
(125)
(3)
(21)
252
103
848
3,403
848
4,251
* Due to an IFRIC decision, restricted cash held by the Groups securitisation entities, which was excluded from cash and cash equivalents in prior years is now included in cash and
cash equivalents for 2022 and 2021. See note 14
Reconciliation of liabilities arising from financing activities
1 January
Financing cash flows:
Lease liability
Issuance of T2 capital notes (including interest)
Interest paid on T2 capital notes
Non-cash movements:
Additions to lease liabilities
Interest accrued on T2 capital notes
31 December
31 December
31 December
2022
€m
283
(6)
-
(8)
13
8
290
2021
€m
34
(3)
252
-
-
-
283
Permanent TSB Group Holdings plc - Annual Report 2022
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Notes to the Consolidated Financial Statements
Notes
1. Corporate information, basis of preparation and significant accounting policies
2. Critical accounting estimates and judgements
3. Business combination
4. Operating segments
5. Net interest income
6. Fees and commission income
7. Net trading income
8. Net other operating income
9. Administrative, staff and other expenses (excluding exceptional items)
10. Bank levy and other regulatory charges
11. Exceptional items
12. Taxation
13. Earnings/(loss) per ordinary share
14. Cash and cash equivalents
15. Loans and advances to banks
16. Derivative financial instruments
17. Other assets
18. Assets classified as held for sale
19. Debt securities
20. Equity securities
21. Prepayments and accrued income
22. Loans and advances to customers
23. Impairment provisions
24. Interest in associated undertakings
25. Property and equipment
26. Intangible assets
27. Deferred taxation
28. Deposits by banks
29. Customer accounts
30. Debt securities in issue
31. Other liabilities
32. Provisions
33. Subordinated liabilities
34. Leases
35. Share capital, reserves and other equity instruments
36. Analysis of other comprehensive income
37. Measurement basis and fair values of financial instruments
38. Financial risk management
39. Capital management
40. Current/non-current assets and liabilities
41. Transfer of financial assets
42. Offsetting financial assets and financial liabilities
43. Commitments and contingencies
44. Related parties
45. Sale of loans and advances to customers
46. Principal subsidiary undertakings and interest in subsidiaries and structured entities
47. Reporting currency and exchange rates
48. Events after the reporting period
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1. Corporate information, basis of preparation and significant accounting policies
1.1 Corporate information
Permanent TSB Group Holdings plc (the Company) is a holding company domiciled in Ireland (registration number 474438). Its registered
office is situated at 56 - 59, St. Stephen’s Green, Dublin 2, Ireland. The Company’s shares are listed on the main market of the Irish and
London Stock Exchanges.
The consolidated financial statements include the financial statements of the Company and its subsidiaries (together referred to as the
Group) and are prepared up to the end of the financial year, 31 December 2022.
Permanent TSB plc (PTSB), a 100% owned subsidiary of the Company, is the main trading entity of the Group which is involved in retail
banking.
These consolidated financial statements for the year ended 31 December 2022 were approved by the Board and authorised for issue by
the Directors on 28 February 2023.
The accounting policies applied in the preparation of the financial statements for the year ended 31 December 2022 are set out below.
1.2 Basis of preparation
Statement of compliance
These consolidated financial statements comprise of the consolidated income statement, the consolidated statement of comprehensive
income, the consolidated statement of financial position, the consolidated statement of changes in equity, the consolidated statement of
cash flows, the Company SOFP, the Company statement of changes in equity, the Company statement of cash flows and the notes to the
consolidated and the Company financial statements have been prepared in accordance with IFRS and interpretations issued by the IFR
Interpretations Committee (IFRIC) as adopted by the EU and those parts of the Companies Act 2014 applicable to companies reporting
under IFRS and EU (Credit Institutions: Financial Statements) Regulations 2015.
The accounting policies have been consistently applied by the Group entities and are consistent with the previous year.
The financial statements include the information that is described as being an integral part of the audited financial statements contained
in the Directors’ Report on Remuneration and in Risk Management. Certain tables and related information in the notes to the financial
statements, included in boxes and clearly identified as unaudited do not form part of the audited financial statements.
The individual financial statements of the holding company have also been prepared in accordance with IFRS and interpretations issued
by IFRIC as adopted by the EU and those parts of the Companies Act 2014 applicable to companies reporting under IFRS. In accordance
with section 304(2) of the Companies Act 2014, the Company is availing of the exemption from presenting its individual income statement
and related notes to the AGM and from filing it with the Registrar of Companies. See note 46 for further information.
The Company’s profit after tax for the year ended 31 December 2022 was €708m (31 December 2021: loss €56m). The Company issued
€250,000,000 Additional Tier 1 securities on 26 October 2022. For further information, see the Company financial statements on pages
263 to 265.
Basis of measurement
The consolidated and Company financial statements have been prepared on the historical cost basis as modified to include the fair
valuation of certain financial instruments classified as HTC&S, equity securities classified as FVOCI, derivative financial instruments,
assets classified as held for sale, financial assets and liabilities designated as hedged items in qualifying fair value hedge relationships, and
land and buildings accounted for using the revaluation model.
Functional and presentation currency
These financial statements are presented in Euro, which is the Company’s functional currency. Except where otherwise indicated,
financial information presented in Euro has been rounded to the nearest million (m).
Use of estimates and judgements
The preparation of these consolidated financial statements, in conformity with IFRS, requires Management to make judgements,
estimates and assumptions that affect the application of accounting policies and the reported amounts of assets, liabilities, income,
expenses and related disclosures.
While the actual results may differ from the estimates made, the Directors believe that they are reasonable in the current circumstances
based on the best available information at the date of the approval of these consolidated financial statements.
Permanent TSB Group Holdings plc - Annual Report 2022
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Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Additional information about key assumptions and judgements are disclosed in the relevant notes for the following areas including
significant estimation uncertainty:
• Allowance for credit impairment losses (note 23);
• Deferred taxation (notes 12 and 27);
• Fair value of financial instruments (note 37);
•
• Fair value assumptions in relation to business combination accounting (note 2).
•
Impairment review of subsidiary undertaking (note 46).
IFRS 3 Business Combination Accounting (BCA) including fair value of acquired assets (note 3)
The estimates and assumptions are reviewed on an on-going basis and where necessary are revised to reflect current conditions. The
principal estimates and assumptions made by Management relate to impairment of loans and advances to customers, deferred taxation,
impairment of investment in subsidiary undertakings and financial instruments. Judgements made by Management that have a significant
effect on the financial statements and estimates with a significant risk of material adjustment in the next year are discussed in note 2.
1.3 Going Concern
In considering Management’s assessment of the Group’s and Company’s ability to continue as a going concern, Management considered
the principal risks and uncertainties as they might pertain to the going concern assumption, particularly the liquidity, profitability, and
capital position. Management considered these items over the course of the year to date and into 2023, their current status, and future
projections.
In doing so, Management considered each risk in turn, and the likelihood of the risk precipitating in the going concern assumptions
becoming invalid over the period of assessment, being twelve months from the date of the approval of the financial statements for the
year ended 31 December 2022. Management considered realistic alternatives, including downside scenarios applied by the Group and
Company to test assumptions and potential outcomes.
Assessment Basis
The time that the Directors and Management have considered in evaluating the appropriateness of the going concern basis in preparing
the Company consolidated financial statements for the twelve months ended 31 December 2022 is a period of twelve months from the
date of approval of these financial statements (28 February 2024).
In making this assessment, the Directors and Management have considered the Group’s and Company’s 2023-2027 MTP, profitability
forecasts, funding and capital resource projections. These projections include both base and stress scenarios applied by the Group and
Company. Together with a number of factors such as the Irish Economy, Government fiscal policies, the availability of collateral to access
funding through third parties and the euro-system, and on-going changes in the regulatory environment.
Economic and political environment
The Irish economy continues to perform strongly with a rapid recovery after the pandemic. Growth is continued to be forecast albeit at a
lower rate. Consumer price inflation has risen due to increases in energy prices along with price pressures for other goods and services. To
manage inflation, the ECB raised interest rates on a number of occasions during 2022 with further rate increases expected in 2023.
Further to this, the Group and Company continues to be materially reliant on Government and EU policy, and materially impacted by
geopolitical events; such as the on-going war in Ukraine, the continuing uncertainty around the Northern Irish Protocol and the
introduction of the global minimum corporation tax rate to a sector of the Irish market.
The Group and Company reassessed the financial impacts of the economic and political environment through the Group’s and Company’s
integrated planning process and believes it is reasonably well positioned to withstand any volatility from economic events, particularly
given the Group’s and Company’s acquisition of certain part of the Ulster Bank business in 2022 and continued management of its
financial position through NPL reduction and capital management.
Funding & Liquidity
The Group and Company continued to have sufficient liquidity throughout 2022, and continues to undertake initiatives to improve its
liquidity position in the areas of deposits, collateral optimisation, and wholesale markets activity. The Directors and Management have also
considered forecasts of the liquidity position over the going concern period, under a range of stress scenarios.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
The Group and Company continues to hold a significant liquidity buffer at 31 December 2022 that can be easily and readily monetised in a
period of stress. The Directors and Management are aware that the Group’s and Company’s ability to effectively utilise its contingent
counterbalancing capacity is dependent on the underlying collateral remaining eligible. However, the Directors and Management are
satisfied, based on a review of funding plans, interaction with wholesale markets and deposit trends that the required liquidity and funding
will be available to the Group and Company during the period of assessment.
There are no material uncertainties, which would cast significant doubt on the ability of the Group and Company to continue as a going
concern basis over the period of assessment.
Profitability and Capital Adequacy
The Group and Company made a profit for the year ended 31 December 2022. Directors and Management have reviewed the MTP and
based on this, the near-term macro-economic conditions of the country and the resolution of legacy issues, the Directors and
Management are satisfied that the Group and Company are well positioned to continue to deliver profits in future years.
The Directors and Management have also considered the Group’s and Company’s forecast capital position, including a deterioration in
economic conditions due to high inflation and disruptions to the global supply chain. Based on the above considerations, the Directors and
Management have assessed and concluded that this does not give rise to a material uncertainty, which would cast significant doubt on the
ability of the Group and Company to continue on a going concern basis for the period of assessment.
Conclusion
As required by IFRS as adopted by the EU, the Directors and Management have considered the principal risks and uncertainties facing the
Group and Company as outlined above. Based on the latest and projected financial performance and position, and the options available to
the Group and Company, the Directors have concluded that the Group and Company have no material uncertainties, which would cast
significant doubt on the going concern assumption and have considered it appropriate to prepare the financial statements on a going
concern basis.
1.4 Comparative information
The comparative information for 2021 has been prepared on a consistent basis with 2022.
1.5 Summary of significant accounting policies
(i) Basis of consolidation
Subsidiaries
Subsidiaries are those entities (including special purpose entities) controlled by the Group. Control exists when the Group has:
the power, directly or indirectly, over the relevant activities of the investee, for example through voting or other rights;
•
• exposure to, or rights to, variable returns through involvement with the investee; and
•
the ability to use its power over the investee to affect the Group’s return from the entity.
The financial statements of subsidiaries are included in the consolidated financial statements from the date that control commences until
the date that control ceases. Financial statements of subsidiaries are prepared up to the financial position date. Intercompany transaction
balances and unrealised gains/losses on transactions between the Group’s companies are eliminated on consolidation.
The Company carries its investment in its subsidiary undertaking at cost in the Company financial statements and reviews whether there
is any indication of impairment at each reporting date. Impairment testing involves comparing the carrying value of the investment to its
recoverable amount. The recoverable amount is the higher of the investment’s fair value or its VIU. If impairment occurs, this loss is
recognised in the income statement.
Details of principal subsidiaries are included in note 46.
Interest in associated undertakings
Interest in associated undertakings encompass investments in entities whereby the Group has significant influence over the financial and
operating policy decisions of the entity but does not have control. It is presumed that significant influence exists if the Group holds more
than 20% of the voting rights in the entity unless it can be demonstrated otherwise. Conversely the Group may hold less than 20% of the
voting rights but could be demonstrated to have significant influence.
Permanent TSB Group Holdings plc - Annual Report 2022
167
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Interest in associated undertakings are initially recognised at cost and subsequently accounted for using the equity method whereby the
investment is increased or decreased each year by the Group’s share of the post-acquisition profit or loss of the associate. The Group’s
share of the post-acquisition profit or loss of the associate is recognised in profit or loss and OCI.
The Group continues to decrease the carrying amount of the investment for its’ share of post-acquisition losses until the carrying amount
is zero unless the Group has incurred a legal or constructive obligation or made payments on behalf of the associate. These additional
losses are provided for and a liability is recognised in this instance.
(ii) Business combinations and goodwill
(a) Business combinations
The Group accounts for business combinations, other than those under common control, using the acquisition method when the acquired
set of activities and assets meets the definition of a business and control is transferred to the Group (see 1.5(i)).
In determining whether a particular set of activities and assets is a business, the Group assesses whether the set of assets and activities
acquired includes, at a minimum, an input and substantive process and whether the acquired set has the ability to produce outputs.
The consideration transferred in the acquisition is generally measured at the fair value of the assets transferred, the liabilities incurred to
the former owners and equity interest issued by the Group. Identifiable assets acquired and liabilities and contingent liabilities assumed in
a business combination are measured initially at their fair values at the acquisition date. Transaction costs are expensed as incurred,
except if related to the issue of debt or equity securities (see (vii)(a)). The consideration transferred does not include amounts related to
the settlement of pre-existing relationships. Such amounts are generally recognised in the income statement. Any contingent
consideration is measured at fair value at the date of acquisition. If an obligation to pay contingent consideration that meets the definition
of a financial instrument is classified as equity, then it is not re-measured and settlement is accounted for within equity. Otherwise, other
contingent consideration is re-measured at fair value at each reporting date and subsequent changes in the fair value of the contingent
consideration are recognised in the income statement.
The results of subsidiaries acquired are included in the consolidated income statement from the date of acquisition. Profits or losses of
subsidiary undertakings acquired or sold during the year are included in the consolidated results from the date of gaining control or up to
the date of disposal.
For each business combination, the Group elects on a transaction-by-transaction basis whether to measure a non-controlling interest at
its fair value or at its proportionate share of the recognised amount of identifiable net assets. The assets and liabilities arising on a
business combination are measured at their fair value at the acquisition date.
Business combinations under common control are accounted for prospectively from the date the Group obtains the ownership interest in
the acquired entity. Assets and liabilities are initially recognised upon consolidation based on their carrying amount in the financial
statements of the acquired entity (or holding entity, if applicable). Any difference between the fair value of the consideration paid and the
amounts at which the assets and liabilities are initially recorded is recognised directly in equity in retained earnings.
(b) Goodwill
The Group measures goodwill as the excess of the (i) consideration transferred; (ii) the amount of any non-controlling interest in the
acquired entity; and (iii) acquisition date fair value of any previous equity interest in the acquired entity over the fair value of the net
identifiable assets acquired. If those amounts are less than the fair value of the net identifiable assets of the business acquired, the
difference is recognised directly in profit or loss as a bargain purchase.
Acquisition costs are expensed to the income statement as incurred. Any contingent consideration to be transferred to the acquirer is
recognised at fair value at the acquisition date. Subsequent changes to the fair value of the contingent consideration which is deemed to
be an asset or liability are recognised in accordance with IFRS 9.
Goodwill arising on associates is shown as part of the investment in the associate.
Goodwill is subject to an impairment review at least annually, and, if events or changes in circumstances indicate that the carrying amount
may not be recoverable, it is written down through the income statement by the amount of any impairment loss identified in the year.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
(iii) Foreign currencies
Foreign currency transactions are translated into the functional currency of the entity, being the currency of the primary environment in
which the entity operates at the exchange rate prevailing at the date of the transaction or valuation where items are remeasured.
Monetary assets and liabilities denominated in foreign currency are translated at the exchange rates prevailing at the reporting date.
Exchange movements are recognised in the income statement. However, exchange movements arising from the translation of the
following items are recognised in OCI:
• equity investments in respect of which an election has been made to present subsequent changes in fair value in OCI (see (vii)(a));
• a financial liability designated as a hedge of the net investment in a foreign operation to the extent that the hedge is effective; and
• qualifying cash flow hedges to the extent that the hedges are effective
Non-monetary assets and liabilities that are measured at fair value in a foreign currency are translated into the functional currency at the
spot exchange rate at the date on which the fair value is determined. Non-monetary items that are measured based on historical cost in a
foreign currency are translated using the spot exchange rate at the date of the transaction.
The results and financial position of the Group’s subsidiaries which have a functional currency different from Euro are translated into Euro
as follows:
• Assets and liabilities, including goodwill and fair value adjustments, are translated at the rates of exchange ruling at the reporting date;
•
• All resulting exchange differences are recognised in Other Comprehensive Income (OCI) and as a separate component of equity
Income and expenses are translated at the average exchange rates for the year; and
On consolidation, exchange differences arising from the translation of borrowings and currency instruments designated as hedges of the
net investment in overseas subsidiaries, are also recognised in OCI to the extent to which the hedge is deemed to be effective. The
ineffective portion of any net investment hedge is recognised in the income statement immediately. On disposal, or partial disposal of an
overseas subsidiary, the appropriate portion of the currency translation adjustment reserve is included in the gain or loss on disposal.
(iv) Recognition of income and expenses
(a) Interest and similar income and expenses
For all interest bearing financial instruments, interest income or expense is recorded using the EIR method.
The EIR is the rate that exactly discounts estimated future cash payments or receipts through the expected life of the financial instrument
to:
•
•
the gross carrying amount of the financial asset; or
the amortised cost of the financial liability.
The effective interest rate of a financial asset or financial liability is calculated on initial recognition of a financial asset or a financial
liability. In calculating interest income and expense, the effective interest rate is applied to the gross carrying amount of the asset (when
the asset is not credit-impaired) or to the amortised cost of the liability. The effective interest rate is also revised for fair value hedge
adjustments at the date on which amortisation of the hedge adjustment begins. The calculation of the EIR includes transaction costs,
premiums or discounts, and fees paid or received that are an integral part of the EIR. Transaction costs include incremental costs that are
directly attributable to the acquisition or issue of a financial asset or financial liability.
Interest income is calculated by applying the EIR to the gross carrying amount of financial assets, except for:
1. POCI financial assets, for which the original credit-adjusted EIR is applied to the amortised cost of the financial asset (the calculation of
interest income does not revert to a gross basis, even if the credit risk of the asset improves); and,
2. Financial assets that are not ‘POCI’ but have subsequently become credit-impaired (or ‘Stage 3’), for which interest revenue is
calculated by applying the EIR to their amortised cost (i.e. net of ECL provision). If the asset is no longer credit-impaired, then the
calculation of interest income reverts to the gross basis.
Permanent TSB Group Holdings plc - Annual Report 2022
169
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Interest income and expense calculated using the effective interest method presented in the consolidated income statement includes:
•
•
•
interest on financial assets and financial liabilities measured at amortised cost;
interest on debt instruments measured at FVOCI;
the effective portion of fair value changes in qualifying hedging derivatives designated in cash flow hedges of variability in interest cash
flows, in the same period as the hedged cash flows affect interest income/expense;
the effective portion of fair value changes in qualifying hedging derivatives designated in fair value hedges of interest rate risk;
•
• negative interest on financial liabilities measured at amortised cost;
• negative interest on financial assets measured at amortised cost; and
•
interest expense on lease liabilities.
(b) Fees and commission income and expense
As outlined above, fees and commission income and expense that are integral to the EIR on a financial asset or liability are included in the
measurement of the EIR.
Other fees and commission income are recognised as the related services are performed. Fees and commission expenses relate mainly to
transaction and service fees, which are expensed as the services are received.
(c) Net trading income/(expense)
Net trading income/(expense) comprises gains and losses relating to trading assets and trading liabilities and includes all realised and
unrealised fair value changes, dividends and FX differences.
Dividend income is recognised when the right to receive income is established.
(d) Exceptional items
Certain items, by virtue of their nature and amount are disclosed separately in order for the user to obtain appropriate understanding of
the financial information. These items would not ordinarily occur while carrying out normal business activities.
Exceptional items include gains and losses on the disposal of businesses, gain on bargain purchase in respect of business combinations,
material restructuring costs and material transaction, integration and restructuring costs associated with acquisitions (including potential
acquisitions).
(e) Bank Levy and other regulatory charges
Bank levy and other regulatory charges consist of DGS fees, Central Bank Industry Funding levy, Single Resolution Fund levy, ECB fees
and a bank levy.
A bank levy payable to the Government, is provided for on the occurrence of the event identified by the legislation that triggers the
obligation to pay the levy.
(v) Employee Benefits
(a) Defined contribution pension plan
The Group operates a number of defined contribution pension schemes, under which the Group pays fixed contributions to a separate
entity.
The contribution payable to a defined contribution plan is recorded as an expense under administration, staff and other expenses. Unpaid
contributions are recorded as a liability.
(b) Short term employee benefits
Short term employee benefits, such as salaries and other benefits, are accounted for on an accruals basis over the period in which the
employee’s service is rendered. Bonuses are recognised where the Group has a legal or constructive obligation to employees that can be
reliably measured.
(c) Termination payments
Termination benefits may be payable when employment is terminated by the Group before the normal retirement date, or whenever an
employee accepts voluntary redundancy in exchange for these benefits. The Group recognises termination benefits at the earlier of the
following dates: (a) when the Group can no longer withdraw the offer of those benefits; and (b) when the entity recognises costs for a
restructuring that is within the scope of IAS 37 and involves the payment of termination benefits. In the case of an offer made to
encourage voluntary redundancy, the termination benefits are measured based on the number of employees where the offer is
irrevocable. Benefits falling due more than 12 months after the end of the reporting period are discounted to their present value.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
(vi) Current and deferred taxation
Taxation comprises both current and deferred tax. Taxation is recognised as income or expenses and included in the income statement
except to the extent it relates to a business combination, or items recognised in either OCI or equity. In the former case, taxation is
recognised in OCI while in the latter case, taxation is recognised directly in equity. In a business combination the tax amounts are
recognised as identifiable assets or liabilities at the acquisition date.
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 reporting date and any adjustment to tax payable in respect of previous years (ROI: 12.5% from 1 April 2015).
Deferred tax is provided using the liability method on all temporary differences except those arising on goodwill not deductible for tax
purposes, or on initial recognition of an asset or liability in a transaction that is not a business combination and which at the time of the
transaction affects neither accounting, nor taxable, profit or loss.
Deferred tax is measured at the tax rates enacted or substantively enacted by the reporting date that are expected to be applied to the
temporary differences when they reverse.
Deferred tax liabilities and assets are offset only when they arise in the same tax reporting group and where there is the intention to settle
on a net basis, or to realise the asset and settle the liability simultaneously.
DTAs and liabilities shall be offset if, and only if:
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there is a legally enforceable right to set off current tax assets and liabilities; and
the DTAs and liabilities relate to income taxes levied by the same taxation authority on either:
- the same taxable entity; or
- different taxable entities which intend to settle current tax liabilities and assets on a net basis, or to realise the assets and settle the
liabilities simultaneously, in each future period in which significant amounts of deferred tax liabilities or assets are expected to be
settled or recovered.
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A DTA is recognised for unused tax losses, tax credits and deductible temporary differences, to the extent that it is probable that future
taxable profits will be available against which they can be utilised. DTAs are reviewed at each reporting date and are recognised only to the
extent that it is probable that the related tax benefit will be realised. Deferred tax assets and liabilities are not discounted in accordance
with IAS 12.
Unrecognised DTAs are reassessed at each reporting date and recognised to the extent that it has become probable that future taxable
profits will be available against which they can be used.
(vii) Financial instruments
(a) Classification of financial assets
Financial assets are recorded at fair value and are classified, on initial recognition, as amortised cost, fair value through OCI (FVOCI), fair
value through profit or loss (FVTPL), elected at FVOCI or designated at FVTPL. Purchases and sales of financial assets are recognised on
the trade date, being the date on which the Group commits to purchase or sell the asset.
With the exception of assets classified as FVTPL, the initial fair value of a financial asset includes direct and incremental transaction costs.
The fair value of assets traded on an active market will be the price that would be received if an asset were to be sold in an orderly
transaction between market participants at the measurement date. In the absence of an active market, the Group establishes a fair value
using various valuation techniques that use observable and unobservable inputs. These include recent transactions in similar items,
discounted cash flow projections, option pricing models and other valuation techniques used by market participants.
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Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
The classification requirements for debt and equity instruments are described below.
Debt instruments
Debt instruments, including loans and debt securities, are classified into one of the following measurement categories:
• Amortised cost; or
• FVOCI; or
• FVTPL; or
• Designated at FVTPL.
Classification and subsequent measurement of debt instruments depend on:
(i) The Group’s business model for managing the asset; and
(ii) The cash flow characteristics of the asset.
(i) Business model assessment
The business model reflects how the Group manages the assets in order to generate cash flows. That is, whether the Group’s objective is
solely to collect the contractual cash flows from the assets (HTC) or is to collect both the contractual cash flows and cash flows arising
from the sale of assets (HTC&S). If neither of these is applicable, then the financial assets are classified as part of ‘other’ business model
and measured at FVTPL.
The Group assesses its business model at a portfolio level based on how it manages groups of financial assets to achieve its business
objectives. The observable factors considered include:
• How the performance of the business model and the financial assets held within that business model are evaluated and reported to
Group ExCo;
• How risks that affect the performance of the business model are managed;
• How business managers are compensated; and
• The timing, frequency and volume of sales.
(ii) Cash flow characteristics assessment
The Group carries out the cash flow characteristics assessment using the contractual features of an instrument to determine if they give
rise to cash flows that are consistent with a basic lending arrangement. Contractual cash flows are consistent with a basic lending
arrangement if they represent cash flows that are solely payments of principal and interest (the ‘SPPI’ test). Principal, for the purpose of
this test, is defined as the fair value of the financial asset at initial recognition and may change over the life of the financial asset, for
example, due to repayments or amortisation of the premium/discount. Interest is defined as the consideration for the time value of money
and credit risk, which are the most significant elements of interest within a lending arrangement. If the Group identifies any contractual
features that could significantly modify the cash flows of the instrument such that they introduce exposures to risk or volatility that are
inconsistent with a basic lending arrangement, the related financial asset is classified and measured at FVTPL.
The Group carries out the SPPI test based on an assessment of the contractual features of each product on origination and subsequently
at every reporting period. Derivative instruments and equity instruments are not covered by this assessment as they are held at FVTPL
(except when equities are accounted for at FVOCI).
Based on the above assessments, the Group classifies its debt instruments into one of the following four measurement categories:
(i) Debt instruments measured at amortised cost
Debt instruments are measured at amortised cost if they are held within a business model whose objective is to hold the assets to collect
contractual cash flows, where those cash flows represent solely payments of principal and interest. After initial measurement, debt
instruments in this category are measured at amortised cost. Interest income on these instruments is recognised in interest income using
the EIR method.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
The EIR is the rate that discounts estimated future cash payments or receipts through the expected life of a financial asset to the gross
carrying amount of a financial asset. Amortised cost is calculated by taking into account any discount or premium on acquisition,
transaction costs and fees that are an integral part of the EIR.
Impairment on debt instruments measured at amortised cost is calculated using the ECL approach. Loans and debt securities measured
at amortised cost are presented net of allowance for ECL in the SOFP.
(ii) Debt instruments measured at FVOCI
Debt instruments are measured at FVOCI if they are held within a business model whose objective is to both hold the assets to collect
contractual cash flows and to sell the financial assets, where the assets’ cash flows represent payments that are solely payments of
principal and interest. Subsequent to initial recognition, unrealised gains and losses on debt instruments measured at FVOCI are recorded
in OCI, unless the instrument is designated in a fair value hedge relationship. When designated in a fair value hedge relationship, any
changes in fair value due to changes in the hedged risk are recognised in interest income in the income statement. On derecognition,
realised gains and losses are reclassified from OCI and recorded in other operating income in the statement of comprehensive income. FX
gains and losses that relate to the amortised cost of the debt instrument are recognised in the income statement. Premiums, discounts
and related transaction costs are amortised over the expected life of the instrument to interest income in the income statement using the
EIR method.
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Impairment on debt instruments measured at FVOCI is calculated using the ECL approach. The ECL on debt instruments measured at
FVOCI does not reduce the carrying amount of the asset in the SOFP, which remains at its fair value. Instead, an amount equal to the
allowance that would arise if the assets were measured at amortised cost is recognised in OCI with a corresponding charge to provision for
credit losses in the income statement. The accumulated allowance recognised in OCI is recycled to the income statement on
derecognition of the debt instrument.
(iii) Debt instruments measured at FVTPL
Debt instruments measured at FVTPL include assets held for trading purposes, assets held as part of a portfolio managed on a fair value
basis and assets whose cash flows do not represent payments that are solely payments of principal and interest. These instruments are
measured at fair value in the SOFP, with transaction costs recognised immediately in the income statement as part of net trading income.
Realised and unrealised gains and losses are recognised as part of other operating income in the income statement.
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(iv) Debt instruments designated at FVTPL
Debt instruments are designated at FVTPL only if doing so eliminates, or significantly reduces, an accounting mismatch that would
otherwise arise. The designation is only available on initial recognition and the designation is irrevocable. Debt instruments designated at
FVTPL are recorded in the SOFP at fair value and changes in fair value are recorded in the income statement.
Equity instruments
Equity instruments are measured at FVTPL, unless an election is made to designate them at FVOCI upon purchase. For equity instruments
measured at FVTPL, changes in fair value are recognised as part of other operating income in the income statement. The Group can elect
to classify non-trading equity instruments at FVOCI. The FVOCI election is made upon initial recognition, on an instrument-by-instrument
basis and once made is irrevocable. Gains and losses on these instruments including when derecognised/sold are recorded in OCI and are
not subsequently reclassified to the income statement. Dividend received is recorded in the income statement.
Reclassifications
Financial assets are not reclassified subsequent to their initial recognition, except in the period after the Group changes its business model
for managing financial assets.
(b) Impairment of financial assets
The Group recognises loss allowances for ECL for the following financial instruments that are not measured at FVTPL:
• Financial assets at amortised cost;
• Loan commitments;
• Financial assets at FVOCI (excluding equity instruments); and
• Guarantees.
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173
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Measurement
ECL is measured by the Group in a way that reflects:
• an unbiased probability weighted amount that is determined by evaluating a range of possible outcomes;
•
•
the time value of money; and
reasonable and supportable information that is available without undue cost or effort at the reporting date and past events, current
conditions and forecast of future economic conditions.
The amount of ECL recognised as a loss allowance depends on the change in credit risk of the financial instrument since origination and
whether the credit risk on those financial instruments has increased significantly since initial recognition. In order to determine the
appropriate ECL, a financial instrument is allocated to a stage dependent on the credit risk relative to when the financial instrument was
originated:
• Stage 1 – includes financial instruments that have not had a SICR since initial recognition. For these assets, 12-month ECL is
recognised. 12-month ECL is the ECL that results from default events that are possible within 12 months of the reporting date. It is not
the expected cash shortfalls over the 12-month period but the entire credit loss on an asset weighted by the probability that the loss will
occur in the next 12 months. Therefore, all financial assets in scope will have an impairment provision equal to at least 12-month ECL;
• Stage 2 – includes financial instruments that have had a SICR since initial recognition but that does not have objective evidence of
impairment. For these assets, lifetime ECL is recognised, being the ECL that results from all possible default events over the expected
life of the financial instrument;
• Stage 3 – includes financial assets that have objective evidence of impairment at the reporting date, i.e. are credit-impaired. For these
assets, lifetime ECL is recognised.
The Group has adopted an ECL framework that reflects a component approach using PD, EAD and LGD components calibrated for IFRS 9
purposes. To adequately capture life-time expected losses, the Group also models early redemptions as a separate component within the
ECL calculation.
The expected cash flows included in the ECL calculation are derived from a) the loan contract b) on the disposal of collateral or c) sale of
loans arising from deleveraging of NPLs which are included in the ECL calculation from the point that they meet the following three
conditions:
• Selling the loans becomes a recovery method that the Group expects to pursue in a default scenario;
• The Group is neither legally nor practically prevented from realising the loans using the recovery method; and
• The Group has reasonable and supportable information upon which to base its expectations and assumptions.
Credit loss is the difference between all contractual cash flows that are due to an entity in accordance with the contract and all the cash
flows that the entity expects to receive (i.e. all cash shortfalls), discounted at the original EIR.
Purchased or originated credit-impaired assets (POCI)
POCI are excluded from the general 3 stage impairment model in IFRS 9. POCI assets are financial assets that are credit-impaired on initial
recognition. POCI assets are recorded at fair value at original recognition and interest income is subsequently recognised on a credit-
adjusted EIR basis. ECL are only recognised or released to the extent that there is a subsequent change in ECL.
Expected life
When measuring ECL, the Group must consider the maximum contractual period over which the Group is exposed to credit risk. All
contractual terms should be considered when determining the expected life, including prepayment options, extension and rollover options.
For most instruments, the expected life is limited to the remaining contractual life, adjusted as applicable for expected prepayments.
For certain revolving credit facilities that do not have a fixed maturity (e.g. credit cards and overdrafts), the expected life is estimated based
on the period over which the Group is exposed to credit risk and where the credit losses would not be mitigated by Management actions.
For instruments in Stage 2 or Stage 3, loss allowances will cover ECL over the expected remaining life of the instrument.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
Expert Credit Judgement
The Group’s ECL accounting framework methodology, in line with the requirements of the standard, requires the Group to use its
experienced credit judgement to incorporate the estimated impact of factors not captured in the modelled ECL results, in all reporting
periods.
Effective Interest Rate
The discount rate used by the Group in measuring ECL is the EIR (or ‘credit-adjusted effective interest rate’ for a POCI financial assets) or
an approximation thereof.
For undrawn commitments, the EIR, or an approximation thereof, is applied when recognising the financial assets resulting from the loan
commitment.
Low credit risk exemption
The Group applied the low credit risk exemption to sovereign debt securities, reverse repurchase agreements, loans and advances to
banks and certain intercompany positions in scope for impairment under IFRS 9.
The Group considers credit risk on a financial instrument low if it meets the following conditions:
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• Strong capacity by borrower to meet its contractual cash flow obligations in the near term.
• Adverse changes in economic business conditions in the longer term may, but will not necessarily, reduce the ability of the borrower to
fulfil its contractual cash flow obligations.
• External rating of investment grade or an internal credit rating equivalent.
These exposures are in Stage 1 with a very low credit risk requiring 12-month ECL and contributing minimally to overall ECL.
Modification Policy for Financial Assets
The Group sometimes renegotiates or otherwise modifies the contractual cash flows of loans to customers. When this happens, the Group
assesses whether or not the new items are substantially different to the original terms. The Group does this by considering, among others,
the following factors:
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•
If the borrower is in financial difficulty, whether the modification merely reduces the contractual cash flows to amounts the borrower is
expected to be able to pay;
• Whether any substantial new items are introduced such as a profit share/equity-based return that substantially affects the risk profile
of the loan;
• Significant extension of the loan term when the borrower is not in financial difficulty;
• Significant change in the interest rate;
• Change in the currency the loan is denominated in; and
•
Insertion of collateral, other security or credit enhancements that significantly affect the credit risk associated with the loan.
If the terms are substantially different, the Group derecognises the original financial asset and recognises a new asset at fair value and
recalculates a new EIR for the asset. The date of renegotiation of the new financial asset is consequently considered to be the date of
initial recognition for impairment calculation purposes, including for the purpose of determining whether a SICR has occurred. However,
the Group also assesses whether the new financial asset recognised is deemed to be credit-impaired at initial recognition, especially in
circumstances where the renegotiation was driven by the debtor being unable to make the originally agreed payments. Differences in the
carrying amount are also recognised in profit or loss as a gain or loss on derecognition.
If the terms are not substantially different, the renegotiation or modification does not result in derecognition, and the Group calculates the
gross carrying amount based on the revised cash flows of the financial asset and recognises a modification gain or loss in profit or loss.
The new gross carrying amount is recalculated by discounting the modified cash flows at the original EIR (or credit-adjusted EIR for POCI
financial assets).
Permanent TSB Group Holdings plc - Annual Report 2022
175
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Write-off policy
The Group writes off an impaired financial asset (and the related impairment allowance), either partially or in full, when there is no realistic
prospect of recovery or on foot of a negotiated settlement. Indicators that there is no prospect of recovery include the borrower being
deemed unable to pay due to their financial circumstances or the cost to be incurred in seeking recovery is likely to exceed the amount of
the write-off. In circumstances where the net realisable value of any collateral has been determined and there is no reasonable
expectation of further recovery, write-off may be earlier than collateral realisation. Write-off on those financial assets subject to
enforcement activity will take place on conclusion of the enforcement process.
In subsequent periods, any recoveries of amounts previously written off are credited to the provision for credit losses in the income
statement.
Presentation of ECL allowance in the statement of financial position
The ECL on financial assets measured at amortised cost is presented as a deduction from the gross carrying amount.
The ECL on debt instruments measured at FVOCI does not reduce the carrying amount of the asset in the SOFP, which remains at fair
value. Instead an amount equal to the allowance that would arise if the assets were measured at amortised cost is recognised in OCI with a
corresponding charge to provision for credit losses in the income statement.
Off-balance sheet credit risks include certain undrawn lending commitments, letters of credit and letters of guarantee as a provision in the
SOFP.
(c) Financial liabilities and equity
Financial liabilities are classified at amortised cost unless mandatorily required to be classified at FVTPL, for example derivatives, or
designated at FVTPL.
Financial liabilities measured at amortised cost
Financial liabilities include deposits by banks (including Central Banks), customer accounts, debt securities and subordinated debt.
Derivative liabilities are dealt with under separate accounting policies.
Debt securities and subordinated debt issued are initially recognised on the date that they originated, while all other financial liabilities are
recognised initially on the trade date. Both the date of origination and the trade date is the date the Group becomes a party to the
contractual provisions of the instrument.
All financial liabilities are recognised initially at fair value, less any directly attributable transaction costs and are subsequently measured
at amortised cost and the related interest expense is recognised in the income statement using the EIR method.
Financial liabilities designated at FVTPL
Financial liabilities classified in this category are those that have been designated by the Group on initial recognition.
Financial liabilities are designated at FVTPL when one of the following criteria is met:
• The designation eliminates, or significantly reduces, an accounting mismatch which would otherwise arise;
• A group of financial liabilities are managed and their performance is evaluated on a fair value basis, in accordance with a documented
risk management strategy; or
• The financial liability contains one or more embedded derivatives which significantly modify the cash flows otherwise required.
Financial liabilities designated at FVTPL are recorded in the SOFP. For liabilities designated at FVTPL, changes in fair value are recognised
in non-interest income in the income statement, with the exception of movements in own credit.
For financial liabilities designated at FVTPL, gains or losses attributable to changes in own credit are presented in OCI. The Group has not
and does not expect to invoke the fair value option for financial liabilities.
The classification of instruments as a financial liability or an equity instrument is dependent upon the substance of the contractual
arrangement. Instruments which carry a contractual obligation to deliver cash or another financial asset to another entity are classified as
financial liabilities. The coupons on these instruments are recognised in the income statement as interest expense using the effective
interest method. Where the Group has absolute discretion in relation to the payment of coupons and repayment of principal, the
instrument is classified as equity and any coupon payments are classified as distributions in the period in which they are made.
If the Group purchases its own debt, it is removed from the balance sheet and the difference between the carrying amount of the liability
and the consideration paid is included in other operating income, net of any costs or fees incurred.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
Equity
Financial instruments classified as equity are accounted for directly in equity less any transaction costs deducted directly from equity.
Transaction costs are incremented costs directly attributable to the equity transaction that otherwise would have been avoided. Equity
instruments are not subsequently re-measured. Any coupon payments on the instrument are treated as dividends and accounted for,
when declared as a distribution out of retained earnings. Equity instruments are issued at arm’s length.
(d) Derecognition of Financial instruments
Financial assets
The Group derecognises a financial asset when the contractual right to the cash flow from the financial asset expires, or it transfers the
rights to receive the contractual cash flows in a transaction in which substantially all of the risks and rewards of ownership of the financial
asset are transferred or in which the Group neither transfers nor retains substantially all of the risks and rewards of ownership and it does
not retain control of the financial asset. Control over the assets is represented by the practical ability to sell the transferred asset.
On derecognition of a financial asset, the difference between the carrying amount of the asset (or the carrying amount allocated to the
portion of the asset derecognised) and the sum of (i) the consideration received (including any new asset obtained less any new liability
assumed) and (ii) any cumulative gain or loss that had been recognised in OCI is recognised in profit or loss.
Any cumulative gain/loss recognised in OCI in respect of equity investment securities designated as at FVOCI is not recognised in profit or
loss on derecognition of such securities. Any interest in transferred financial assets that qualify for derecognition that is created or
retained by the Group is recognised as a separate asset or liability.
The Group enters into transactions whereby it transfers assets recognised on its SOFP, but retains either all or substantially all of the risks
and rewards of the transferred assets or a portion of them. In such cases, the transferred assets are not derecognised. Examples of such
transactions are securities lending and sale-and-repurchase transactions.
When assets are sold to a third party with a concurrent total rate of return swap on the transferred assets, the transaction is accounted for
as a secured financing transaction similar to sale-and-repurchase transactions, because the Group retains all or substantially all of the
risks and rewards of ownership of such assets.
In transactions in which the Group neither retains nor transfers substantially all of the risks and rewards of ownership of a financial asset
and it retains control over the asset, the Group continues to recognise the asset to the extent of its continuing involvement, determined by
the extent to which it is exposed to changes in the value of the transferred asset.
In certain transactions, the Group retains the obligation to service the transferred financial asset for a fee. The transferred asset is
derecognised if it meets the derecognition criteria. An asset or liability is recognised for the servicing contract if the servicing fee is more
than adequate (asset) or is less than adequate (liability) for performing the servicing.
The Group sells loans and advances to customers to SEs that in turn issue notes to investors which are collateralised by the purchased
assets. For the purpose of disclosure, a transfer of such financial assets may arise if the Group sells assets to a consolidated SE, the
transfer of financial assets is from the Group (that includes the consolidated SE) to investors in the notes issued by the SE. The transfer is
in the form of the Group assuming an obligation to pass cash flows from the underlying assets to investors in the notes. The securitisation
is generally retained in the form of senior or subordinated tranches, or other residual interests (retained interests) however, these
securitisations may also occur with entities external to the Group. Retained interests are recognised as debt securities. The Group sells
loans and advances to customers to SEs that are not consolidated SEs and the Group retains no interest in these assets and they are
derecognised in their entirety.
Permanent TSB Group Holdings plc - Annual Report 2022
177
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Financial liabilities
The Group derecognises a financial liability when its contractual obligations are discharged, cancelled, or expire. This may happen when
payment is made to the lender; the borrower legally is released from primary responsibility for the financial liability; or if there is an
exchange of debt instruments with substantially different terms or a substantial modification of the terms of an existing debt instrument.
Derecognition conditions are also satisfied when an entity repurchases its own debt instruments issued previously. When a financial
liability is extinguished, any difference between the carrying amount of the financial liability and the consideration paid is recognised in the
income statement.
(e) Determination of fair value of financial instruments and other assets
The Group measures financial instruments, such as, derivative financial instruments, trading financial instruments and other financial
instruments at FVTPL. Certain risks in hedged financial instruments, financial assets classified as FVOCI, property and equipment, and
collateral in possession are measured at fair value on initial recognition.
Fair value is the price that would be received to sell an asset, or paid to transfer a liability in an orderly transaction between market
participants at the measurement date. The fair value measurement is based on the presumption that the transaction to sell the asset, or
transfer the liability takes place either in the principal market for the asset or liability, or in the absence of a principal market, in the most
advantageous market for the asset or liability which is accessible to the Group.
The Group uses valuation techniques that are appropriate in the circumstances and for which sufficient data is available to measure fair
value, maximising the use of relevant observable inputs and minimising the use of unobservable inputs.
All assets and liabilities for which fair value is measured or disclosed in the financial statements are categorised within the fair value
hierarchy based on the lowest level input that is significant to the fair value measurement as a whole and is described as follows:
• Level 1: Quoted market prices in active markets for identical assets or liabilities (unadjusted);
• Level 2: Valuation techniques such as discounted cash flow method, comparison with similar instruments for which market observable
prices exist, options pricing models, credit models and other relevant valuation models for which the lowest level input that is significant
to the fair value measurement is directly or indirectly observable; or
• Level 3: Valuation techniques for which the lowest level input that is significant to the fair value measurement is unobservable.
For assets and liabilities that are recognised in the financial statements on a recurring basis, the Group determines whether transfers have
occurred between levels in the hierarchy by re-assessing categorisation (based on the lowest level input that is significant to the fair value
measurement as a whole) at the end of each reporting period. The Group recognises transfers between levels of the fair value hierarchy as
of the end of the reporting period during which the change has occurred.
An analysis of the fair values of financial instruments, and further details as to how they are measured, are provided in note 37.
(viii) Derivative instruments and hedging
The Group follows the IFRS 9 model for hedge accounting.
Derivative instruments used by the Group primarily comprise interest rate swaps and currency forward rate contracts. Such derivative
financial instruments are initially recognised at fair value on the date on which a derivative contract is entered into and are subsequently
remeasured at fair value. Derivatives are carried as financial assets when the fair value is positive and as financial liabilities when the fair
value is negative.
For the purpose of hedge accounting, hedges are classified as:
• Fair value hedges when hedging the exposure to changes in the fair value of a recognised asset or liability, or an unrecognised firm
commitment;
• Cash flow hedges when hedging the exposure to variability in cash flows that is either attributable to a particular risk associated with a
recognised asset or liability or a highly probable forecast transaction or the foreign currency risk in an unrecognised firm commitment;
or
• Hedges of a net investment in a foreign operation.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
At the inception of a hedge relationship, the Group formally designates and documents the hedge relationship to which it wishes to apply
hedge accounting and the risk management objective and strategy for undertaking the hedge. The documentation includes identification
of the hedging instrument, the hedged item, the nature of the risk being hedged and how the Group will assess whether the hedging
relationship meets the hedge effectiveness requirements (including the analysis of sources of hedge ineffectiveness and how the hedge
ratio is determined). A hedging relationship qualifies for hedge accounting if it meets all of the following effectiveness requirements:
• There is ‘an economic relationship’ between the hedged item and the hedging instrument;
• The effect of credit risk does not ‘dominate the value changes’ that result from that economic relationship; and
• The hedge ratio of the hedging relationship is the same as that resulting from the quantity of the hedged item that the Group actually
hedges and the quantity of the hedging instrument that the Group actually uses to hedge that quantity of hedged item.
Certain derivative instruments do not fulfil the hedge accounting criteria under IFRS 9 and are consequently classified as held for trading.
The fair value movement and any interest income/(expense) are included in Net trading income/(expense).
Hedges that meet all the qualifying criteria for hedge accounting are accounted for, as described below:
(a) Fair value hedges
The change in the fair value of a hedging instrument is recognised in the consolidated income statement as NII. The change in the fair
value of the hedged item attributable to the risk hedged is recorded as part of the carrying value of the hedged item and is also recognised
in the consolidated income statement as NII.
For fair value hedges relating to items carried at amortised cost, any adjustment to carrying value is amortised through profit or loss over
the remaining term of the hedge using the EIR method. The EIR amortisation may begin as soon as an adjustment exists and no later than
when the hedged item ceases to be adjusted for changes in its fair value attributable to the risk being hedged.
If the hedged item is derecognised, the unamortised fair value is recognised immediately in profit or loss.
(b) Embedded derivatives
A derivative embedded in a hybrid contract, with a financial liability or non-financial host, is separated from the host and accounted for as
a separate derivative if:
• The economic characteristics and risks are not closely related to the host;
• A separate instrument with the same terms as the embedded derivative would meet the definition of a derivative; and
• The hybrid contract is not measured at FVTPL.
Embedded derivatives are measured at fair value with changes in fair value recognised in profit or loss. Reassessment only occurs if there
is either a change in the terms of the contract that significantly modifies the cash flows that would otherwise be required or a
reclassification of a financial asset out of the FVTPL category.
A derivative embedded within a hybrid contract containing a financial asset host is not accounted for separately. The financial asset host,
together with the embedded derivative, is required to be classified in its entirety as a financial asset at FVTPL.
(c) Credit valuation adjustment
The Group is engaged in over the counter (OTC) derivative transactions and considers whether a fair value adjustment for credit risk is
required. CVA is considered to reflect the counterparty’s default risk and debit valuation adjustment (DVA) to reflect own credit risk. There
is no specific guidance on the methods used to calculate CVA or DVA which creates challenges in estimation.
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Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
As a result, IFRS 13 requires entities to consider the effects of credit risk when determining a fair value measurement, e.g. by calculating a
CVA on their derivatives. Estimation can be complex and requires the use of significant judgement which is often influenced by various
qualitative factors, such as:
• The materiality of the entity’s derivative’s carrying value to its financial statements;
• The number and type of contracts for derivatives in the entity’s portfolio;
• The extent to which derivative instruments are either deeply in or out of the money;
• The existence and terms of credit mitigation arrangements (e.g. collateral arrangements in place);
• The cost and availability of technology to model complex credit exposures;
• The cost and consistent availability of suitable input data to calculate an accurate credit adjustment; and
• The credit worthiness of the entity and its counterparties.
The Group mitigates the majority of its derivative positions through the use of netting and Credit Support Annex collateral arrangements.
The Group do not operationally net positions. The netting and collateral arrangements may be called upon in the event of a default. This
allows a counterparty to net all assets and liabilities outstanding with the defaulting counterparty, subject to the agreement when the
default event occurs. The collateral arrangements in place require the counterparty in a liability position to place collateral to cover that
shortfall. The Group considers and discounts the necessity for any amendments to the valuations to reflect the CVA when calculating the
fair value of the derivative positions.
The Group monitors this position at every reporting period and assesses if material CVAs become appropriate to be recognised.
(ix) Cash and cash equivalents
Cash comprises cash on hand and demand deposits and cash equivalents include liquid investments that are readily convertible to known
amounts of cash which are subject to an insignificant risk of change in value and with an original maturity of less than three months.
(x) Leases
(a) Classification of Leases
At inception of a contract, the Group assesses whether a contract is, or contains, a lease. A contract is, or contains, a lease if the contract
conveys the right to control the use of an identified asset for a period of time in exchange for consideration. To assess whether a contract
conveys the right to control the use of an identified asset, the Group assesses whether:
•
•
•
the contract involves the use of an identified asset; this may be specified explicitly or implicitly, and should be physically distinct or
represent substantially all of the capacity of a physically distinct asset. If the supplier has a substantive substitution right, then the asset
is not identified;
the Group has the right to obtain substantially all of the economic benefits from use of the asset throughout the period of use; and
the Group has the right to direct the use of the asset. The Group has this right when it has the decision-making rights that are most
relevant to changing how and for what purpose the asset is used. In rare cases where the decision about how and for what purpose the
asset is used is predetermined, the Group has the right to direct the use of the asset if either:
- the Group has the right to operate the asset; or
- the Group designed the asset in a way that predetermines how and for what purpose it will be used.
Unless the lease is of short-term and of low-value assets, where the Group has the right to obtain substantially all of the economic benefits
from use of identified assets and has the right to direct the use of the identified asset, a right-of-use asset is recognised in property and
equipment and a lease liability is recognised in other liabilities.
If a lease is assumed as part of a business combination the Group, subject to not meeting the recognition exemptions as detailed below,
will recognise a right-of-use asset and a lease liability as if the lease were a new lease at the acquisition date. The right-of-use assets and
lease liability are then measured consistently with the Groups accounting policy as detailed above with the lease commencement date
being the acquisition date.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
As a lessee
The Group recognises a right-of-use asset and a lease liability at the lease commencement date. The right-of-use asset is initially
measured at cost, which comprises the initial amount of the lease liability adjusted for any lease payments made at or before the
commencement date, plus any initial direct costs incurred and an estimate of costs to dismantle and remove the underlying asset or to
restore the underlying asset or the site on which it is located, less any lease incentives received.
The right-of-use asset is subsequently depreciated using the straight-line method from the 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 estimated useful lives of right-of-use assets are determined on
the same basis as those of property and equipment. In addition, the right-of-use asset is periodically reduced by impairment losses, if any,
and adjusted for certain remeasurements of the lease liability.
The lease liability is measured at amortised cost using the incremental borrowing rate. Incremental borrowing rate is the rate of interest
that a lessee would have to pay to borrow over a similar term, and with a similar security, the funds necessary to obtain an asset of a
similar value to the right of use asset in a similar economic environment. For its incremental borrowing rate, the Group uses its FTP, which
comprises its base cost of funds with add-ons related to regulatory requirements, and term liquidity premium based on the slope of swap
curve as a proxy of time value of money. The Group FTP is fully reflective of its funding profile and therefore considers it an appropriate
reflection of the Group’s borrowing cost. For retail properties, property yield is added as a lease specific adjustment.
Lease payments included in the measurement of the lease liability comprise the following:
• Fixed payments, including in-substance fixed payments;
• Variable lease payments that depend on an index or a rate, initially measured using the index or rate as at the commencement date;
• Amounts expected to be payable under a residual value guarantee;
• The exercise price under a purchase option that the Group is reasonably certain to exercise, lease payments in an optional renewal
period if the Group is reasonably certain to exercise an extension option; and
• Penalties for early termination of a lease unless the Group is reasonably certain not to terminate early.
The lease liability is remeasured, if there is a change in future lease payments arising from a change in index-linked considerations, if
there is a change in the Group’s estimate of the amount expected to be payable under a residual value guarantee, or if the Group changes
its assessment of whether it will exercise a purchase, extension or termination option.
When the lease liability is remeasured in this way, a corresponding adjustment is made to the carrying amount of the right-of-use asset, or
is recorded in profit or loss if the carrying amount of the right-of-use asset has been reduced to zero.
Short-term leases and leases of low-value assets
The Group has elected not to recognise right-of-use assets and lease liabilities for short-term leases of vehicles that have a lease term of
twelve months or less and leases of low-value assets, including office equipment. The Group recognises the lease payments associated
with these leases as an expense on a straight-line basis over the lease term.
As a lessor
When the Group acts as a lessor, it determines at lease inception, whether each lease is a finance lease or an operating lease.
To classify each lease, the Group makes an overall assessment of whether the lease transfers substantially all of the risks and rewards
incidental to ownership of the underlying asset. If this is the case, then the lease is a finance lease; if not, then it is an operating lease. As
part of this assessment, the Group considers certain indicators such as, whether the lease is for the major part of the economic life of the
asset.
When the Group is an intermediate lessor, it accounts for its interests in the head lease and the sub-lease separately. It assesses the lease
classification of a sub-lease with reference to the right-of-use asset arising from the head lease, not with reference to the underlying
asset. If a head lease is a short-term lease to which the Group applies the exemption described above, then it classifies the sub-lease as
an operating lease.
If an arrangement contains lease and non-lease components, the Group applies IFRS 15 to allocate the consideration in the contract.
The Group recognises lease payments received under operating leases as income, on a straight-line basis, over the lease term, as part of
other income.
Permanent TSB Group Holdings plc - Annual Report 2022
181
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
The accounting policies applicable to the Group as a lessor in the comparative period were not different from IFRS 16. However, when the
Group was an intermediate lessor the sub-leases were classified with reference to the underlying asset.
The Group presents right-of-use assets in property and equipment and lease liabilities in other liabilities in the SOFP.
(xi) Property and equipment
Leasehold premises with initial lease terms of less than 50 years and all other equipment are stated at cost less accumulated depreciation
and impairment losses. Depreciation is calculated on a straight-line basis to write off the costs of such assets to their residual value over
their estimated useful lives, which are assessed annually.
Freehold premises (including land) are revalued at least annually by external professional valuers. Any accumulated depreciation (on
freehold premises excluding land) at the date of revaluation is eliminated against the gross carrying amount of the asset, and the net
amount is restated to the revalued amount of the asset. Any resulting increase in value is credited to OCI and shown as revaluation
reserves in shareholders’ equity. Any decrease in value that offsets previous increases of the same asset are charged in OCI and debited
against the revaluation reserves directly in equity while all other decreases are charged to the income statement. The revalued premises,
excluding the land element, are depreciated to their residual values over their estimated useful lives, which are assessed annually.
Subsequent costs are included in the asset’s carrying amount, only when it is probable that future economic benefits associated with the
item will flow to the Group and the cost of the item can be measured reliably. Property and equipment are assessed for impairment where
there is an indication of impairment. Where impairment exists, the carrying amount of the asset is reduced to its recoverable amount and
the impairment loss is recognised against the revaluation reserve to the extent it is available and any remainder is recognised in the
income statement. The depreciation charge for the asset is then adjusted to reflect the asset’s revised carrying amount.
If an item of property, plant and equipment is disposed of, any gains or losses are recognised in the profit or loss before tax. If the asset
being disposed of had previously been revalued then any amount in OCI relating to that asset is reclassified directly to retained earnings on
disposal rather than the income statement.
The estimated useful lives are as follows:
Freehold Buildings
Leasehold Buildings
Office Equipment
Computer Hardware
Motor Vehicles
50 years
50 years or term of lease if less than 50 years
5 – 15 years
3 – 10 years
5 years
(xii) Intangible assets (other than goodwill)
Acquired computer software is stated at cost, less amortisation and provision for impairment, if any. The external costs and identifiable
internal costs of bringing to use the computer software are capitalised where it is probable that future economic benefits that exceed its
cost will flow from its use over more than one year.
Capitalised computer software has a finite life and is amortised on a straight-line basis over a period of between three to seven years.
Expenditure on internally developed software is recognised as an asset when the Group is able to demonstrate: that the product is
technically and commercially feasible, its intention and ability to complete the development and use the software in a manner that will
generate future economic benefits, and that it can reliably measure the costs to complete the development. The capitalised costs of
internally developed software include all costs directly attributable to developing the software and capitalised borrowing costs, and are
amortised over its useful life. Internally developed software is stated at capitalised cost less accumulated amortisation and any
accumulated impairment losses
Software is reviewed for impairment whenever events or changes in circumstances indicate that the carrying amount may not be
recoverable. An asset’s carrying value is written down immediately to its recoverable amount if the asset’s carrying amount is greater than
its estimated recoverable amount. The estimated recoverable amount is the higher of the asset’s fair value less costs to sell or VIU.
Costs associated with research activities or maintaining computer software programmes are recognised as an expense as incurred.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
Acquired intangible assets
Customer related intangible assets and brands acquired in a business combination are recognised at fair value at acquisition date.
Customer related intangible assets and brands have a finite useful life and are carried at cost less accumulated amortisation and provision
for impairment, if any. Amortisation is calculated using the straight line basis to allocate the cost over their estimated useful life.
(xiii) Collateral in possession
In certain circumstances, property is repossessed following foreclosure on loans that are in default. When a property is repossessed, the
associated loan relating to that property is derecognised and any provision on that loan is reversed. On initial recognition the collateral in
possession is valued at its fair value.
Subsequent to initial recognition, the property is carried at the lower of its cost or net realisable value.
(xiv) Assets and liabilities classified as held for sale
An asset or a disposal group is classified as held for sale if the following criteria are met:
Its carrying value will be recovered principally through sale rather than continuing use;
It is available for immediate sale; and
•
•
• The sale is highly probable within the next 12 months.
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When assets (or disposal groups), other than financial assets as classified under IFRS 9, or rights under an insurance contract, are initially
classified as held for sale, they are measured at the lower of the carrying amount or fair value less costs to sell at the date of
reclassification.
Impairment losses subsequent to classification of such assets (or disposal groups) are recognised in the income statement. Increases in
fair value less costs to sell of such assets (or disposal groups) that have been classified as held for sale are recognised in the income
statement to the extent that the increase is not in excess of any cumulative loss previously recognised in respect of the asset (or disposal
group).
Where the above conditions cease to be met, the assets (or disposal group) are reclassified out of held for sale and included under the
appropriate SOFP classifications.
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Financial assets within the scope of IFRS 9, DTAs and income taxes within the scope of IAS 12 continue to be measured in accordance
with these standards.
(xv) Provisions
A provision is recognised if, as a result of a past event, the Group has a present legal or constructive obligation that can be estimated
reliably, and it is probable that an outflow of economic benefits will be required to settle the obligation. Provisions are determined by
discounting the expected future cash flows at a pre-tax rate that reflects current market assessments of the time value of money and,
where appropriate, the risks specific to the liability.
A restructuring provision is recognised when there is an approved detailed and formal Restructuring Plan, and the restructuring either has
commenced or has been publicly announced. Future operating losses are not permitted to be recognised.
Present obligations arising under onerous contracts are recognised and measured as provisions at the present value of the lower of the
expected cost of terminating the contract and the expected net cost of continuing with the contract. An onerous contract is a contract in
which the unavoidable cost of meeting the obligation under the contract exceeds the economic benefits expected to be received under it.
Contingent liabilities are either possible obligations that arise from past events whose existence is dependent on whether some uncertain
future events occur which are not wholly within the control of the entity or are a present obligation that arises from a past event but is not
recognised because:
It is not probable that an outflow of resources embodying economic benefits will be required to settle the obligation; or
•
• The amount of the obligation cannot be measured with sufficient reliability.
Contingent liabilities are not recognised but are disclosed unless the probability of their occurrence is remote.
Financial guarantees are contracts that require the Group to make specified payments to reimburse the holder for a loss that it incurs
because a specified debtor fails to make payment when it is due in accordance with the terms of a debt instrument.
Permanent TSB Group Holdings plc - Annual Report 2022
183
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
Loan commitments are firm commitments to provide credit under pre-specified terms and conditions.
The maximum exposure to credit loss under commitments is the contractual amount of the instrument in the event of non-performance
by the other party where all counter claims, collateral or security prove worthless. The transfer of economic resources is uncertain and
cannot be reasonably measured to be recognised on the SOFP.
ECL held against commitments are reported under loans and advances to customers.
Financial guarantees issued or commitments to provide a loan at a below-market interest rate are initially measured at fair value.
Subsequently, they are measured at the higher of the loss allowance determined in accordance with IFRS 9 and the amount initially
recognised less, when appropriate, the cumulative amount of income recognised in accordance with the principles of IFRS 15.
Other loan commitments issued are measured at the sum of (i) the loss allowance determined in accordance with IFRS 9 and (ii) the
amount of any fees received, less, if the commitment is unlikely to result in a specific lending arrangement, the cumulative amount of
income recognised. Derecognition policies in 1(d) are applied to loan commitments issued and held.
The Group has issued no loan commitments that are measured at FVTPL
(xvi) Dividends
Final dividends on ordinary shares are recognised in equity in the period in which they are approved by the Company’s shareholders.
Interim dividends are recognised in equity in the period in which they are paid.
(xvii) Operating segments
An operating segment is a component of the Group that engages in business activities from which it may earn revenues and incur
expenses, including revenues and expenses that relate to transactions with any of the Group’s other components, whose operating results
are reviewed regularly by the Group Executive Committee (being the chief operating decision maker (CODM)) to make decisions about
resources allocated to each segment and assess its performance, and for which discrete financial information is available. Transactions
between the operating segments are on normal commercial terms and conditions unless stated otherwise. Internal charges and transfer
pricing adjustments have been reflected in the performance of each segment. Revenue from external parties is measured in a manner
consistent with the income recognition policy of the Group.
(xviii) Sales and repurchase agreements
Financial assets may be lent for a fee or sold subject to a commitment to repurchase them (“repos”). Such assets are retained on the
SOFP when substantially all the risks and rewards of ownership remain with the Group. The assets are reclassified as pledged assets
when the transferee has the right by contract to sell or repledge the collateral. The liability to the counterparty is included separately on
the SOFP as appropriate in either Deposits by banks or Customer accounts.
Similarly, where financial assets are purchased with a commitment to resell (“reverse repos”), or where the Group borrows financial assets
but does not acquire the risks and rewards of ownership, the transactions are treated as collateralised loans, and the financial assets are
not included in the SOFP. The collateralised loan asset is included separately on the SOFP as appropriate in either Loans and advances to
banks or Loans and advances to customers.
The difference between the sale and repurchase price is recognised in the income statement over the life of the agreements using the EIR.
Fees earned on stock lending are recognised in the income statement over the term of the lending agreement. Securities lent to
counterparties are also retained on the SOFP.
In certain circumstances, the Group pledges collateral in respect of liabilities or borrowings. Collateral pledged in the form of securities or
loans and advances continues to be recorded on the SOFP. Collateral placed in the form of cash is recorded in loans and advances to
banks or customers. Any interest receivable arising is recorded as interest income.
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1. Corporate information, basis of preparation and significant accounting policies (continued)
(xix) Collateral
The Group enters into master agreements with counterparties to ensure that in the event of a default, all amounts outstanding with those
counterparties will be settled on a net basis. The Group obtains collateral in respect of customer liabilities where this is considered
appropriate. The collateral normally takes the form of a lien over the customers’ assets and gives the Group a claim on these assets for
both existing and future liabilities. The collateral is not recorded on the Group’s SOFP.
The Group also receives collateral in the form of cash or securities in respect of other credit instruments, such as stock borrowing
contracts and derivative contracts, in order to reduce credit risk. Collateral received in the form of securities is not recorded on the SOFP.
Collateral received in the form of cash is recorded on the SOFP, with a corresponding liability recognised within deposits from banks or
deposits from customers. Any interest payable arising is recorded as interest expense.
(xx) Offsetting
Financial assets and liabilities are offset and the net amount reported in the balance sheet when there is currently a legally enforceable
right of set off and there is an intention to settle on a net basis, or realise the asset and settle the liability simultaneously. No impairment
loss allowance for ECL is recognised on a financial asset, or portion thereof, which has been offset.
1.6 Application of new and revised IFRSs
In 2022, the Group assessed the impact of new and revised pronouncement of IFRSs which took effect during the year. The changes to
IFRS during 2022 did not have a material impact on the Group’s financial statements. The Group has not early adopted any of the changes
described below.
1.7 Impact of other accounting standards with effective periods beginning on or after 1 January 2022
Accounting Standard
Update
Amendments to IFRS 3 –
Reference to the Conceptual
Framework
Amendments to IAS 16 –
Property, Plant and Equipment:
Proceeds before Intended Use
Description of Change
Key impacts for PTSB
Effective
Date
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2022.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2022.
Updates certain references to the
Conceptual Framework for
Financial Reporting without
changing the accounting
requirements for business
combinations.
Requires amounts received from
selling items produced while the
company is preparing the asset
for its intended use to be
recognised in profit or loss, and
not as an adjustment to the cost
of the asset.
Amendments to IAS 37 –
Onerous Contracts: Cost of
Fulfilling a Contract
Specifies which costs to include
when assessing whether a
contract will be loss-making.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2022.
Annual Improvements to IFRS
Standards 2018-2020 Cycle
Minor amendments to IFRS 1,
IFRS 16, IFRS 9 and IAS 41.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2022.
Permanent TSB Group Holdings plc - Annual Report 2022
185
Notes to the Consolidated Financial Statements
(continued)
1. Corporate information, basis of preparation and significant accounting policies (continued)
The following table outlines the new pronouncements coming into effect for accounting periods on or after 1 January 2023 and are
not deemed to have a significant impact on the financial statements
Accounting Standard
Update
Description of Change
Key impacts for PTSB
Effective
Date
IFRS 17 ‘Insurance Contracts’
IFRS 17 will come into effect for
2023.
Amendments to IFRS 17
(Insurance contracts)
Amendment to IAS 1 –
Classification of Liabilities as
Current or Non-current
Disclosure of Accounting
Policies (Amendments to IAS 1
and IFRS Practice Statement 2)
Amendments are intended to
clarify some of the
implementation challenges faced
in the implementation of IFRS 17
Insurance contracts.
Clarifies that the classification of
liabilities as current or non-
current should be based on rights
that exist at the end of the
reporting period.
Amendments are intended to
help preparers in deciding which
accounting policies to disclose in
their financial statements.
This amendment is expected to
have no significant impact on
current or future reporting. PTSB
has no insurance contracts.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2023.
Annual periods beginning on or
after 1 January 2023.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2023. Not yet
endorsed by the EU.
This amendment is expected to
have no significant impact on
current or future reporting
Annual periods beginning on or
after 1 January 2023.
Amendments to IAS 8 –
Definition of Accounting
Estimates
Distinguishes between
accounting policies and
accounting estimates.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2023.
Amendments to IAS 12 -
Deferred Tax related to Assets
and Liabilities arising from a
Single Transaction
Clarifies how to account for
deferred tax on transactions such
as leases and decommissioning
obligations.
Lease Liability in a Sale and
Leaseback (Amendments to
IFRS 16)
Clarifies how to measure sales in
a sales and lease back
agreement. The aim is to ensure
it meets the requirements of
IFRS15 revenue recognition.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2023.
This amendment is expected to
have no significant impact on
current or future reporting.
Annual periods beginning on or
after 1 January 2024. Not yet
endorsed for use in the EU.
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2. Critical accounting estimates and judgements
The preparation of these consolidated financial statements, in conformity with IFRS, requires Management to make assumptions,
estimates and judgements that affect the reported amounts of income, expenses, assets and liabilities and the accompanying disclosures.
Uncertainty about these assumptions and estimates could result in outcomes that may require a material adjustment to the carrying
amount of the assets or liabilities affected in future periods.
The current economic climate, with interest rate increases and high inflation, elevates the uncertainty associated with judgements,
estimates and assumptions made by Management. The Irish economy demonstrated recovery post Covid and resilience in the current
economic climate in 2022. The results of the actions taken by the Government, EBA and CBI point toward a positive trajectory of recovery.
The Directors and Management, however, remain cautious and risk remains in the medium to long-term that the Irish Banking sector will
continue to face challenges, particularly due to higher capital requirements and new and emerging risks.
While the actual results may differ from the estimates made, the Directors believe that they are reasonable in the current circumstances
based on the best available information at the date of the approval of these consolidated financial statements.
Assumptions, estimates and judgements are revised on an ongoing basis and where necessary are revised to reflect current conditions
and updated information.
Critical accounting estimates and judgements made by Management in applying accounting policies are set out below.
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(a) Allowance for credit losses under IFRS 9
IFRS 9 requires an impairment allowance to be recorded for ECL on financial assets regardless of whether there has been an actual loss
event. There is a requirement to track and assess changes in credit risk on financial instruments since origination and determine whether
the credit risk on those financial instruments has increased significantly since initial recognition.
Government-led customer support initiatives in response to the pandemic have weakened established relationships between model
inputs and outputs, reducing the ability to forecast using models alone. In addition, models are constructed based on a single economic
cycle. As a result a greater level of management judgement is required to reflect the current nature and uncertainty of the economic
outlook.
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The following concepts introduce significant judgement within impairment and have a tangible impact on the level of ECL allowances.
Determination of significant increase in credit risk (SICR)
The determination of whether a loan has experienced a significant increase in credit risk may have a material impact on the level of ECL
impairment allowance as a 12-month ECL is recognised for Stage 1 loans whereas a lifetime ECL is recognised for Stage 2 loans.
Migration of loans between Stage 1 and Stage 2 can cause some volatility in the amount of the recognised ECL allowances and the
provision for expected credit losses in any accounting period.
The Group has relied on a number of measures including delinquency, forborne status, risk grade, change in remaining lifetime Probability
of Default (PD) and PD at maturity to determine SICR.
At December 2022, management judgement has been applied to specified non-standard mortgages classified as Stage 1 by Impairment
models and these loans were transferred to Stage 2 with a lifetime impairment loss allowance applied. The impact of this staging
adjustment is a c.€138m increase in Stage 2 volumes.
Forward Looking Information (FLI)
The Group has adopted an ECL framework that reflects a component approach using PD, EAD and LGD components calibrated for IFRS 9
purposes. To adequately capture lifetime ECL, the Group also modelled early redemptions as a separate component within the ECL
calculation.
Judgement is combined with statistical evidence in determining which forward-looking variables are relevant for the Group’s loan
portfolios and in determining the extent by which through-the-cycle parameters should be adjusted for FLI to determine point-in-time
parameters.
Changes in FLI variables applied to convert through-the-cycle PD and LGD into point-in-time parameters can either increase or decrease
ECL impairment allowances in a particular accounting period. On update, increases in the level of optimism in the FLI variables will cause a
decrease in ECL while increases in the level of pessimism in the FLI variables will cause an increase in ECL. These movements could be
significant in the accounting period of update.
Permanent TSB Group Holdings plc - Annual Report 2022
187
Notes to the Consolidated Financial Statements
(continued)
2. Critical accounting estimates and judgements (continued)
The estimation and application of FLI requires significant judgement. In its calculation of ECL, the Group considers multiple scenarios and
possible outcomes together with their probability of occurrence. Scenarios are designed to capture a range of possible outcomes. Each
macroeconomic scenario in the Group’s ECL calculation includes a projection of all relevant macroeconomic variables applied in the
models for a five year period (where the relevant period extends to five years), subsequently reverting to long-run averages.
The Group’s approach applies extreme-but-plausible economic scenarios (i.e. underpinned by historical evidence) to estimate the
distribution of ECL to which the Group is exposed. Using statistical techniques combined with expert credit judgement the Group then
formulates an unbiased probability weighted estimate of ECL at the reporting date.
Three scenarios are currently considered in the Group’s calculation of ECL. The base scenario is used for financial planning purposes. The
Group considers one scenario that represents a macroeconomic environment that is more favourable to the central scenario and one
scenario that represents a macroeconomic environment that is less favourable to the central scenario. Three scenarios are currently
considered in the Group’s calculation of ECL at the reporting date.
The following table details the key macroeconomic variables applied to model credit losses together with the associated percentiles and
probability weightings for Stages 1 and 2 at 31 December 2022. Macroeconomic scenarios were most recently updated in December 2022.
The update in the Base Case Scenario reflects a deterioration in the outlook for the Irish economy in future years as a result of higher
inflation, with lower forecast HPI and GDP growth.
IFRS 9 Upside and Downside scenarios have been updated to present extreme ‘1-in-20’ scenarios relative to the updated Base scenario.
Given the severity of these scenarios (5th Percentile upside and 95% Percentile downside), their combination captures the
macroeconomic uncertainty arising from the current economic environment.
31 December 2022
31 December 2021
Base Case
Upside
Scenario
Down side
Scenario
Base Case
Upside
Scenario
Average
value over
Year 1
Average
value over
the forecast
period
Average
value for
the forecast
period
Average
value over
the forecast
period
Average
value over
Year 1
Average
value over
the forecast
period
Average
value over
the forecast
period
Down
side
Scenario
Average
value
over the
forecast
period
Percentile
Scenario Probability Weighting
Irish Residential House Prices
Irish Unemployment
Irish GDP
Consumer Price Index
ECB Base Rate
50th
54%
2%
5%
3%
3%
3%
5th
23%
95th
23%
12%
-10%
4%
6%
2%
1%
11%
-2%
4%
3%
0%
7%
4%
6%
3%
50th
54%
3%
6%
4%
2%
0%
5th
23%
13%
4%
6%
2%
0%
95th
23%
-8%
12%
-1%
3%
2%
4%
7%
6%
3%
0%
The Base, Upside and Downside scenarios are described as follows:
Base scenario
In the base scenario, the outlook for the global economy is one of slower growth and more uncertainty in 2023, as the economic rebound
from the impact of Covid lockdowns in 2020 and 2021 dissipates, and the remaining inflationary shock drives the most aggressive
response from global central banks for the past 30 years.
A forceful series of interest rate increases to stem burgeoning inflation, marks the end of the zero-rate environment and highly
accommodative global monetary policy of the past decade. With fallout from the Russian invasion of Ukraine continuing to drive price
instability in key energy and agri-food markets and combined with the Covid driven global supply chain issues, the inflation outlook
continues to be highly uncertain, leading to a period of much greater economic uncertainty.
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Permanent TSB Group Holdings plc - Annual Report 2022
2. Critical accounting estimates and judgements (continued)
Property prices have now reached the peak last seen in April 2007, although wages are significantly ahead of that period in 2022, and the
number of households in the economy has grown by c.400,000 with new housing supply meeting a fraction of demand. Underlying driving
forces, such as a) decade of under supply of housing (with 2022 falling short of output forecasts), b) strong population growth through
inward migration, c) record rental values, d) an influx of Ukrainian war refugees and e) exceptionally strong construction price increases,
are expected to hold property prices at current levels in 2023.
On unemployment, the Baseline model reflects both the expectation of better than expected unemployment numbers in the end of 2022,
and a rise in forecast unemployment level for 2023 to 6.5% (up 1%).
Upside scenario
This is an extreme positive scenario developed to reflect a much stronger outcome for the Irish economy than in the base scenario. There
is both historical context and statistical backing to the key forecasts, but at a positive extremity.
Average GDP growth over the forecast period is 6%, which is higher than the average of 3.9% for the Irish economy since 1950. The
outlook reflects an extreme positive of effective full employment.
Consistent with the longer term nominal house price average gain of 9.3% since 1970 ( Irish property prices are 50X higher than in 1970 in
nominal terms) and 6.4% globally during that period, the HPI forecast for the extreme positive scenario, puts average HPI increases during
the scenario under review, at 12% per annum.
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Substantially below trend CPI growth returns in the Irish economy over the forecast horizon, with inflation trends remaining highly
supportive of economic growth.
Downside scenario
The Downside scenario is an extreme scenario backed by Irish historical context and international comparatives. The scenario captures a
statistical extreme in unemployment, GDP and HPI, while maintaining credibility as a single scenario. A prolonged period of mid teen
unemployment, extends quickly, reaching a peak of 15% in 2024.
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Five years of sub normal growth across the forecast horizon in 2022 to 2027, shows a sharp reversal from current expected growth levels
and is significantly below the 3.9% average GDP growth seen in the Irish economy since 1950. GDP falls a low point of minus 11.5% over
the forecast period.
The threat of CPI moving ahead at a much faster pace than expected, is a key feature of this 1 in 20 scenario for this period, acknowledging
the weakness in the global supply chain, and the impact of the Ukraine /Russian conflict which has pushed inflationary forces to 40 year
highs.
The Group applies statistical techniques combined with expert credit judgement to formulate an unbiased probability weighted estimate of
ECL at the reporting date. A review of the methodology to calculate the final weighted estimate of ECL based on three scenario inputs
(Base, Upside and Downside scenarios) by reference to challenger methods and supplementary benchmarks was conducted in H2 2022.
The review concluded that the methodology remains in compliance with IFRS 9.
Given the relative sizes of the portfolios, the key judgemental area for the Group is in relation to the level of ECL calculated for the
residential mortgage portfolio.
Determining probability weightings of the scenarios and forecasting FLI in respect of those scenarios requires a significant degree of
Management judgement. The reported ECL allowance is impacted by the probability weighting attributed to each macroeconomic
scenario.
If the Group were to only use its Base Case Scenario for the measurement of ECL for the secured mortgage portfolio, excluding
Management’s adjustment to modelled outcomes, the ECL impairment allowance would be €98m less than reported at 31 December
2022.
Permanent TSB Group Holdings plc - Annual Report 2022
189
Notes to the Consolidated Financial Statements
(continued)
2. Critical accounting estimates and judgements (continued)
Similarly, excluding Management’s adjustment to modelled outcomes, if the Group were to only apply its Upside Scenario for the
measurement of ECL for the secured mortgage portfolio, the ECL impairment allowance would be €126m less than reported at 31
December 2022. Whereas, if the Group were to only use its Downside Scenario, the ECL impairment allowance would be €336m greater
than reported at December 2022.
The adequacy of ECL allowance is reviewed by the BAC on a half-yearly basis. At 31 December 2022, the total impairment provision
included €137m of management’s adjustments to modelled outcomes (31 December 2021: €118m) which primarily comprises the
following:
• €44m of Management’s adjustment in respect of Stage 3 residential mortgage loans that are in default for a prolonged period and for
which Management consider the modelled impairment to be insufficient to cover resolution; €31m of which are in default for greater
than seven years.
• A Management adjustment of €3m to reflect the tail risk of payment at maturity of a cohort of loans which cannot be reflected in the
residential mortgage model due to lack of empirical data.
• Management are of the view that the modelled impairment allowance may not fully reflect expected credit losses for certain cohorts of
borrowers. The Groups IFRS9 models are constructed based on a single economic cycle covering a period of low and stable inflation
rates. In addition, post pandemic demand as a result of government-led supports and economic stimulus has weakened the
relationships between model inputs and outputs. At the reporting date, a €26m management overlay is held for this risk.
• A €64m overlay to reflect the uncertainty associated with the current economic headwinds as a result of accelerated inflation and the
increasing interest rate environment. CPI accelerated to 8.2% for 2022 with the ECB rates rising by 2.5% in the year. In addition, further
increases to ECB rate are expected in 2023. The overlay comprises of €4m in respect of the consumer portfolio, €14m in respect of the
commercial portfolio and €46m in respect of the residential mortgage portfolio.
At December 2022, management judgement has been applied to specified non-standard mortgages classified as Stage 1 by Impairment
models and these loans were transferred to Stage 2 with a lifetime impairment loss allowance applied. The impact of this staging
adjustment is a c. €138m increase in Stage 2 volumes.
(b) Deferred taxation
At 31 December 2022, the Group had a net deferred tax asset of €309m (31 December 2021: €350m). See note 27 for further details.
Deferred tax assets are recognised only to the extent that it is probable that future taxable profits will be available against which the asset
can be utilised. The recognition of a deferred tax asset relies on Management’s judgements surrounding the probability and adequacy of
future taxable profits and the reversals of existing taxable temporary differences.
The most important judgement relates to Management’s assessment of the recoverability of the deferred tax asset relating to carried
forward tax losses, being €334m at 31 December 2022. It should be noted that the full deferred tax asset on tax losses relates to tax losses
generated in the PTSB legal entity (i.e. no deferred tax asset is being recognised on tax losses carried forward in any other Group
company).
The assessment of recoverability of this asset requires significant judgements to be made about the projection of long-term profitability
because of the period over which recovery extends. In addition, given PTSB’s history of recent losses, in accordance with IAS 12, there
must be convincing other evidence to underpin this assessment.
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2. Critical accounting estimates and judgements (continued)
In making the assessment, the Board considered the following factors:
• The current macroeconomic environment and external forecasts for the Irish economy particularly in light of the geopolitical
environment, the forecast interest rate rises and inflationary risks;
• The significant progress made on the Group’s NPL strategy and the deleveraging of the Group’s Non-Core portfolios in recent years;
• The current expected trajectory of the Group’s financial performance;
• The impairment performance;
• The Group’s projected liquidity and capital position;
• The absolute level of deferred tax assets on tax losses compared to the Group’s equity;
• The forecasted future profitability as a result of the Ulster Bank transaction;
• The quantum of profits required to be generated to utilise the tax losses and the extended period of time over which these profits are
projected to be generated;
• The challenge of forecasting over an extended period and in particular taking account of external factors such as global political
uncertainty, the level of competition and disruptors to the market and market size;
• Consideration of the assumptions underpinning the Group’s financial projections (on which analysis of the recoverability of the deferred
tax asset on tax losses are based). The key relevant assumptions considered being:
- No material change to the Group’s business activities in the medium term;
- Further progress in addressing the Group’s legacy, non-performing assets;
- NIM, which has benefitted from increasing interest rates, is also expected to be positively impacted by the evolution of the Group’s
lending book as new lending volumes are added and lower yielding tracker mortgages pay down; however, further material reductions
in cost of funds are considered unlikely;
- Continued focus on cost management; and
- The cost of risk will continue its return to normalised levels reflecting the Group’s assessment of the medium to long term average;
and
• Consideration of forecasting risks, including sensitivity analysis on the financial projections, such sensitivity analysis including the
effect of higher than expected impairments, cost of funds or operating expenditure, and lower than expected asset yields, new lending
or ECB rates.
Taking the above factors into account, and in the absence of any expiry date for the utilisation of carried forward tax losses in Ireland, the
Board have concluded that it is more likely than not that there will be sufficient taxable profits against which the losses can be utilised and
on the basis of the assessment above, continue to recognise €334m of a deferred tax asset on tax losses on the statement of financial
position as at 31 December 2022.
In this regard, the Group has carried out an exercise to determine the likely number of years required to utilise the deferred tax asset
arising on tax losses carried forward. Based on the Group’s latest forecast plans to 2027 and assuming a level of profitability growth
consistent with GDP growth of approximately 2.5%, it will take c. 10 years for the deferred tax asset on tax losses of €334m to be utilised. A
level of profitability consistent with GDP growth continues to be considered by Management to be appropriate given the Group’s primarily
domestic retail focus and the expectation arising therefrom that, over the long-term, the Group’s performance would be expected to
broadly track the performance of the Irish economy. While the geopolitical uncertainty has significantly impacted GDP in the short-term it
is expected that, over the medium-term, GDP will recover and Management are of the view that a long-term assumed growth rate of 2.5%
is not unreasonable in this context.
IFRS does not allow for the deferred tax asset recognised to be discounted notwithstanding that it is likely to take a number of years for it
to be recovered.
The expected period of time to full utilisation of the deferred tax asset has decreased since 31 December 2021 from 22 to 10 years. This is
mainly due to forecast interest rate rises and the impact of the Ulster Bank transaction. These revised profitability figures also impact the
assumed long-term projections for the Group with the result that the expected utilisation period has decreased.
Permanent TSB Group Holdings plc - Annual Report 2022
191
Notes to the Consolidated Financial Statements
(continued)
2. Critical accounting estimates and judgements (continued)
It should be noted that Management make certain judgements in the process of applying the Group’s accounting policies which may
impact on amounts recognised in the financial statements and consequently on taxable profits and the utilisation of tax losses. As set out
in note 27, analysis carried out demonstrates that were certain adverse events to arise (see below for further detail of the adverse events
considered) it continues to be Management’s view that there would be sufficient future taxable profits against which the full quantum of
tax losses carried forward could be utilised, albeit that the period of time over which such utilisation would occur would be extended.
It should be further noted that the analysis of the estimated utilisation of the deferred tax asset arising on tax losses carried forward in
PTSB is based on the current business model of the Group.
The recognition of this asset is dependent on the Group earning sufficient profits to utilise the tax losses. The quantum of and timing of
these profits is a source of significant estimation uncertainty. However, as a principle, the Group is expecting to be profitable in the
medium term. Consequently the key uncertainty relates principally to the time period over which these profits will be earned. Whilst the
Group may be more or less profitable in certain periods owing to various factors such as the interest rate environment, loan loss
provisions, operating costs and the regulatory environment, Management expect that, notwithstanding these, the Group will be profitable
over the long term. Consequently, any change to these factors which would ultimately impact on profitability, are highly subjective, but will
only impact on the time period over which this asset is recovered.
As set out above, in assessing the appropriateness of recognising a deferred tax asset on tax losses carried forward, Management has
considered the impact of various stress case scenarios on the period of recoverability. The three scenarios identified as having potentially
significant implications for the deferred tax asset recoverability are (i) adverse changes in the interest rate environment, (ii) increased
impairment charges and (iii) increases in operating costs. These sensitivity case scenarios are intended to simulate a situation where
there is an economic downturn. If any one of the stress case scenarios were to occur, within a reasonably possible range, it is our
expectation that the time period over which these assets might be recovered could extend by 1 year. If all adverse assumptions were to
arise the period of recoverability would be extended by 1 year (i.e. full utilisation by 2033). However, Management consider this scenario
unlikely. Changes in these assumptions are most impacted by changes to house prices and unemployment, which represent the majority
of any expected stress loss which could occur. This position will continue to be reviewed for each reporting period; however, much of this
estimation uncertainty may not be resolved for a number of years. However, as noted, based on the Group’s latest forecast plan, it is
Management estimate that the expected time period for recovery of the deferred tax asset on tax losses to be 10 years, i.e. full utilisation is
expected by 2032.
(c) Fair Value of Financial instruments
The Group’s accounting policy for the determination of fair value of financial instruments is set out in note 1(vii)(e). The best evidence of
fair value is quoted prices in an active market. The absence of quoted prices increases reliance on valuation techniques and requires the
use of judgement in the estimation of fair value. This judgement includes evaluating available market data, determining the expected cash
flows for the instruments, as well as identifying and applying an appropriate discount rate and credit spread.
Valuation techniques that rely on non-observable data require a higher level of Management judgement in estimating the fair value
compared to those based on observable data.
The quality of market data, valuation techniques and other inputs into the valuation models used are subject to internal review and
approval.
The Group carries certain financial assets at fair value. In estimating the fair value of these assets and derivatives, the Group seeks to use
quoted market prices (level 1). Where quoted market prices are not available, the Group uses internally developed valuation models and
valuations from external experts. Inputs to these models are taken from observable market data where possible (level 2) but where this is
not possible, a degree of judgement is used (level 3). Such judgement considerations typically include items such as interest rate yield
curves, equity prices, option volatilities and currency rates.
Further details of the fair value of financial assets and liabilities are set out in note 37.
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Permanent TSB Group Holdings plc - Annual Report 2022
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2. Critical accounting estimates and judgements (continued)
(d) Impairment review of its subsidiary undertaking
The Company carries its investment in its subsidiary undertaking at cost and reviews whether there is any indication of impairment at
each reporting date. Impairment testing involves comparing the carrying value of the investment to its recoverable amount. The
recoverable amount is the higher of the investment’s fair value or its value-in-use (VIU).
An impairment charge arises if the carrying value exceeds the recoverable amount and where the carrying value is not supported by the
estimated discounted future cash flows of the underlying business. Management note that the market capitalisation of the Group is lower
than its net assets. The depressed share price is a result of the overall subdued banking environment currently in which the entity
operates along with various entity specific factors that affect the liquidity of the shares. The recoverable amount of the investment is the
higher of its fair value less costs to sell or it’s VIU. The carrying value of the investment in PTSB plc was €888m as at 31 December 2021.
During 2022, an AT1 issuance of €245m (net of transaction costs) and a share issuance related to Project Sun of €516m occurred which
brought the carrying value to €1,649m. The recoverable amount based on the VIU is in excess of the carrying amount after the reversal of
previous impairment charges. On the basis that the VIU in in excess of the carrying value no impairment charge is required (31 December
2021: impairment charge of €66m). Management have considered whether a reversal of impairment charge from previous years is
appropriate. Having reviewed external and internal information management noted that there had been a significant change in the value of
the asset, primarily due to the increased forecast profitability as a result of the Ulster Bank transaction and increased interest rates. On
this basis, management were satisfied there was sufficient headroom to take a full write back of the previous impairment charges of
€697m.
The VIU is the present value of the future free cash flows expected to be derived from the investment, based upon a VIU calculation
discounted at an appropriate rate for the investment.
The recoverable amount reflecting Management’s best estimate is sensitive to changes in the following key assumptions:
Cash flow forecasts
Cash flow forecasts are based on internal management information used for strategic planning for a period of up to five years, after which
a long-term growth rate appropriate for the business is applied. The key cash flows in these forecasts are as follows:
• Forecasted net lending growth, which is based on historical experience of the Group, strategic priorities and direction;
• Forecasted SME business and increase in fee based income portfolio based on the targets for the coming years;
•
•
• Operating profits based on historical experience, average margins adjusted for impacts of cost saving initiatives and future operating
Increase in the loan book as result of the Ulster Bank business combination;
Increase in revenue due to interest rate increases;
models;
Impairment charge based on historical experience and forecasted general macro-economic outlook;
•
• Deposits projections based on the liquidity funding needs of the Groups; and
Issuance / redemptions of the debt issued and other capital raising activities.
•
The projected cash flows are stress tested with actual performance and verifiable economic data annually to reflect current market
conditions and Management’s best estimates of future projections.
Growth rate
Growth rate is determined by reference to long-term economic growth and does not exceed the relevant long-term average growth rate of
the industry in which it operates. A growth rate of 2.5% was used.
Discount rate
The discount rate used is a post-tax weighted average cost of capital of the Group of 10% (2020: 10%) as the cash flows used in
impairment assessment are post tax cash flows. The discount rate includes an additional risk premium to account for various specific
risks. These specific risks are not reflected in the cash flows projected for impairment analysis.
The discount rate is used for various internal pricing models and is benchmarked with the industry averages to cater for the any changes
in risk profile of the Group.
The Group uses post-tax discount rate as the cash flows generated by the subsidiary are post tax cash flows.
Permanent TSB Group Holdings plc - Annual Report 2022
193
Notes to the Consolidated Financial Statements
(continued)
2. Critical accounting estimates and judgements (continued)
Sensitivity analysis
The impact of changes in the growth rate, the discount rate and cash flows has been assessed by the Directors:
• A decrease in ECB interest rate of 100bps would result in a VIU in excess of the carrying value after impairment write-back, resulting in
no impairment charge;
• An increase in operating expenses of €20m per annum, would result in a VIU in excess of the carrying value after impairment write-
back, resulting in no impairment charge;
• An increase of 1% in long-term growth rate would result in a VIU in excess of the carrying value after impairment write-back, resulting in
no impairment charge.;
• A decrease of 1% in long-term growth rate would result in a VIU in excess of the carrying value after impairment write-back, resulting in
no impairment charge.;
• An increase of 1% in the discount rate would result in a VIU in excess of the carrying value after impairment write-back, resulting in no
impairment charge.; and
• A decrease of 1% in the discount rate would result in a VIU in excess of the carrying value after impairment write-back, resulting in no
impairment charge.
(e) IFRS 3 Business Combination Accounting (BCA) including fair value of acquired net assets
On 17 December 2021, PTSB entered into a conditional agreement to acquire a business from Ulster Bank consisting of certain elements
of its non-tracker residential mortgage portfolio, SME portfolio and asset finance portfolio. The acquisition also included 25 branches and
the workforce associated with the various businesses and branches. The agreement was effected through a series of linked contracts and
became unconditional on 7 November 2022. For operational reasons, the above businesses/ assets will not transfer to the group on a
single date. The group took possession of the majority of the mortgage book and its associated workforce on 7 November 2022 (the
Principal Completion Date). The branches and associated workforce transferred in January 2023 and the SME assets (including
associated employees) transferred in February 2023. The remainder of the mortgage book, and the asset finance assets (including
associated employees) are expected to transfer to the group in the first half of 2023.
This agreement was accounted for as a business combination on the Principal Completion Date with the purchase price allocation (PPA)
and fair value of the net assets acquired being determined on that date. This gave rise to gain on bargain purchase of €362m. The forward
purchase of the loans yet to be transferred under the contract is accounted for as a derivative from that date. See note 3 for further details.
The accounting for this transaction required Management to make certain critical accounting judgements and estimates.
Critical Accounting Judgement
Management had to make the following accounting judgements:
• whether the agreement should be accounted for as one transaction or a number of transactions- this impacts both the measurement of
the assets acquired and the recognition date;
• whether the agreement is a business combination or an asset acquisition - this impacts recognition of the gain on bargain purchase
and the measurement of the assets at initial recognition (fair value for business combination or at the amount of consideration paid for
an asset purchase);
• when the acquisition is accounted for - this determines the accounting period in which the assets and gain are recognised and
measured; and
• what is measured at the acquisition date.
Management considered these judgements in detail and concluded as follows:
Judgement
Conclusion
How many transactions are
there?
Management considered the requirements of IFRS 3 and IFRS 9 and believe that the group should
account for this agreement as one overall transaction due to following reasons:
1. the various legal agreements are linked by one overarching framework agreement;
2. all the transactions documents were signed at the same time with the same counterparty and each
such document contemplates the completion of the others;
3. there was a substantive business need to structure the transaction in this way i.e., operational
reasons;
4. in substance, the entire transaction relates to the purchase of a certain part of Ulster Bank’s Irish
banking business by the group.
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2. Critical accounting estimates and judgements (continued)
Judgement
Conclusion
What is PTSB acquiring – a
business or assets?
When is the acquisition
accounted for?
What is measured?
Management considered the requirements of IFRS 3 and concluded that this transaction collectively
constitutes the acquisition of a business on the basis it includes acquired inputs (the loan books) and
substantive processes which are embodied in the key individuals transferring (credit risk, underwriting
and customer relationship management) along with sufficient support staff. The assessment of
whether an acquired set of activities and assets constitutes a business must include, at a minimum, an
input and substantive process and whether when these are applied to an input or inputs it is critical to
the ability to continue producing outputs. This assessment must be performed from the perspective of
a market participant. The mere existence of an output (e.g. interest income) doesn’t indicate that both
an input and a substantive process have been acquired. Management considerd substantive processes
to include strategic, operational and resource management processes in order to be considered a
business. These processes are usually documented but the intellectual capacity of an organised
workforce with the necessary skills and experience also provide the necessary processes to determine
the acquired set of assets and activities as a business. Management determined that the acquisition of
the organised workforce from Ulster Bank that included key individuals with the necessary skills and
experience to direct the substantive processes within credit risk, underwriting and customer
relationship management met the requirements of IFRS 3. As a result, the entire transaction was
accounted for as a business combination.
Management considered the requirements of IFRS 3 and concluded that there is one business
combination date and that this takes place at the Principal Completion Date i.e., when the mortgage
business (being the majority of the mortgage book and workforce (including key mortgage employees))
transfers. The fact that certain parts of the business do not transfer for operational reasons at this date
does not change this judgement. As noted above this is one unconditional, interrelated transaction. The
mortgage business, which amounts to the vast majority of the overall business, is irreversibly
transferred on this date with the rest of the assets and workforce being contractually obliged to follow.
As a result, the business combination is accounted for as at this date.
The Directors considered the requirements of IFRS 3 and IFRS 9 and concluded that what is measured
is the fair value of the net assets transferred at the Principal Completion Date and that the contractual
obligation for assets to be transferred after the Principal Completion Date creates derivatives (forward
purchase) which are fair valued at the date. These derivatives are accounted for a fair value until the
actual transfer of the underlying assets
This transaction has been accounted for as a business combination under IFRS 3 (as described above). If this transaction was not
accounted for as a business combination no gain on bargain purchase would be recognised and the timing of asset recognition and
associated measurement including subsequent EIR would be significantly different.
Critical Accounting Estimates
Business combination accounting required Management to make certain critical accounting estimates being the fair value of the assets
acquired including derivatives. Management engaged the services of independent third-party valuers to provide valuations of the assets
being transferred in the transaction. The fair value of the branch properties was determined using the open market prices. As there was no
observable market price for the loans (Level 3), their fair value was calculated using discounted cashflow model and included calculating
the expected contractual cash flows of the assets and applying the following to the portfolio of assets; prepayment rate, redemption rate,
transition rate (from fixed to variable rates and vice versa), probability of default (PD) and loss given default assumptions, servicing cost,
risk weights based on the asset characteristics and a discount rate based on cost of funding, capital and targeted capital ratio.
See notes 3 and 37 for sensitivities relating to the fair values.
Permanent TSB Group Holdings plc - Annual Report 2022
195
Notes to the Consolidated Financial Statements
(continued)
3. Business combination
On 17 December 2021, PTSB entered into a legally binding agreement with NatWest Group Plc (‘NatWest’) to acquire certain elements of
the Retail mortgage lending, Asset Financing and SME businesses, including 25 branch properties and staff of Ulster Bank Ireland DAC
(‘Ulster’) in the Republic of Ireland. On 7 November 2022 the transaction was completed when €5.2bn of the Retail business assets and
significant processes were acquired by the Bank thereby legally binding the Bank to acquire the remaining Retail, Asset Financing and
SME assets. No voting interest in Ulster was acquired as part of the acquisition. The remaining Retail, Asset Financing and SME assets are
envisioned to be acquired by the Bank on subsequent dates in the first half of 2023.See note 2(e) for further details on this transaction.
The acquisition of the Ulster business was accounted for under IFRS 3: Business Combinations and therefore, any resulting negative
goodwill/gain on bargain purchase is calculated as the excess of the fair value of the identifiable assets acquired and the liabilities
assumed over the fair value of the consideration transferred. In this transaction a gain on bargain purchase arose because the fair value of
the assets and liabilities acquired exceeded the fair value of the consideration paid. This is as a result of a number of external factor’s
including NatWest’s decision to leave the Irish market therefore the Bank acquired the assets at a discount to their fair value. The
accounting for the business acquisition was completed on 7 November 2022 when business combination accounting was achieved.
The details of the business combination are as follows:
Fair value of consideration transferred
Amount settled in cash
Equity consideration
Contingent consideration
Total
Recognised amounts of identifiable net assets – at fair value
Retail mortgage lending
Forward Contract Derivatives
Total
Gain on bargain purchase
31 December
2022
€m
4,816
155
37
5,008
5,386
(16)
5,370
(362)
The total fair value of the consideration transferred on the acquisition date was €5,008m and consists of;
• Cash €4,816m;
• Liability for contingent consideration to be paid in cash €37m;
• 90,893,627 ordinary shares of the Group at €1.70 (share price on close of business 4 November 2022) €155m (See note 35 for further
detail)
The liability for contingent consideration consists of a liability to pay an equity cash consideration amount based on 4.04% of the Banks
ordinary shares (after the issuance of shares on the acquisition date described below) using a volume weighted average price (VWAP) of
the Banks ordinary shares for a period of 60 days post the acquisition date. On the acquisition date the liability is measured using the
closing share price on 4 November 2022 of €1.70. The undiscounted range of outcomes based on the highest and lowest VWAP in the 60
day period are €37m and €41m. The contingent consideration is accounted for at fair value until settlement. This liability was settled in
January 2023 when cash of €41m was paid to NatWest.
The total fair value of the net assets acquired on the acquisition date was €5,370m and consists of;
• Loans and advances to customers: €5,385m
• Retail mortgages Fair value: €5,385m, Gross contractual receivable: €5,218m
• Forward Contract Derivatives Fair Value: €(16)m
The fair value measurements were performed by independent professional valuers having appropriate qualifications and recent
experience in the fair value measurement of loans and properties in the locations and categories being valued.
196
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3. Business combination (continued)
A discounted cash flow model was used to estimate the fair value of the acquired retail mortgage assets. This included calculating the
expected contractual cash flows of the assets and applying the following to the portfolio of assets; prepayment rate, redemption rate,
transition rate (from fixed to variable rates and vice versa), probability of default (PD) and loss given default assumptions, servicing cost,
risk weights based on the asset characteristics and a discount rate based on cost of funding, capital and targeted capital ratio.
The forward contract derivatives represent the remaining Retail lending assets and the entirety of the Asset Financing and SME assets
and Branch Properties that will not be transferred until a later date and therefore the Bank have not acquired control of these assets. As
the business combination was accounted for on 7 November 2022, the Group is required to account for derivatives for the forward
purchase of the remaining Retail lending assets and the entirety of the Asset Financing and SME assets and Branch Properties on that
date. The forward contract derivatives are measured as the net of the fair value of the assets based on the above discounted cash flow
model and the fair value of the consideration to be transferred i.e. the gross outstanding balance. The same discounted cash flow model
was used to estimate the fair value of the remaining assets to be acquired. The Branch Properties were measured at their open market
prices.
The gross fair value of the assets to be acquired as at the acquisition date included as part of the forward contract derivatives are as
follows. These are based on an estimate of the outstanding balance of these loans on their expected transfer date.
• €889m in relation to the remaining mortgage assets
• €164m in relation to SME assets
• €436m in relation to asset finance assets
• €9m in relation to branch properties
The gross fair value of the consideration to be transferred as at the acquisition date included as part of the forward contract derivatives
are as follows. These are based on an estimate of the outstanding balance of these loans on their expected transfer date.
• €893m in relation to the remaining mortgage assets
• €174m in relation to SME assets
• €438m in relation to asset finance assets
• €9m in relation to branch properties
See note 37 for further detail on fair value of the forward contract derivatives as at 31 December 2022 and the related sensitives.
The Branch Properties (including associated employees) transferred in January 2023 and €9m cash was paid to NatWest. The SME
assets (including associated employees) transferred in February 2023 and €162m cash was paid to NatWest.
In accordance with IFRS 3 as the fair value of the assets acquired and the liabilities assumed (€5,008m) is in excess of the fair value of the
consideration transferred (€5,370m) a gain on bargain purchase of €362m was recognised on the acquisition date in the Income
Statement. Management recognised this gain in Exceptional Items.
An assessment of sensitivity to changes in the discount rates used in the discounted cash flow model was performed. A 25 basis point
increase in the discount rate results in a reduction of the gross fair value of the business combination of €87m, a 25 basis point decrease
in the discount rate results in an increase of the gross fair value of the business combination of €90m.
Under section 71 of the Companies Act 2014 as the consideration for the acquisition of the Ulster business includes the issuance of
ordinary shares, Company law requires that the share premium be recognised as the difference between the nominal value of shares and
the fair value of the consideration received. This results in the shares being issued at €5.68 per share as part of the consideration
transferred. The share price on the issuance date was €1.70 per share with €0.50 being recognised in Share Capital and €1.20 being
recognised in Share Premium. As the remaining fair value of the consideration received is in excess of the fair value of the shares this
excess is required by law to be included in share premium and is, therefore, reclassified directly in equity between Retained Earnings and
Share Premium. The excess amount is the gain on bargain purchase of €362m.
The acquired retail assets incurred a pre-tax loss of €21m from the acquisition date to the reporting date primarily due to initial recognition
of ECL on the acquired loans. Revenue from the acquisition date to 31 December 2022 was €16m. The day 1 ECL recognised of this
transaction was €30m. This is not included in the gain on bargain purchase.
Permanent TSB Group Holdings plc - Annual Report 2022
197
Notes to the Consolidated Financial Statements
(continued)
3. Business combination (continued)
If the business assets (including retail, SME and asset finance) had been acquired on 1 January 2022, revenue of the Group for 2022 would
have increased by €167m, and pre-tax profit for the year would have increased by €57m. The basis for this is estimate is data received on
the loan assets since the acquisition date.
Acquisition-related costs amounting to €92m are not included as part of consideration transferred and have been recognised as an
expense in the consolidated income statement, as part of exceptional items within total operating expenses. €1m of transaction costs were
incurred as part of the share issuance to NatWest. These are recognised in Share Premium.
4. Operating segments
The Group reports one operating segment which is in accordance with IFRS 8 ‘Operating segments’.
In line with IFRS 8, the Group also reports revenue from external customers for each major group of products and services. The amount of
revenue reported is based on the financial information used to produce the Group’s financial statements. The Group also reports revenue
and non-current assets on a geographical basis; Ireland and Isle of Man (IOM)
The ExCo as the Chief Operating Decision Maker (CCDM) is responsible for implementing the strategic management of the Group as
guided by the Board. The ExCo reviews key performance indicators and internal management reports on a monthly basis.
4.1 Revenue from external customers split by products and services
The sources from which the Group earns external revenue are: interest income, fee and commission income, net trading income, and
other operating income. Total revenue from external customers was €501m (2021: €431m). The main products from which the Group
earns external revenue include: mortgages; consumer finance; and treasury assets. The interest income from these products is set out in
the table below. Net interest income from external customers split by product:
31 December
2022
31 December
2021
Mortgages
Consumer finance*
Treasury assets
Wholesale funding
Total
€m
354
33
11
19
417
*Consumer finance comprises income from term loans, credit cards and overdrafts.
4.2 Profit for the year based on geographical location
During the years ended 31 December 2022 and 31 December 2021, the majority of the Group's profit/(loss) was incurred in Ireland.
Immaterial losses (less than €1m) were incurred outside of Ireland in the Group's IOM subsidiary PBI Ltd during the years ended 31
December 2022 and 31 December 2021.
4.3 Assets and liabilities based on geographical location
31 December 2022
Assets
Held for sale
Other assets
Total segment assets
Total segment liabilities
Capital expenditure
Ireland
€m
18
25,914
25,932
23,534
112
Of which inter-
group balances
€m
-
(56)
(56)
(56)
-
-
IOM*
€m
-
1
1
1
-
-
*This is based on geographical locations and reflects Group intercompany activity with PBI Ltd.
198
Permanent TSB Group Holdings plc - Annual Report 2022
€m
315
31
7
1
354
Total
€m
18
25,915
25,933
23,535
112
4. Operating segments (continued)
31 December 2021
Assets
Held for sale
Other assets
Total segment assets
Total segment liabilities
Capital expenditure
*This is based on geographical locations and reflects Group intercompany activity with PBI Ltd.
5. Net interest income
Ireland
€m
28
22,205
22,233
20,444
65
Of which inter-
group balances
€m
IOM*
€m
-
2
2
2
-
-
(59)
(59)
(59)
-
Total
€m
28
22,207
22,235
20,446
65
Year ended
31 December
2022
€m
Year ended
31 December
2021
€m
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Interest income
Loans and advances to customers
Loans and advances to banks
Debt securities and other fixed-income securities
Deposits from banks
Interest expense
Deposits from banks
Due to customers
Debt securities in issue
Loans and advances to banks
Subordinated liabilities
Net interest income
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346
-
7
1
354
-
(14)
(8)
(14)
(5)
(41)
313
387
15
11
4
417
(10)
(10)
(16)
(10)
(9)
(55)
362
Net interest income includes a charge of €22m in respect of deferred acquisition costs and €4m amortisation on the day 1 gain generated
by the migration of the mortgages as a result of the Ulster Bank business combination(31 December 2021: deferred acquisition costs of
€17m).
6. Fees and commission income
Fees and commission income
Retail banking and credit card fees
Brokerage and insurance commission
Other fees and commission income
Fees and commission income
Fees and commission expense *
Net fees and commission income
* Fees and commission expenses primarily comprises retail banking and credit cards fees.
Year ended
31 December
2022
€m
Year ended
31 December
2021
€m
65
9
1
75
(33)
42
52
11
1
64
(29)
35
Permanent TSB Group Holdings plc - Annual Report 2022
199
Notes to the Consolidated Financial Statements
(continued)
7. Net trading Income
Held-for-trading
Foreign exchange gains
Net trading income
8. Net other operating income
Other income
Net other operating income
9. Administrative, staff and other expenses (excluding exceptional items)
Staff costs (as detailed below)
Other general and administrative expenses
Administrative, staff and other expenses (excluding exceptional items)
Year ended
Year ended
31 December
2022
31 December
2021
€m
€m
3
3
2
2
Year ended
Year ended
31 December
2022
31 December
2021
€m
6
6
€m
11
11
Year ended
Year ended
31 December
2022
31 December
2021
€m
152
150
302
€m
142
121
263
Administrative, staff and other expenses (excluding exceptional items) includes costs of €4m in relation to legacy legal cases in 2022 (31
December 2021: €15m).
Fees paid to the Group’s auditors for services outlined below
Statutory auditor’s remuneration (including expenses and excluding VAT)
- Audit of the individual and the Group financial statements
- Other assurance services
- Other non-audit services*
Year ended
Year ended
31 December
2022
31 December
2021
€m
€m
1.4
0.1
0.8
1.1
0.1
0.3
* Other non-audit services for 2022 primarily relate to the Project Sun Class 1 Circular to shareholders and comfort letters and other services in relation to the Group’s Euro Notes
Programme and subsequent debt issuance, the AT1 issuance and the Fastnet securitisations. Other non-audit services in 2021 include comfort letters and other services in relation
to the Fastnet securitisations, the Group’s Euro Note Programme and subsequent debt and capital issuances.
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9. Administrative, staff and other expenses (excluding exceptional items) (continued)
Staff costs
Wages and salaries (including commission payable to sales staff)
Social insurance
Pension costs
• Payments to defined contribution pension schemes
Total staff costs
Year ended
Year ended
31 December
2022
31 December
2021
€m
124
15
13
152
€m
115
14
13
142
Staff redundancy costs associated with exceptional items for the year ended 31 December 2022 and 31 December 2021 are included as
part of note 11 exceptional Items.
Staff costs of €13m (31 December 2021: €13m), have been capitalised to Intangible assets (see note 26), as the cost incurred was directly
related to developing software and it is probable that future economic benefits that exceed its cost will flow from its use over more than
one year. Therefore these costs are not included in this note.
Staff numbers
Closing and average number of staff (including Executive Directors) employed during the year are as follows:
Closing staff numbers*
Average staff numbers
2022
2021
2022
2021
Ireland
Total number of staff
2,614
2,614
2,236
2,236
2,422
2,422
2,286
2,286
*Closing staff numbers are calculated on a full time equivalent (FTE) basis. Includes 126 closing and 70.6 average staff numbers working on the Ulster Bank transaction.
10. Bank levy and other regulatory charges
Bank levy
Other regulatory charges
Bank levy and other regulatory charges
Year ended
Year ended
31 December
2022
31 December
2021
€m
22
29
51
€m
22
28
50
Other regulatory charges include €19m for the Deposit Guarantee Scheme (DGS) (31 December 2021: €17m), €5m for the Single
Resolution Fund (SRF) (31 December 2021: €4m), €4m for the Central Bank Industry Funding Levy (31 December 2021: €5m) and €1m
related to other regulatory charges (31 December 2021: €2m).
Permanent TSB Group Holdings plc - Annual Report 2022
201
Notes to the Consolidated Financial Statements
(continued)
11. Exceptional items
Gain on bargain purchase (a)
Costs incurred in relation to the Ulster Bank transaction (b)
Restructuring and other costs (c)
Impairment arising from deleveraging of loans (d)
Exceptional items
Year ended
Year ended
31 December
2022
31 December
2021
€m
362
(92)
(13)
8
265
€m
-
(28)
(14)
19
(23)
(a) The Group recognised a gain on bargain purchase of €362m in respect of the Ulster Bank transaction. This was treated as an
exceptional gain in the Income Statement. Please see notes 2 and 3 for further information.
(b) During 2022, the Group incurred costs of €92m in relation to the Ulster Bank transaction.
The Group incurred costs of €28m on the transaction in 2021, these costs were also recognised as exceptional costs in the income
statement.
The Group has incurred total costs of €120m on the Transaction during 2021 and 2022.
(c) Restructuring and other costs of €13m (31 December 2021: €14m) relate to additional costs incurred as a result of phase 2 of the
Group’s Enterprise Transformation Programme which was originally announced in 2020 and costs arising in respect of a previous disposal
of a business.
(d) The definition of exceptional items was refined to exclude profit or loss on material loan deleveraging post 31 December 2021 (including
any increase in impairment arising solely as a result of the sale of loans) due to the sale of loans becoming part of the Group’s normal
recovery strategy.
During 2022, warranty provisions and accruals of €8m were released in relation to loan transactions that the Group executed in prior
years.
During 2021, an impairment write-back of €11m was recognised as a result of the sale of the Glenbeigh III mortgage portfolio which met
the conditions as noted above. Warranty provisions of €4m were written back in relation to loan transactions which the Group executed in
prior years. An indemnity provision of €4m was also released relating to the sale of the Glenbeigh II loan sale.
The Group considers these releases as exceptional as the warranty and indemnity provisions were previously recorded through
exceptional impairment. This treatment is consistent with the treatment of losses on deleveraging of loans in prior years.
202
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12. Taxation
(a) Analysis of taxation charge
Current taxation
Charge for current year
Deferred taxation
Origination and reversal of temporary differences
Deferred taxation recognised in the income statement (note 27)
Taxation charged/(credited) to income statement
Year ended
Year ended
31 December
2022
31 December
2021
€m
€m
2
2
42
42
44
1
1
(2)
(2)
(1)
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Effective tax rate
16%
5%
The Group taxation charge for the year ended 31 December 2022 was €44m (31 December 2021: €1m credit) of which €39m was in
respect of a corporation tax charge on exceptional items. The main drivers of this charge/credit include (i) a current tax charge of €2m
arising on trading and non-trading income, (ii) a current year deferred tax charge of €39m arising from the utilisation of tax losses carried
forward to shelter tax adjusted profits arising in the year, and (iii) the partial release of a DTA of €3m created on the introduction of IFRS 9.
(b) Reconciliation of standard to effective tax rate
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Year ended
Year ended
31 December
2022
31 December
2021
Profit/(loss) on the Group activities before tax
Tax calculated at standard ROI corporation tax rate of 12.5% (2021: 12.5%)
Tax effect of non-deductible expenses and non-trading income
Other
Adjustment to tax losses carried forward
Taxation charged/(credited) to income statement
(c) Tax effects of each component of other comprehensive income
Revaluation of property
Fair value reserve:
- Change in fair value of equity instruments
- Change in fair value of debt instruments
- Transfer to income statement on asset disposal
31 December 2022
€m
267
33
10
1
-
44
Year ended 31 December 2022
Gross
€m
(8)
3
-
-
(5)
Tax
€m
2
(1)
-
-
1
€m
(21)
(3)
2
-
-
(1)
Net
€m
(6)
2
-
-
(4)
Permanent TSB Group Holdings plc - Annual Report 2022
203
Notes to the Consolidated Financial Statements
(continued)
12. Taxation (continued)
Revaluation of property
Fair value reserve:
-Change in fair value of equity instruments
-Change in fair value of debt instruments
- Transfer to income statement on asset disposal
31 December 2021
13. Earnings/(loss) per ordinary share
(a) Basic earnings/(loss) per ordinary share
Year ended 31 December 2021
Gross
€m
2
2
-
-
4
Tax
€m
-
-
-
-
-
Net
€m
2
2
-
-
4
Year ended
Year ended
31 December
2022
31 December
2021
Weighted average number of ordinary shares in issue and ranking for dividend excluding treasury
shares
468,387,212
454,690,912
Profit/(loss) for the year attributable to equity holders
Less AT1 coupon paid (see note 35)
Profit/(loss) for the year attributable to equity holders less AT1 coupon paid
Basic earnings/(loss) per ordinary share (€ cent)
(b) Diluted earnings/(loss) per ordinary share
Weighted average number of ordinary shares excluding treasury shares held under employee benefit
trust used in the calculation of diluted earnings per share
Diluted earnings/(loss) per ordinary share (€ cent)
€223m
(€10m)
€213m
(€20m)
(€21m)
(€41m)
45.4
(9.0)
Year ended
Year ended
31 December
2022
31 December
2021
468,387,212
454,690,912
45.4
(9.0)
Diluted earnings/(loss) per ordinary share is calculated by adjusting the weighted average number of ordinary shares outstanding to
assume conversion of all dilutive potential ordinary shares.
No adjustment to the weighted average number of ordinary shares for the effects of dilutive potential ordinary shares was required for the
year ended 31 December 2022 or 31 December 2021 as the AT1 securities issued in 2020 and 2022 have no conversion features. The AT1
securities issued in 2015 was assessed due to the conversion feature within the security, and was found to have an anti-dilutive effect. It
was redeemed on the first call of 1 April 2021.
Weighted average number of ordinary shares*
2022
2021
Number of ordinary shares in issue at 1 January (note 35)
454,695,492
454,695,492
Treasury shares held (note 35)
Net movements during the year
Weighted average shares redesignated
Weighted average shares issued
Weighted average number of ordinary shares
(4,580)
(4,580)
-
13,696,300
-
-
468,387,212
454,690,912
* When calculating the earnings/(loss) per share the weighted average number of ordinary shares outstanding during the year and all years presented shall be adjusted for events
other than the conversion of potential ordinary shares that have changed the number of ordinary shares without a corresponding change in reserves.
204
Permanent TSB Group Holdings plc - Annual Report 2022
13. Earnings/(loss) per ordinary share (continued)
On 7 November 2022, the Group issued 90,893,627 shares as part of the consideration transferred for the retail mortgage activities and
significant processes of Ulster Bank. See notes 2 and 3 for further details.
There are no instruments with a potential to be converted to ordinary shares at 31 December 2021 as the AT1 security issued in 2015 was
redeemed on the first call date of 1 April 2021 (see note 35 for further detail). The AT1 securities issued in 2022 and 2020 have no
conversion features within the securities.
14. Cash and cash equivalents
For the purpose of the statement of cash flows, cash and cash equivalents comprise of following:
Cash at bank
Items in the course of collection
Loans and advances to banks repayable on demand (maturity of less than 3 months) (note 15)
Cash and cash equivalents as per statement of cash flows
31 December
2022
31 December
2021
€m
58
40
2,123
2,221
€m
57
20
4,174
4,251
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At 31 December 2022, restricted cash of €408m (31 December 2021: €330m) consists of cash of €405m (31 December 2021: €329m)
held by the Group’s securitisation entities and €3m (31 December 2021: €1m) which relates to cash collateral placed with counterparties in
relation to derivative positions and repurchase agreements.
The following contractual restrictions apply to our securitisation vehicles cash balances;
• Each vehicle must hold an amount equal to a percentage of the outstanding notes in a reserve account on demand as part of the credit
enhancement and liquidity support rules. These funds can only be used to fund any revenue shortfall for contractual payments and must
be replenished as soon as additional funds are available. When the notes are fully repaid these reserve funds can be used to pay
outstanding principal on the subordinated loan.
As a result of these restrictions, the group excluded these balances from cash and cash equivalents in prior period cash flow statements.
However, the group reviewed this treatment on foot of a decision taken by IFRIC in 2022. This IFRIC decision clarified that such balances
should be included in cash and cash equivalents and removed inconsistencies in accounting treatment in the market place. As a result,
the group are including these balances in cash and cash equivalents in the cash flow statement for both 2022 and 2021.
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15. Loans and advances to banks
Held at amortised cost
Placed with central banks
Placed with other banks
Loans and advances to banks
31 December
2022
31 December
2021
€m
€m
1,619
504
2,123
3,709
465
4,174
Placements with other banks includes restricted cash of €408m (31 December 2021: €330m) of which €405m (31 December 2021:
€329m) is held by the Group’s securitisation entities and €3m (31 December 2021: €1m) which relates to cash collateral placed with
counterparties in relation to derivative positions and repurchase agreements. The fair value of collateral pledged by counterparties in
relation to reverse repurchase agreements at 31 December 2022 is €8m (31 December 2021: €433m).
Loans and advances to banks amounting to €2,123m (31 December 2021: €4,174m) have a maturity of less than three months and
therefore have been treated as cash and cash equivalents, with the exception of restricted cash as noted above.
Permanent TSB Group Holdings plc - Annual Report 2022
205
Notes to the Consolidated Financial Statements
(continued)
16. Derivative financial instruments
Derivative instruments are primarily used by the Group to hedge against foreign currency risk.
Certain derivative instruments do not fulfil the hedge accounting criteria under IFRS 9 and are consequently classified as held for trading
(HFT). All derivatives are carried at fair value.
The derivative instruments used by the Group include currency forward rate contracts, which are commitments to purchase and sell
currencies, including undelivered spot transactions.
As disclosed in note 3 the forward contract derivatives represent the remaining Retail lending assets and the entirety of the Asset
Financing and SME assets and branch properties that will not be transferred until a later date. The forward contract derivatives are
measured as the net of the fair value of the assets and the fair value of the consideration to be transferred i.e. the gross outstanding
balance. The forward contract derivative was valued as a liability of €12m as at 31 December 2022. See notes 2 and 3 for further detail.
Further details on the Group’s risk management policies are set out in the Risk Management Report.
Derivatives held by the Group are analysed as follows:
31 December 2022
31 December 2021
Contract/
notional
amount
€m
Fair
value
asset
€m
Fair
value
liability
€m
Contract/
notional
amount
€m
Fair
value
asset
€m
Fair
value
liability
€m
82
1,520
1,602
1,602
-
-
-
-
1
12
13
13
84
-
84
84
1
-
1
1
-
-
-
-
31 December
2022
31 December
2021
€m
-
1
1
€m
310
-
310
Held for trading
Forwards
Business combination forwards
Derivative financial instruments
as per the statement of financial
position
17. Other assets
Loan sale receivable
Other
Loan sale receivable at 31 December 2021 relates to the amount due from the purchaser of the Glenbeigh III portfolio, which was received
in the first quarter of 2022.
Other assets include accruals for miscellaneous debtors of €1m at 31 December 2022 (31 December 2021:€nil).
18. Assets classified as held for sale
At 31 December 2022, assets classified as held for sale amounted to €18m (31 December 2021: €28m). This relates to collateral in
possession. These properties are expected to be sold within the next 12 months.
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19. Debt securities
Government bonds
Corporate bonds
Gross debt securities
31 December
2022
31 December
2021
Total HTC
Total HTC
€m
€m
3,128
49
3,177
2,434
60
2,494
As at 31 December 2022, all unpledged debt securities are available to be used and are eligible as collateral (though eligibility will depend
on the criteria of the counterparty) in sale and repurchase agreements.
Debt securities that are managed on a HTC business model basis are accounted for at amortised cost. Debt securities that are managed
on a HTC&S basis are accounted for at FVOCI.
Government bonds of €3.1bn (31 December 2021: €2.4bn) comprise Irish, Spanish, Portuguese, French, Italian and EU government bonds
which are designated as HTC. Corporate bonds of €49m (31 December 2021: €60m) comprise Residential Mortgage Backed Securities
(RMBS) and are designated as HTC. The HTC securities represent a portfolio of securities purchased for the purpose of collecting
contractual cashflows to maturity. The Group has no HTC&S securities as at 31 December 2022 (31 December 2021: €nil).
At 31 December 2022, debt securities at amortised cost with a fair value of €654m (31 December 2021: €732m) had been pledged to third
parties in sale and repurchase agreements. The Group has not derecognised any securities delivered in such sale and repurchase
agreements on the statement of financial position.
All debt securities at 31 December 2022 are stage 1 for ECL purposes.
(a) HTC
The movement in HTC securities is classified as follows:
As at 1 January
Additions
Maturities
Interest net of cash receipts
Amortisation of premium/(discount)
Total
31 December
2022
31 December
2021
HTC
€m
2,494
972
(251)
3
(41)
3,177
HTC
€m
2,583
-
(46)
-
(43)
2,494
(b) Amounts arising from impairment provisioning on debt securities:
Held at amortised cost
As at 31 December 2022, the amount arising from ECL on debt securities measured at amortised cost is €0.6m (31 December 2021:
€0.7m). The ECL on debt instruments measured at amortised cost is offset against the carrying amount of the assets in the statement of
financial position.
Permanent TSB Group Holdings plc - Annual Report 2022
207
Notes to the Consolidated Financial Statements
(continued)
20. Equity securities
As at 1 January
Revaluation
Total equity securities
The carrying value of equity securities can be analysed as follows:
Unlisted
Gross equity securities
31 December
2022
31 December
2021
€m
26
4
30
€m
24
2
26
31 December
2022
31 December
2021
€m
30
30
€m
26
26
PTSB Group holds Series A and Series B preferred stock in Visa Inc. at 31 December 2022 with a value of €30m. The Series A preferred
stock was initially acquired during 2020 upon the conversion of Series B preferred stock by Visa Inc (the latest conversion occurred in July
2022). These were fair valued at €26m and €4m respectively at 31 December 2022 (31 December 2021: €17m and €9m) and are
recognised in the statement of financial position at FVOCI.
The fair value of the preferred stock Series A is classified as Level 1 and the fair value of the preferred stock Series B is classified as Level
3, as the valuation of these preferred stock includes inputs that are based on unobservable data (refer to note 37 for details).
21. Prepayments and accrued income
31 December
2022
31 December
2021
€m
175
32
207
€m
182
23
205
31 December
2022
31 December
2021
€m
€m
7,915
11,249
19,164
239
401
19,804
(521)
310
19,593
7,337
6,854
14,191
196
358
14,745
(604)
115
14,256
Visa prepayments
Other prepayments
22. Loans and advances to customers
Loans and advances by category are set out below:
Residential mortgages
- Held through special purpose entities
- Held directly
Commercial mortgage loans
Consumer finance (term loans/other)
Gross loans and advances to customers
Less: provision for impairment (note 23)
Deferred fees, discounts and fair value adjustments
Net loans and advances to customers
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22. Loans and advances to customers (continued)
Loans and advances can be analysed into tracker, fixed and variable rate loans as follows:
Tracker rate
Variable rate
Fixed rate
Deferred fees, discounts and fair value adjustments
Total
Gross loans and advances to
customers
Net loans and advances to
customers
31 December
2022
31 December
2021
31 December
2022
31 December
2021
€m
€m
€m
€m
4,378
2,788
12,638
19,804
310
20,114
6,027
2,820
5,898
14,745
115
14,860
4,099
2,665
12,519
19,283
310
19,593
5,605
2,688
5,848
14,141
115
14,256
The Group has established a number of securitisation entities. This involved transferring the Group’s interest in pools of residential
mortgages to a number of special purpose entities which issued mortgage-backed floating-rate notes to fund the purchase of the interest
in the mortgage pools. The notes are secured by a first fixed charge over the residential mortgages in each pool and may be sold to
investors or held by the Group and used as collateral for borrowings.
Details of the residential mortgage pools sold to special purpose entities and the notes issued by the special purpose entities are included
below:
Residential mortgages held through special purpose entities
Notes issued by special purpose entities
- rated
- unrated
The notes issued by these special purpose entities comprise the following:
Sold to third parties and included within debt securities in issue (non-recourse)
on the Statement of financial position (note 30)
Held by other banks and institutions as part of collateralised lending or sale and
repurchase agreements (note 28)
Available collateral*
Rated notes, unavailable for collateral
Unrated notes
Total
*The eligibility of available collateral will depend on the criteria of the counterparty.
31 December
2022
31 December
2021
€bn
€bn
7.9
6.7
1.2
7.3
6.1
1.2
31 December
2022
31 December
2021
€bn
€bn
-
0.3
5.6
0.8
1.2
7.9
0.2
-
5.3
0.6
1.2
7.3
Permanent TSB Group Holdings plc - Annual Report 2022
209
Notes to the Consolidated Financial Statements
(continued)
22. Loans and advances to customers (continued)
Loans and advances balance movement for the year ended 31 December 2022 and the year ended 31 December 2021 is set out in the
following tables:
Non-credit impaired
Credit impaired
Stage 1
€m
Stage 2
€m
Stage 3
€m
POCI
€m
Balance as at 1 January 2022
11,689
2,239
New assets originated*
Loans acquired
Stage Transfers:
Transfers from Stage 1 to Stage 2
Transfers to Stage 3
Transfers from Stage 2 to Stage 1
Transfers from Stage 3
Net movement arising from transfer of Stage
Redemptions and repayments
Decrease due to write offs
Disposals
Other movements
Balance as at 31 December 2022
* Loan originations are net of repayments in the year
Balance as at 1 January 2021
New assets originated*
Stage Transfers:
Transfers from Stage 1 to Stage 2
Transfers to Stage 3
Transfers from Stage 2 to Stage 1
Transfers from Stage 3
Net movement arising from transfer of Stage
Redemptions and repayments
Decrease due to write offs
Disposals
Other movements
Balance as at 31 December 2021
* Loan originations are net of repayments in the year
2,586
5,063
(296)
(16)
344
2
34
(1,575)
(1)
(341)
-
17,455
111
-
296
(119)
(344)
155
(12)
(242)
(2)
(395)
-
1,699
Non-credit impaired
Stage 1
€m
10,575
1,843
(311)
(23)
875
5
546
(1,270)
-
(5)
-
11,689
Stage 2
€m
3,152
111
311
(257)
(875)
185
(636)
(259)
(5)
(124)
-
2,239
815
-
-
-
135
-
(157)
(22)
(62)
(40)
(42)
-
649
2
-
-
-
-
-
-
-
-
-
-
(1)
1
Credit impaired
Stage 3
€m
POCI
€m
1,127
2
-
280
-
(190)
90
(78)
(60)
(266)
-
815
1
-
-
-
-
-
-
-
-
-
1
2
Total
€m
14,745
2,697
5,063
-
-
-
-
-
(1,879)
(43)
(778)
(1)
19,804
Total
€m
14,855
1,956
-
-
-
-
-
(1,607)
(65)
(395)
1
14,745
During 2021 Stage 2 balances declined by €636 million. The decline is primarily attributable to:
• PD refinements incorporating greater segmentation of default information for mortgage customers distinguishing between nonstandard
mortgage defaults and standard mortgage defaults (€404m move to stage 1); and
• Improvements in risk grade and reduction in forborne accounts (€163m move to stage 1).
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23. Impairment provisions
Loans and advances to customers
The following table reflects non-performing loans for which ECL provisions are held and an analysis of Stage 1, Stage 2 and Stage 3 ECL
provisions across the loans and advances to customers portfolio.
The non-performing loan balance as at 31 December 2022 was €650m (31 December 2021: €817m). Refer to note 38 for further details.
31 December 2022
Residential:
-Home loans
-Buy-to-let
Commercial
Consumer Finance:
-Term loans/other
Total gross loans
Impairment provision
Deferred fees, discounts and fair
value adjustments
Balance as at 31 December
2022
31 December 2021
Residential:
-Home loans
-Buy-to-let
Commercial
Consumer Finance:
-Term loans/other
Total gross loans
Impairment provision
Deferred fees, discounts and fair
value adjustments
Loans and
advances to
customers
€m
18,340
824
239
401
19,804
(521)
310
19,593
Loans and
advances to
customers
€m
12,568
1,623
196
358
14,745
(604)
115
Balance as at 31 December 2021
14,256
NPLs
€m
342
270
23
15
650
NPLs
€m
420
339
44
14
817
ECL provisions
NPL % of
total loans
Stage 1
Stage 2
Stage 3
%
€m
€m
€m
1.9%
32.8%
9.6%
3.7%
3.3%
127
3
1
5
136
50
68
30
15
163
103
96
9
14
222
ECL provisions
NPL % of
total loans
Stage 1
Stage 2
Stage 3
%
€m
€m
€m
3.3%
20.9%
22.5%
3.9%
5.5%
55
1
-
5
61
45
152
30
11
238
127
145
23
10
305
Total ECL
provisions
as % of
total
loans
%
Total
€m
280
167
40
34
521
1.5%
20.3%
16.7%
8.5%
2.6%
Total ECL
provisions
as % of
total
loans
%
Total
€m
227
298
53
26
604
1.8%
18.4%
27.0%
7.3%
4.1%
Permanent TSB Group Holdings plc - Annual Report 2022
211
Notes to the Consolidated Financial Statements
(continued)
23. Impairment provisions (continued)
A reconciliation of the provision for impairment losses for loans and advances is as follows:
2022
Total by portfolio
ECL as at 1 January 2022
Redemptions and repayments
Net remeasurement of loss allowance
Loan originations
Loans acquired
Net movement excluding derecognition
Derecognition-disposals
Derecognition-repossessions
Derecognition-write offs*
Derecognition
ECL as at 31 December 2022
Net movement excluding derecognition (from above)
Interest income booked but not recognised
Write offs net of recoveries
Impairment charge on loans and advances to customers for the
year ended 31 December 2022
Residential
mortgages
€m
Commercial
€m
Consumer
finance
€m
525
(18)
(41)
34
37
12
(64)
(3)
(23)
(90)
447
53
(9)
(16)
13
-
(12)
-
-
(1)
(1)
40
26
(1)
5
7
-
11
-
-
(3)
(3)
34
Total
€m
604
(28)
(52)
54
37
11
(64)
(3)
(27)
(94)
521
11
(8)
4
7
* The Group writes off an impaired financial asset (and the related impairment allowance), either partially or in full, when there is no realistic prospect of recovery. In circumstances
where the net realisable value of any collateral has been determined and there is no reasonable expectation of further recovery, write-off may be earlier than collateral realisation.
2021
Total by portfolio
ECL as at 1 January 2021
Redemptions and repayments
Net remeasurement of loss allowance
Loan originations
Net movement excluding derecognition
Derecognition-disposals
Derecognition-repossessions
Derecognition-write offs*
Derecognition
ECL as at 31 December 2021
Net movement excluding derecognition (from above)
Interest income booked but not recognised
Write offs net of recoveries
Impairment write-back on loans and advances to customers for the
year ended 31 December 2021
Residential
mortgages
€m
Commercial
€m
Consumer
finance
€m
639
(45)
35
16
6
(84)
(1)
(35)
(120)
525
53
(4)
(4)
13
5
(2)
-
(3)
(5)
53
36
(3)
(8)
5
(6)
-
-
(4)
(4)
26
Total
€m
728
(52)
23
34
5
(86)
(1)
(42)
(129)
604
5
(8)
2
(1)
* The Group writes off an impaired financial asset (and the related impairment allowance), either partially or in full, when there is no realistic prospect of recovery. In circumstances
where the net realisable value of any collateral has been determined and there is no reasonable expectation of further recovery, write-off may be earlier than collateral realisation.
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23. Impairment Provisions (continued)
Total by stage
Stage 1
€m
Stage 2
€m
Stage 3
€m
ECL as at 1 January 2022
Transfer to Stage 1
Transfer to Stage 2
Transfer to Stage 3
Stage transfers
Redemptions and repayments
Net remeasurement of loss allowance
Loan originations
Loans Acquired
Net movement excluding derecognition
Derecognition-disposals
Derecognition-repossessions
Derecognition-write offs*
Derecognition
ECL as at 31 December 2022
Net movement excluding derecognition (from above)
Interest income booked but not recognised
Write offs net of recoveries
Impairment charge on loans and advances to customers for the
year ended 31 December 2022
61
13
(3)
-
10
(5)
-
34
37
66
(1)
-
-
(1)
136
238
(13)
39
(19)
7
(11)
(34)
20
-
(25)
(56)
-
(1)
(57)
163
305
-
(36)
19
(17)
(12)
(18)
-
-
(30)
(7)
(3)
(26)
(36)
222
Total
€m
604
-
-
-
-
(28)
(52)
54
37
11
(64)
(3)
(27)
(94)
521
11
(8)
4
7
* The group writes off an impaired financial asset (and the related impairment allowance), either partially or in full, when there is no realistic prospect of recovery. In circumstances
where the net realisable value of any collateral has been determined and there is no reasonable expectation of further recovery, write off may be earlier than collateral realisation.
Permanent TSB Group Holdings plc - Annual Report 2022
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Notes to the Consolidated Financial Statements
(continued)
23. Impairment Provisions (continued)
Total by stage
Stage 1
€m
Stage 2
€m
Stage 3
€m
ECL as at 1 January 2021
Transfer to Stage 1
Transfer to Stage 2
Transfer to Stage 3
Stage transfers
Redemptions and repayments
Net remeasurement of loss allowance
Loan originations
Net movement excluding derecognition
Derecognition-disposals
Derecognition-repossessions
Derecognition-write offs*
Derecognition
ECL as at 31 December 2021
Net movement excluding derecognition (from above)
Interest income booked but not recognised
Write offs net of recoveries
Impairment write-back on loans and advances to customers for the
year ended 31 December 2021
55
23
(4)
-
19
(4)
(26)
17
(13)
-
-
-
-
61
286
(23)
42
(44)
(25)
(27)
(9)
17
(19)
(2)
-
(2)
(4)
238
387
-
(38)
44
6
(21)
58
-
37
(84)
(1)
(40)
(125)
305
Total
€m
728
-
-
-
-
(52)
23
34
5
(86)
(1)
(42)
(129)
604
5
(8)
2
(1)
*The group writes off an impaired financial asset (and the related impairment allowance), either partially or in full, when there is no realistic prospect of recovery or on foot of a
negotiated settlement. In circumstances where the net realisable value of any collateral has been determined and there is no reasonable expectation of further recovery, write off
may be earlier than collateral realisation.
Modified Financial Assets
At 31 December 2022 there have been no significant modified financial assets for which the loss allowance has changed from lifetime to
12-month ECL.
From time to time, the original terms of a customer’s loan is modified either as part of the ongoing relationship or arising from changes in
the customer’s circumstances such as when that customer is unable to make the agreed original contractual repayments. The risk of
default of such assets after modification is assessed at the reporting date and compared with the risk under the original terms at initial
recognition, when the modification is not substantial and so does not result in de-recognition of the original asset.
The gross carrying amount of modified financial assets for which impairment loss allowance has changed from lifetime to 12-month
expected credit losses during the year is €52m.
24. Interest in associated undertakings
Synch Payments and Clearpay
First Home Scheme Ireland
31 December
2022
€m
31 December
2021
€m
3
10
13
2
-
2
The Group owns a non-controlling interest in Synch Payments DAC (25%) and Clearpay DAC (33%). These investments are accounted for
under the equity method in the consolidated financial statements and have a carrying value of €3m at 31 December 2022 (31 December
2021: €2m). Post-acquisition costs of €0.4m have been capitalised in 2022.
These investments will be increased or decreased by the Group’s share of the profit or loss which will be assessed annually.
On 1 July 2022, The Group entered into a joint venture with First Home Scheme Ireland DAC. This investment is accounted for under the
equity method in the consolidated financial statements and was initially recognised at €11m, post-acquisition losses of €1m have been
recognised.
In presenting details of the associates of the Group, the exemption permitted by Section 316 of the Companies Act 2014 has been availed
of and the Group will annex a full listing of associates to its annual return to the Companies Registration Office.
214
Permanent TSB Group Holdings plc - Annual Report 2022
25. Property and equipment
2022
Cost or valuation
At 1 January
Additions
Revaluations
Depreciation write-back on
revaluation
Disposals/lease exits or
cancellations
At 31 December
Accumulated depreciation
At 1 January
Provided in the year
Eliminate on revaluation
At 31 December
Held at fair
value land and
buildings
€m
Held at cost
buildings
Held at cost
office and
computer
equipment
Right-of-use assets*
Leased
buildings
Leased motor
vehicles
€m
117
11
-
-
-
128
(77)
(7)
-
(84)
44
€m
€m
€m
91
18
-
-
-
109
(69)
(8)
-
(77)
-
32
49
13
-
-
(1)
61
(20)
(5)
-
(25)
36
2
1
-
-
-
3
(2)
-
-
(2)
1
99
-
(7)
(1)
-
91
-
(1)
1
-
91
Net book value at 31 December
* For further details on right-of-use assets refer to note 34.
Of the €7m net revaluation loss, €8m is included in the revaluation reserve in the statement of comprehensive income and €1m
impairment write-back is recognised on land and buildings in the income statement.
2021
Cost or valuation
At 1 January
Additions
Revaluations
Depreciation write-back on
revaluation
At 31 December
Accumulated depreciation
At 1 January
Provided in the year
Eliminate on revaluation
At 31 December
Net book value at 31 December
Held at fair
value land and
buildings
Held at cost
land and
buildings
Held at cost
office and
computer
equipment
Right-of-use assets*
Leased
buildings
Leased motor
vehicles
€m
98
-
2
(1)
99
-
(1)
1
-
99
€m
107
10
-
-
117
(71)
(6)
-
(77)
40
€m
€m
€m
85
6
-
-
91
(61)
(8)
-
(69)
22
46
3
-
-
49
(14)
(6)
-
(20)
29
2
-
-
-
2
(2)
-
-
(2)
-
t
r
o
p
e
R
c
g
e
t
a
r
t
S
i
e
c
n
a
n
r
e
v
o
G
s
t
n
e
m
e
t
a
t
S
l
i
a
c
n
a
n
F
i
n
o
i
t
a
m
r
o
f
n
I
l
a
r
e
n
e
G
Total
€m
358
43
(7)
(1)
(1)
392
(168)
(21)
1
(188)
204
Total
€m
338
19
2
(1)
358
(148)
(21)
1
(168)
190
* For further details on right-of-use assets refer to note 34.
Of the €2m revaluation gain, €2m is included in the revaluation reserve in the statement of comprehensive income and no impairment
write-back is recognised on land and buildings in the income statement.
Permanent TSB Group Holdings plc - Annual Report 2022
215
Notes to the Consolidated Financial Statements
(continued)
25. Property and equipment (continued)
The net book value of land and buildings includes the following:
Land
Buildings - freehold fair value
Buildings - freehold cost
Buildings - leasehold
31 December
31 December
2022
€m
30
61
33
47
171
2021
€m
32
67
26
43
168
Land and buildings at 31 December 2022 held at fair value was €91m (31 December 2021: €99m). The historic cost of land and buildings
under the cost model is €92m (31 December 2021: €117m).
Fair value measurement of Group’s land and buildings
The Group’s freehold land and buildings are stated at their revalued amounts, being the fair value at the date of revaluation less any
accumulated depreciation recognised from the date of the latest revaluation. On the date of revaluation any accumulated depreciation is
eliminated. The fair value measurements of the Group’s freehold land and buildings as at 31 December 2022 and 31 December 2021 were
performed by independent professional valuers having appropriate qualifications and recent experience in the fair value measurement of
properties in the locations and categories being valued. The effective date of revaluation is 31 October 2022 and 31 October 2021.
The fair value of the freehold land and buildings was determined based on a market comparable approach that reflects recent transaction
prices for similar properties using capitalisation yields ranging from 5% to 10.75%. There has been no change to the valuation techniques
during the year.
Details of the freehold land and buildings and information about the fair value hierarchy as defined in the Group’s accounting policy as at
31 December 2022 and 31 December 2021 are as follows:
31 December 2022
Land
Buildings - freehold
31 December 2021
Land
Buildings - freehold
Level 1
€m
-
-
-
Level 1
€m
-
-
-
Level 2
Level 3 Total fair value
€m
30
61
91
€m
-
-
-
€m
30
61
91
Level 2
Level 3 Total fair value
€m
32
67
99
€m
-
-
-
€m
32
67
99
216
Permanent TSB Group Holdings plc - Annual Report 2022
26. Intangible assets
Software
Cost
At 1 January
Additions
At 31 December
Accumulated amortisation
At 1 January
Provided in the year
At 31 December
Net book value at 31 December
27. Deferred taxation
Deferred tax liabilities
Deferred tax assets
Net deferred tax assets
t
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o
p
e
R
c
g
e
t
a
r
t
S
i
e
c
n
a
n
r
e
v
o
G
s
t
n
e
m
e
t
a
t
S
l
i
a
c
n
a
n
F
i
31 December
2022
31 December
2021
€m
224
69
293
(102)
(31)
(133)
160
€m
178
46
224
(76)
(26)
(102)
122
31 December
2022
31 December
2021
€m
(25)
334
309
€m
(26)
376
350
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o
i
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Net deferred tax assets are attributable to the following:
2022
Property and equipment
Unrealised gains/(losses) on assets/liabilities
Losses carried forward
Other temporary differences
2021
Property and equipment
Unrealised gains/(losses) on assets/liabilities
Losses carried forward
Other temporary differences
Recognised in
income
statement
Recognised in
equity
At 1 January
Recognised in
other
comprehensive
income At 31 December
€m
(20)
(6)
373
3
350
€m
-
-
(39)
(3)
(42)
€m
-
(1)
-
-
(1)
€m
2
-
-
-
2
€m
(18)
(7)
334
-
309
Recognised in
income
statement
Recognised in
equity
At 1 January
Recognised in
other
comprehensive
income At 31 December
€m
(21)
(5)
370
5
349
€m
1
-
3
(2)
2
€m
-
(1)
-
-
(1)
€m
-
-
-
-
-
€m
(20)
(6)
373
3
350
Permanent TSB Group Holdings plc - Annual Report 2022
217
Notes to the Consolidated Financial Statements
(continued)
27. Deferred taxation (continued)
In line with the requirements of IAS 12 “Deferred Tax Assets”, Management and Directors formed the view that there should be sufficient
future taxable profits within the PTSB legal entity against which PTSB tax losses carried forward can be used. Management and Directors
have reviewed this position as at 31 December 2022 and remain of the view that it is appropriate to continue to recognise a deferred tax
asset on the full quantum of tax losses carried forward in PTSB. This information is based on the following supporting evidence: (i) a review
of the quantum of tax losses carried forward in PTSB in conjunction with forecasted profitability (the projections used having been
approved by the Board of Directors). This review demonstrated that it is probable that there will be sufficient future taxable profits within
PTSB against which the full quantum of tax losses carried forward can be utilised; (ii) The consideration of forecasting risks, including
sensitivity analysis on the financial projections used (including an analysis of the effects of higher than expected impairment levels and
lower than expected net interest margin). This analysis demonstrated, were certain adverse events to occur, it would remain probable that
there would be sufficient future taxable profits within PTSB against which the full quantum of tax losses carried forward could be utilised,
albeit that the period of time over which such utilisation would occur would be extended; and (iii) The consideration of a number of other
factors which may impact the utilisation of the tax losses including the macroeconomic environment, progress made on the Group’s NPL
strategy and the Group’s financial position. These factors are set out in further details in note 2, Critical accounting estimates and
judgements.
It should also be noted that under current Irish tax legislation there is no time restriction on the utilisation of trading losses. Therefore, the
tax losses carried forward in PTSB are available for utilisation against profits of the same trade in any future period. Also, the Directors are
satisfied that taxable future profits should be available to recover the remaining deferred tax assets.
The total unrecognised deferred tax assets on carried forward tax losses at 31 December 2022 amounted to €20m (31 December 2021:
€20m) which relates to the Group’s subsidiaries.
Included in the overall deferred tax asset is a deferred tax asset of €nil in relation to Permanent TSB Group Holdings plc (31 December
2021: €42k).
In accordance with IFRS these balances are recognised on an undiscounted basis.
28. Deposits by banks
Placed by other banks and institutions on repurchase agreements
Other deposits
Deposits by banks
31 December
2022
31 December
2021
€m
611
3
614
€m
347
-
347
Securities which are sold under agreements to repurchase are secured by Irish and other eligible Government bonds. These agreements
are completed under market standard Global Master Repurchase Agreements. The fair value of the financial assets pledged under existing
agreement to repurchase is €654m at 31 December 2022 (31 December 2021: €732m).Other deposits include €3m (31 December 2021:
€nil) of cash collateral placed in relation to derivative positions and repurchase agreements.
29. Customer accounts
Term deposits
Demand deposits
Current accounts
Notice and other accounts
Customer accounts
31 December
2022
31 December
2021
€m
1,509
8,871
8,983
2,367
€m
2,226
7,657
7,104
2,102
21,730
19,089
At 31 December 2022, the Group held corporate deposits of €1.2bn (31 December 2021: €1.4bn).
An analysis of the contractual maturity profile of customer accounts is set out in the liquidity risk section of note 38 of the consolidated
financial statements.
218
Permanent TSB Group Holdings plc - Annual Report 2022
30. Debt securities in issue
At amortised cost
Bonds and medium-term notes
Non-recourse funding
Maturity analysis
Repayable in less than 1 year
Repayable in greater than 1 year but less than 5 years
Repayable in greater than 5 years
31 December
2022
31 December
2021
€m
658
–
658
10
648
–
658
€m
352
172
524
2
350
172
524
Bonds and medium-term notes
In June 2022, PTSBGH issued €300m of Senior Unsecured Medium Term Notes priced at a fixed rate of 5.25% per annum, maturing on
30 June 2025. Interest is payable on the nominal amount annually in arrears on the coupon date.
t
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e
t
a
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i
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c
n
a
n
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v
o
G
s
t
n
e
m
e
t
a
t
S
l
i
a
c
n
a
n
F
i
Non-recourse funding
As at 31 December 2022 the Group had no advances (31 December 2021: €172m) collateralised on residential property loans (31 December
2021: €153m) subject to non-recourse funding by way of residential mortgage securitisations. Residential mortgage securitisations involve
transferring the interest in pools of mortgages to special purpose entities which issue mortgage-backed floating rate notes to fund the
purchase of the interest in mortgage pools. These loans, which have not been de-recognised, are shown within loans and advances to
customers while the non-recourse funding is shown as a separate liability.
n
o
i
t
a
m
r
o
f
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I
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e
G
Non-recourse funding reduced by €172m between 31 December 2021 and 31 December 2022 to nil, primarily due to the accelerated
redemption of a securitisation during the year. The Group did not have any defaults of principal or interest or other breaches with respect
to non-recourse funding during 2022.
Under the terms of these securitisations, the rights of the providers of the related funds are limited to the mortgage loans in the
securitised portfolios, together with any related income generated by the portfolios and the subordinated loans provided by the Group,
without further recourse to the Group. During the term of the transactions, any amounts realised from the portfolios in excess of that due
to the providers of the funding, less any related administrative costs, will be paid to the Group. The providers of this funding have agreed in
writing (subject to the customary warranties and covenants) that they will seek repayment of the finance, as to both principal and interest,
only to the extent that sufficient funds are generated by the mortgages and related security and any subordinated loans provided by the
Group, and that they will not seek recourse in any other form.
31. Other liabilities
Amounts falling due within one year
PAYE and social insurance
Creditor accruals
Other*
Lease liability (see note 34 for further information on lease liabilities)
Total amounts falling due within one year
Amounts falling due greater than one year
Lease liability (see note 34 for further information on lease liabilities)
Total amounts falling due greater than one year
Total other liabilities
31 December
2022
31 December
2021
€m
5
84
54
6
149
32
32
181
€m
4
79
56
5
144
26
26
170
* Other includes €38m relating to additional cash consideration payable for the Ulster business acquired by the Group in 2022 and other miscellaneous liabilities. In 2021, other
includes €48m relating to the deposit received by the Group on 11 November 2021 as part of the purchase price for the sale of the Glenbeigh III portfolio and miscellaneous liabilities.
Permanent TSB Group Holdings plc - Annual Report 2022
219
Notes to the Consolidated Financial Statements
(continued)
32. Provisions
2022
Provision
for legacy,
legal and
compliance
liabilities
Restructuring
costs
€m
6
2
-
(4)
4
€m
28
8
(3)
(10)
23
2021
Provision
for legacy,
legal and
compliance
liabilities
Restructuring
costs
€m
28
7
-
(29)
6
€m
29
21
(3)
(19)
28
Other
€m
21
39
(6)
(1)
53
Total
€m
55
49
(9)
(15)
80
Other Total
€m €m
20
9
(7)
(1)
21
77
37
(10)
(49)
55
As at 1 January
Provisions made during the year
Write-back of provisions during
the year
Provisions used during the year
As at 31 December
The provision at 31 December 2022 is €80m (31 December 2021: €55m) which is comprised of the following:
Restructuring costs
During 2020, the Group announced an Enterprise Transformation programme. At 31 December 2020, a provision for restructuring of €27m
was recognised based on the estimate of the costs of this programme. During 2021 an additional provision of €7m was made and an
amount of €29m was utilised as part of this programme. During 2022 a further provision of €2m was made and an amount of €4m was
utilised. The remaining provision of €3m is based on an estimate of the remaining costs to bring the programme to a conclusion. This
programme is expected to conclude within the next 12 months.
The Group remains a lessee on a number of non-cancellable leases over properties that it no longer occupies following a restructure in
2013. The remaining provision of €1m relates to dilapidation costs associated with the remaining properties.
Provision for legacy, legal and compliance liabilities
As at 31 December 2022, the Group has provisions of €23m relating to legal, compliance and other costs of on-going disputes in relation to
legacy business issues (31 December 2021: €28m).
A provision of €8m was made during 2022 relating to legal, compliance and other costs of on-going disputes in relation to legacy business
issues.
Management has exercised judgment in arriving at the estimated provision in respect of the potential liabilities.
Other
As at 31 December 2022, the provision of €53m (31 December 2021: €21m) primarily relates to Stamp Duty (€25m) arising as a result of
the Ulster Bank transaction. Other amounts include indemnities and guarantees provided by the Group, together with further costs,
relating to the deleveraging of various asset portfolios.
33. Subordinated liabilities
At amortised cost:
€250m Tier 2 capital notes due August 2031, Callable 2026
Maturity date
Repayable in less than 1 year
Repayable in greater than 1 year but less than 5 years
Repayable in greater than 5 years
220
Permanent TSB Group Holdings plc - Annual Report 2022
31 December
2022
31 December
2021
€m
252
252
€m
252
252
31 December
2022
31 December
2021
€m
3
-
249
252
€m
3
-
249
252
33. Subordinated liabilities (continued)
Tier 2 capital notes – PTSBGH
In May 2021, PTSBGH issued €250m of Tier 2 capital notes at a fixed rate of 3% per annum. The notes mature on 19 August 2031 with a
call date of any date from and including 19 May 2026 to and including 19 August 2026. The call is subject to approval of the regulatory
authorities, with approval conditional on meeting the requirements of the EU CRR.
The interest rate will be reset, in the event that the securities are not called, on 19 August 2026 to Euro 5 year Mid Swap rate plus a margin
of 3.221% per annum. The loan is subordinated and ranks as Tier 2 capital with interest paid annually in arrears on 19 August. The loan
may be subject to the exercise of Irish Statutory loss absorption powers by the relevant resolution authority.
In the event of winding up of PTSBGH, the Tier 2 capital notes will be:
junior in right of payment to all Senior Claims;
•
• pari passu with all other subordinated claims against PTSBGH which constitute, or would but for any applicable limitation on the amount
of such capital constitute, Tier 2 capital notes or that rank or are expressed to rank pari passu with the obligations of PTSBGH under
Tier 2 capital notes; and
in priority to PTSBGH ordinary shares, preference shares and junior subordinated obligations or other securities of PTSBGH which by
law rank, or by their terms are expressed to rank, junior to the Tier 2 capital notes.
•
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t
a
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c
n
a
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v
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G
s
t
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m
e
t
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a
c
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a
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F
i
34. Leases
Right-of-use assets*
As at 1 January 2022
Additions
Lease exits and cancellations
Depreciation of right-of-use assets
Balance as at 31 December 2022
Right-of-use assets*
As at 1 January 2021
Additions
Lease exits and cancellations
Depreciation of right-of-use assets
Balance as at 31 December 2021
Lease liabilities*
As at 1 January 2022
Additions
Lease exits or cancellations
Repayment of lease liabilities
Balance as at 31 December 2022
Land and
buildings Motor vehicles
€m
29
13
(1)
(5)
36
€m
-
1
-
-
1
Land and
buildings Motor vehicles
€m
32
3
-
(6)
29
€m
-
-
-
-
-
Land and
buildings Motor vehicles
€m
31
13
(1)
(6)
37
€m
-
1
-
-
1
n
o
i
t
a
m
r
o
f
n
I
l
a
r
e
n
e
G
Total
€m
29
14
(1)
(5)
37
Total
€m
32
3
-
(6)
29
Total
€m
31
14
(1)
(6)
38
Permanent TSB Group Holdings plc - Annual Report 2022
221
Notes to the Consolidated Financial Statements
(continued)
34. Leases (continued)
Lease liabilities*
As at 1 January 2021
Additions
Lease exits or cancellations
Repayment of lease liabilities
Balance as at 31 December 2021
* Right-of-use assets are included in PPE and lease liabilities are included in Other liabilities.
Lease liabilities
Maturity analysis - contractual undiscounted cash flows*
Less than one year
One to five years
More than five years
Total undiscounted lease liabilities
Lease liabilities included in the statement of financial position
Current lease liability
Non-current lease liability
* The maturity analysis of undiscounted lease liabilities are disclosed in note 38.
Amounts recognised in income statement*
Interest on lease liabilities
Expenses relating to short-term leases
Depreciation of right-of-use assets
Total charge in income statement
Land and
buildings Motor vehicles
€m
€m
34
3
-
(6)
31
-
-
-
-
-
Total
€m
34
3
-
(6)
31
31 December
2022
€m
31 December
2021
€m
7
18
15
40
38
6
32
6
16
10
32
31
5
26
31 December
2022
€m
31 December
2021
€m
-
(1)
(5)
(6)
-
(1)
(6)
(7)
* Interest expense on the lease liabilities amounted to €0.4m (31 December 2021: €0.4m) whereas expenses relating to short-term leases amounted to €0.6m (31 December 2021:
€0.6m) and is included in Administrative, staff and other expenses (excluding exceptional items).
Amounts recognised in statement of cash flow
Cash outflow for leases
Total
31 December
2022
€m
31 December
2021
€m
(6)
(6)
(6)
(6)
As a lessee
i. Real estate
The Group leases retail properties for its branch operations. The lease term of retail properties typically run for a period of 10-35 years. The
Group does not have variable lease payments and its leases do not contain extension options.
ii. Vehicles
The Group leases vehicles with lease terms of three to five years. The Group has no option to purchase the assets at the end of the
contract term and it does not guarantee the residual value of the leased assets at the end of the contract term.
iii. Sub-leases
The Group has no sub leases as at 31 December 2022 (31 December 2021: two properties).
222
Permanent TSB Group Holdings plc - Annual Report 2022
35. Share capital, reserves and other equity instruments
Share capital
Share capital is the funds raised as a result of a share issue and comprises the ordinary shares of the holding company Permanent TSB
Group Holdings plc.
The holders of ordinary shares are entitled to receive dividends as declared from time to time, and are entitled to one vote per share at
meetings of the Bank. All ordinary rank equally with regard to the Bank’s residual assets.
Authorised share capital
31 December 2022
Ordinary shares of €0.50 each
31 December 2021
Ordinary shares of €0.50 each
Issued share capital
The movement in the number of paid up ordinary shares is as follows:
Balances as at 31 December 2022
As at 1 January 2022
Movement
As at 31 December 2022
Issued share capital (€m)
Shares held under employee benefit trust
% of authorised capital issued
t
r
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c
g
e
t
a
r
t
S
i
e
c
n
a
n
r
e
v
o
G
s
t
n
e
m
e
t
a
t
S
l
i
a
c
n
a
n
F
i
Number of
shares
1,550,000,000
Number of
shares
1,550,000,000
€m
775
€m
775
€ 0.50 Ordinary
shares
Total
454,695,492
90,893,627
545,589,119
273
4,580
273
35%
n
o
i
t
a
m
r
o
f
n
I
l
a
r
e
n
e
G
On 7 November 2022, the Group issued 90,893,627 shares at €5.68 per share as part of the consideration transferred for the Ulster Bank
transaction. The share price on the issue date of €1.70 was recognised in Share Capital at €0.50 per share and the excess in Share
Premium. The remaining premium of €3.98 is recognised in Share Premium and represents the gain on bargain purchase that is
transferred from Retained Earnings to Share Premium as per below. See notes 2 and 3 for further detail.
Balances as at 31 December 2021
As at 1 January 2021
Movement
As at 31 December 2021
Issued share capital (€m)
Shares held under employee benefit trust
% of authorised capital issued
€ 0.50 Ordinary
shares
454,695,492
-
454,695,492
227
4,580
Total
227
29%
Share Premium
The share premium reserve represents the excess of amounts received for share issues less associated issue costs over the par value of
those shares of the Company.
Under section 71 of the Companies Act 2014 as the consideration for the Ulster Bank transaction includes the issuance of ordinary shares,
Company law requires that the share premium be recognised as the difference between the nominal value of shares and the fair value of
the consideration received. This results in the shares being issued at €5.68 per share as part of the consideration transferred. The share
price on the issuance date was €1.70 per share with €0.50 being recognised in Share Capital and €1.20 being recognised in Share
Premium. As the remaining fair value of the consideration received is in excess of the fair value of the shares this excess is required by law
to be included in share premium and is, therefore, reclassified directly in equity between Retained Earnings and Share Premium. The
excess amount is the gain on bargain purchase of €362m.
Permanent TSB Group Holdings plc - Annual Report 2022
223
Notes to the Consolidated Financial Statements
(continued)
35. Share capital, reserves and other equity instruments (continued)
Other Reserves
Revaluation reserve (Non-distributable)
The revaluation reserve is a non-distributable reserve comprising unrealised gains or losses, net of tax, on the revaluation of owner
occupied properties.
Fair value reserve (Non-distributable)
The fair value reserve comprises:
•
•
the cumulative net change in the fair value of equity securities measured at FVOCI; and
the cumulative net change in the fair value of debt securities measured at FVOCI until the assets are derecognised or reclassified. This
amount is increased by the amount of loss allowance
Other capital reserves (Non-distributable)
Other capital reserves includes €1,087m capital issued by the Company net of €7m capital redemption reserve from the repurchase and
cancellation of shares and €224m incurred in the cancellation of the share capital and share premium of PTSB on the incorporation of the
Company.
Retained earnings
Retained earnings include distributable and non-distributable earnings. This reserve represents the retained earnings of the holding
company and subsidiaries after consolidation adjustments.
€10m (2021: €21m) coupon interest on the AT1 securities was paid from this reserve during 2022.
Other equity instruments - Non-distributable
Additional Tier 1 Securities
As at 1 January
Issued during the period
Additional Tier 1 Securities - net of the transaction costs
Redemption during the period
Additional Tier 1 Securities (issued 2015)
Additional Tier 1 securities
31 December
2022
31 December
2021
€m
123
245
-
368
€m
245
-
(122)
123
On 26 October 2022, PTSBGH issued additional €250m AT1 Fixed Rate Reset Perpetual Temporary Write Down Securities. The
transaction costs incurred were €5m. The first reset date for the fixed rate is 26 April 2028.
The AT1 securities are perpetual and redeemable financial instruments with a semi-annual coupon of 13.25% paid in arrears on 26 April
and 26 October of each year, commencing on 26 April 2023. On the first reset date on 26 April 2028, in the event the securities are not
redeemed, interest will be reset to Euro 5 year Mid Swap rate plus a margin of 10.546% (converted from an annual to a semi-annual rate).
The Company may elect at its full discretion at any time to cancel permanently (in whole or in part) the interest amount otherwise
scheduled to be paid on an interest payment date.
On 25 November 2020, PTSBGH issued €125m nominal value of AT1 Perpetual Temporary Write Down Securities as part of capital raise.
The transaction costs incurred were €2m. The first reset date for the fixed rate is 25 May 2026.
The AT1 securities are perpetual and redeemable financial instruments with a semi-annual coupon of 7.875% paid in arrears on 25 May
and 25 November. On the first reset date on 25 May 2026, in the event the securities are not redeemed, interest will be reset to Euro 5 year
Mid Swap rate plus a margin of 8.468% (converted from an annual to a semi-annual rate). The Company may elect at its full discretion at
any time to cancel permanently (in whole or in part) the interest amount otherwise scheduled to be paid on an interest payment date.
224
Permanent TSB Group Holdings plc - Annual Report 2022
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35. Share capital, reserves and other equity instruments (continued)
The Company may use such cancelled payments without restriction, including to make distributions or any other payments to the holders
of its shares or any other securities issued by the Company. Any cancellation of interest payments will be permanent and on a non-
cumulative basis and such cancellation will not give rise to or impose any restriction on the Company.
Although the AT1 securities are perpetual, the Company may, in its sole discretion, redeem the AT1 securities in full on any day falling in
the period commencing 25 November 2025 and the first reset date above and on every interest payment date thereafter (subject to the
approval of the Supervisory Authority) at the prevailing principal amount together with accrued but unpaid interest. In addition, the
securities are redeemable at the option of the Company for certain regulatory or tax reasons, subject to regulatory approval.
The securities, which do not carry voting rights, rank pari passu with holders of other tier 1 instruments (excluding the Company’s ordinary
shares). They rank ahead of the holders of ordinary share capital of the Company but junior to the claims of senior creditors and to Tier 2
capital of the Company.
Under the EU (Bank Recovery and Resolution) Regulations 2015, these securities are loss absorbing at the point of non-viability.
On the occurrence of a trigger event, at any time, any accrued and unpaid interest up to (but excluding) the write down date shall be
automatically and irrevocably cancelled, and the then Prevailing Principal Amount of each Security shall be automatically and irrevocably
reduced by the write down amount. This will occur if the CET1 Capital Ratio of PTSB or the Group at any time falls below 7%. Subsequent
to any write-down event the Company may, at its sole discretion, write-up some or all of the written-down principal amount of the AT1
instrument provided regulatory capital requirements and certain conditions are met.
36. Analysis of other comprehensive income
The analysis of other comprehensive income below provides additional analysis to the information provided in the primary statements and
should be read in conjunction with the consolidated statement of changes in equity.
31 December 2022
Other comprehensive income/(expense) (net of tax)
Revaluation of property
Fair value reserve (equity instruments):
Change in fair value of equity instruments
Fair value reserve (debt instruments):
Change in fair value of debt instruments
Total other comprehensive income/(expense), net of tax
31 December 2021
Other comprehensive income (net of tax)
Revaluation of property
Fair value reserve (equity instruments):
Change in fair value of equity instruments
Fair value reserve (debt instruments):
Change in fair value of debt instruments
Total other comprehensive income, net of tax
Revaluation
reserve
€m
(6)
-
-
(6)
Fair value
reserve
€m
-
2
-
2
Revaluation
reserve
€m
Fair value
reserve
€m
2
-
-
2
-
2
-
2
Total
€m
(6)
2
-
(4)
Total
€m
2
2
-
4
Permanent TSB Group Holdings plc - Annual Report 2022
225
Notes to the Consolidated Financial Statements
(continued)
37. Measurement basis and fair values of financial instruments
The Group’s accounting policy on valuation of financial instruments is described in note 1. The table below sets out an overview of financial
instruments held by the Group and their fair values.
(a) Measurement basis and fair value of financial instruments
31 December 2022
Financial assets
Cash at bank
Items in course of collection
Loans and advances to banks
Derivative financial instruments
Debt securities
Equity securities
Loans and advances to
customers
Financial liabilities
Deposits by banks
Customer accounts
Derivative financial instruments
Debt securities in issue
Subordinated liabilities
Other financial liabilities
31 December 2021
Financial assets*
Cash at bank
Items in course of collection
Loans and advances to banks
Derivative financial instruments
Debt securities
Equity securities
Loans and advances to
customers
Financial liabilities*
Deposits by banks
Customer accounts
Derivative financial instruments
Debt securities in issue
Subordinated liabilities
Other financial liabilities
Held at
amortised cost
Note
At fair value
through OCI
At fair value
through profit
or loss
Total carrying
value
€m
€m
€m
€m
Fair value
€m
14
14
15
16
19
20
22
28
29
16
30
33
31
58
40
2,123
-
3,177
-
19,593
614
21,730
-
658
252
143
-
-
-
-
-
30
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
-
-
38
58
40
2,123
-
3,177
30
58
40
2,123
-
2,929
30
19,593
20,059
614
21,730
13
658
252
181
614
21,726
13
634
204
181
Held at
amortised cost
Note
At fair value
through OCI
At fair value
through profit
or loss
Total carrying
value
€m
€m
€m
€m
Fair value
€m
14
14
15
16
19
20
22
28
29
16
30
33
31
57
20
4,174
-
2,494
-
14,256
347
19,089
-
524
252
170
-
-
-
-
-
26
-
-
-
-
-
-
-
-
-
-
1
-
-
-
-
-
-
-
-
-
57
20
4,174
1
2,494
26
57
20
4,174
1
2,526
26
14,256
14,050
347
19,089
-
524
252
170
347
19,092
-
530
256
170
* In addition the Group had an other asset of €310m and an other liability of €48m in respect of the sale of the sale of the Glenbeigh III, both of which were settled in early 2022.
The following table sets out the fair value of financial instruments that the Group holds at 31 December 2022. It categorises these financial
instruments into the relevant level on the fair value hierarchy.
The fair values of financial instruments are measured according to the following fair value hierarchy:
• Level 1 – financial assets and liabilities measured using quoted market prices (unadjusted).
• Level 2 – financial assets and liabilities measured using valuation techniques which use observable inputs including quoted prices of
financial instruments themselves or quoted prices of similar instruments – in either active or inactive markets.
• Level 3 – financial assets and liabilities measured using valuation techniques which use unobservable market data inputs.
226
Permanent TSB Group Holdings plc - Annual Report 2022
37. Measurement basis and fair values of financial instruments (continued)
Basis and fair values of financial instruments
Level 1
€m
Level 2
€m
Level 3
€m
31 December 2022
Financial assets
Cash at bank
Items in course of collection
Loans and advances to banks
Derivative financial instruments
Debt securities
Equity securities
Loans and advances to
customers
Financial liabilities
Deposits by banks
Customer accounts
Derivative financial instruments
Debt securities in issue
Subordinated liabilities
Other financial liabilities
31 December 2021
Financial assets
Cash at bank
Items in course of collection
Loans and advances to banks
Derivative financial instruments
Debt securities
Equity securities
Loans and advances to
customers
Financial liabilities
Deposits by banks
Customer accounts
Derivative financial instruments
Debt securities in issue
Subordinated liabilities
Other financial liabilities
Total carrying
value
Note
€m
58
40
2,123
-
3,177
30
19,593
614
21,730
13
658
252
181
14
14
15
16
19
20
22
28
29
16
30
33
31
Note
Total carrying
value
€m
57
20
4,174
1
2,494
26
14,256
347
19,089
-
524
252
170
14
14
15
16
19
20
22
28
29
16
30
33
31
58
-
-
-
2,929
26
-
-
-
-
634
204
-
-
40
2,123
-
-
-
-
614
21,726
1
-
-
181
57
-
-
-
2,526
17
-
-
-
-
357
256
-
-
20
4,174
1
-
-
-
347
19,092
-
173
-
170
Level 1
€m
Level 2
€m
Level 3
€m
20,059
20,059
l
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n
a
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F
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t
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s
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m
e
t
a
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S
Total fair
value
€m
58
40
2,123
-
2,929
30
n
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i
t
a
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I
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n
e
G
614
21,726
13
634
204
181
Total fair
value
€m
57
20
4,174
1
2,526
26
-
-
-
-
-
4
-
-
12
-
-
-
-
-
-
-
-
9
14,050
14,050
-
-
-
-
-
-
347
19,092
-
530
256
170
Permanent TSB Group Holdings plc - Annual Report 2022
227
Notes to the Consolidated Financial Statements
(continued)
37. Measurement basis and fair values of financial instruments (continued)
(b) Fair value measurement principles
The Group’s accounting policy on valuation of financial instruments is described in note 1 and note 2 and contains details on the critical
accounting estimates and judgements made by management in relation to the fair value measurement of financial instruments. The fair
value of a financial instrument is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly
transaction between market participants at the measurement date.
Where possible, the Group calculates fair value using observable market prices in an active market. Where market prices are not available,
fair values are determined using valuation techniques. These techniques are subjective in nature and may involve assumptions which are
based upon management’s view of market conditions at year end, which may not necessarily be indicative of any subsequent fair value.
Any minor changes in the assumptions used could have a significant impact on the resulting estimated fair values and, as a result, it may
be difficult for the users to make a reasonable comparison of the fair value information disclosed in this note, against that disclosed by
other financial institutions or to evaluate the Group’s financial position and, therefore, are advised to exercise caution in interpreting these
fair values. Also the fair values disclosed above do not represent, nor should it be interpreted to represent, the underlying value of the
Group as a going concern at the reporting date.
Financial assets and financial liabilities not subsequently measured at fair value
Other than the HTC&S debt securities, derivative financial instruments and equity securities, all other financial assets and liabilities are not
measured at fair value at the reporting date. A description of the methods and assumptions used to calculate fair values of these assets
and liabilities is set out below.
Cash at bank
The fair value of these financial instruments is equal to their carrying value due to these instruments being repayable on demand and
short-term in nature in an active market.
Items in course of collection
The fair value of these financial instruments is equal to their carrying value due to these instruments being repayable on demand and
short-term in nature.
Loans and advances to banks
For the purposes of fair value valuation, loans and advances to banks have been treated as cash and cash equivalents. These loans and
advances are repayable on demand and short-term in nature; hence, the fair value of each financial instrument is equal to their carrying
value.
Loans and advances to customers
Loans and advances to customers are carried net of impairments. The Group uses a discounted cash flow valuation model to estimate the
fair value for the ROI residential and commercial mortgages. Cash flows are discounted using the current weighted average interest rate
based on the specific portfolio. The fair value calculation also takes into account loan impairment provisions at the balance sheet date. The
carrying value of the consumer finance portfolio is considered equal to its fair value due to its short duration.
Debt securities (HTC securities)
Debt securities at 31 December 2022 are €3,177m (31 December 2021 €2,494m) and consist of HTC securities. HTC securities are derived
from observable inputs through independent pricing sources such as Bloomberg. A weighted average method is used to apply the prices to
the Group’s retained holding in the securitisation.
Deposits by banks/customer accounts
The estimated fair value of deposit liabilities and current accounts with no stated maturity which are repayable on demand (including non-
interest bearing deposits), approximates to their book value. The estimated fair value of fixed-interest bearing deposits and other
borrowings is based on discounted cash flows using interest rates for new deposits with similar remaining maturities.
Debt securities in issue/subordinated liabilities
The fair values of debt securities in issue/subordinated liabilities are estimated using market prices of instruments that are substantially
the same as those issued by the Group. Where a readily available market price is unavailable in relation to the instrument, an estimated
price is calculated using observable market data for similar instruments. If observable market data is not available, an appropriate credit
spread linked to similar instruments, is used within the valuation technique.
228
Permanent TSB Group Holdings plc - Annual Report 2022
37. Measurement basis and fair values of financial instruments (continued)
Financial assets and financial liabilities subsequently measured at fair value
On initial recognition, all financial instruments are measured at fair value. Following this, the Group measures HTC&S financial assets at
fair value through other comprehensive income. Derivative financial instruments are held for trading and fair valued through the income
statement.
Derivative financial instruments
The fair values of derivatives are determined using valuation techniques such as discounted cash flow and pricing models which are
commonly used by market participants. These valuations are provided by third party brokers and the models used incorporate observable
market inputs such as current interest rate, time to maturity, forward foreign exchange rates, yield curves and volatility measures.
Equity securities
PTSB Group holds Series A and Series B preferred stock in Visa Inc. at 31 December 2022. The Series A preferred stock was acquired
during 2020 upon the conversion of Series B preferred stock by Visa Inc. These were fair valued at €30m at 31 December 2022 (31
December 2021: €26m) and are recognised in the statement of financial position at FVOCI.
The fair values of the Series A preferred stock in Visa Inc. is classified as Level 1 and the fair value of the Series B preferred stock is
classified as Level 3, as the valuation of these preferred stock includes inputs that are based on unobservable data.
Fair value measurements recognised in the Statement of financial position
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F
i
31 December 2022
Financial assets measured at fair value
Derivative financial instrument
Equity instruments
Financial liabilities measured at fair value
Derivative financial instrument
31 December 2021
Financial assets measured at fair value
Derivative financial instrument
Equity instruments
Financial liabilities measured at fair value
Derivative financial instrument
Notes
16
20
16
Notes
16
20
16
Reconciliation of level 3 fair value measurements of financial assets
Equity Instruments
As at 1 January
Revaluation movement in OCI – fair value reserve (equity instruments)
Conversion of Series B preferred stock to Series A preferred stock
As at 31 December
Level 1
€m
Level 2
€m
Level 3
€m
-
26
-
-
-
1
-
4
12
Level 1
€m
Level 2
€m
Level 3
€m
-
17
-
-
1
-
-
-
-
9
-
-
2022
€m
9
-
(5)
4
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o
i
t
a
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f
n
I
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a
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e
n
e
G
Total
€m
-
30
13
Total
€m
1
26
-
-
2021
€m
8
1
-
9
Permanent TSB Group Holdings plc - Annual Report 2022
229
Notes to the Consolidated Financial Statements
(continued)
37. Measurement basis and fair values of financial instruments (continued)
There were no transfers between level 1, level 2 or level 3 of the fair value hierarchy during 2022 or 2021 for financial assets.
Level 3 fair value measurements of financial liabilities
There were no transfers between level 1, level 2 or level 3 of the fair value hierarchy during 2022 or 2021 for financial liabilities. The level 3
of €12m relates to business combination forwards. The fair value of the forward derivative at the acquisition date was a liability of €16m.
This is calculated as the difference between the fair value of the consideration to be paid and the fair value of the assets to be acquired.
See notes 2 and 3 for further detail.
Level 3 sensitivity analysis
The table below sets out information about significant unobservable inputs used in measuring financial instruments categorized as Level 3
in the fair value hierarchy.
Financial instruments
31 December 2022
Visa Inc. Series B Preferred Stock
Valuation
technique
Significant
unobservable
inputs
Range of
estimates for
unobservable
inputs
Ranges of
estimates
changes in the
fair value
Fair value
€m
Quoted market
price
(Discounted)*
Final share
conversion rate
0 - 90%
4
0 - 90%
* Discount has been applied for illiquidity and the conversion rate variability of the Visa Inc. Series B Preferred stock.
31 December 2021
Visa Inc. Series B Preferred Stock
Valuation
technique
Quoted market
price
(Discounted)*
Significant
unobservable
inputs
Final share
conversion rate
Range of
estimates for
unobservable
inputs
Ranges of
estimates
changes in the
fair value
Fair value
€m
0 - 90%
9
0 - 90%
*Discount has been applied for illiquidity and the conversion rate variability of the Visa Inc. Series B Preferred stock.
Significant unobservable inputs
Visa Inc. Series A and Series B preferred stock
The Visa Inc. Series A preferred stock held by PTSB was acquired during 2020 upon the partial conversion of Series B preferred stock by
Visa Inc. These Series A and B preferred stock were fair valued at €26m and €4m respectively at 31 December 2022 (31 December 2021:
€17m and €9m) and are recognised in the statement of financial position at FVOCI.
Valuation Methodology: The Visa Inc. Class A Common stock price and conversion ratios were applied to the PTSB shareholding of Visa
Inc. Series A and Series B preferred shares at 31 December 2022 and 31 December 2021. Future conversions are calculated using
discounted cash follows. The stock was revalued at the year-end exchange rate.
Unobservable input: The unobservable inputs are the discount factor used to discount the future conversions of Series B preferred stock.
The Visa Inc. Series A and Series B preferred stock is denominated in US dollars and is exposed to FX risk.
230
Permanent TSB Group Holdings plc - Annual Report 2022
37. Measurement basis and fair values of financial instruments (continued)
Business combination forwards
There was a transfer in to Level 3 per the fair value hierarchy of €12m. As noted in note 3 the business combination became binding on 7
November 2022.
Valuation Methodology: The fair value of the forward derivative at 31 December 2022 was a liability of €12m. This is calculated as the
difference between the fair value of the consideration to be paid and the fair value of the assets to be acquired.
Unobservable input: The unobservable inputs are the prepayment rate, redemption rate, transition rate (from fixed to variable rates and
vice versa), probability of default (PD) and loss given default assumptions, servicing cost, risk weights based on the asset characteristics
and a discount rate based on cost of funding, capital and targeted capital ratio. Taking account of the various uncertainties, Management
estimate the range of changes in fair value on the receive leg (loans acquired) to be 95% to 105%, with no material change expected on
the pay leg (the consideration).
38. Financial risk management
Maximum exposure to credit risk before collateral held or other credit enhancements
The following table outlines the maximum exposure to credit risk before collateral held or other credit enhancements in respect of the
Group’s financial assets as at the statement of financial position date.
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F
i
Cash at bank
Items in course of collection
Loans and advances to banks (iii)
Derivative financial instruments (ii)
Debt securities (i)
Loans and advances to customers (iv)
Commitments and contingencies
Notes
31 December
2022
31 December
2021
14
14
15
16
19
22
43
€m
58
40
2,123
-
3,177
19,593
24,991
1,342
26,333
n
o
i
t
a
m
r
o
f
n
I
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a
r
e
n
e
G
€m
57
20
4,174
1
2,494
14,256
21,002
1,181
22,183
The following tables outline the Group’s exposure to credit risk by asset class
(i) Debt securities
The Group is exposed to the credit risk on third parties where the Group holds debt securities (primarily sovereign debt). These exposures
are subject to the limitations contained within Board approved policies, with sovereign debt restricted to those countries that have an
External Credit Assessment Institution (ECAI) rating of investment grade.
The following table gives an indication of the level of the credit worthiness of the Group’s debt securities and is based on the Group’s
internal rating policy which was approved by the CBI. The inputs to the ratings used in the table below are those prescribed by Moody’s
Investor Services Limited and Standard and Poor’s for the EU.
Rating
Aaa
AA+
Aa2
A1
A2
Baa1
Baa2
Baa3
Total
31 December
2022
31 December
2021
€m
49
110
250
1,734
-
497
456
81
3,177
€m
60
-
-
-
1,463
506
465
-
2,494
Permanent TSB Group Holdings plc - Annual Report 2022
231
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
The following table discloses, by country, the Group’s exposure to sovereign debt and corporate debt as at:
Country
Ireland
Portugal
Spain
France
Italy
EU
Total
31 December
2022
31 December
2021
€m
€m
1,783
456
497
250
81
110
1,523
465
506
-
-
-
3,177
2,494
(ii) Derivative financial instruments
The Group has executed standard ISDA agreements with all of its counterparties. The Group has also executed CSAs with all of its
counterparties in respect of the majority of derivative instruments to mitigate its credit risk. As part of these agreements, the Group
exchanges collateral in line with movements in the market values of derivative positions daily. FX forward derivatives are settled gross. The
cumulative positive market value of derivative assets at 31 December 2022 was €nil (31 December 2021: €1m). The Group manages its
collateral derivative positions with counterparties on a net basis. The uncollaterised derivative positions are all held with investment grade
counterparties.
(iii) Loans and advances to banks
The Group has a policy to ensure that, where possible, loans and advances to banks are held with investment grade counterparties with
any exceptions subject to prior approval by the BRCC. The following table gives an indication of the level of creditworthiness of the Group’s
loans and advances to banks and is based on the ratings prescribed by Moody’s Investor Services Limited and Standard and Poor’s for the
CBI.
Rating
AAA
Aa2
Aa3
A1
A2
Ba1
Total
31 December
2022
31 December
2021
€m
€m
1,620
199
286
10
-
8
3,709
199
258
2
6
-
2,123
4,174
232
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38. Financial risk management (continued)
The following sections detail additional disclosures on asset quality.
(iv) Loans and advances to customers
Gross customer loans and advances
The tables below outline total loans and advances to customers for the Group analysed by home loan, buy-to-let, commercial and
consumer finance.
Measured at amortised cost
Residential mortgages:
Home loan
Buy-to-let
Total residential mortgages
Commercial
Consumer finance
Total measured at amortised cost
Analysed by ECL staging:
Stage 1
Stage 2
Stage 3
POCI
Total measured at amortised cost
Of which at the reporting date
Neither past due nor Stage 3
Past due but not Stage 3
Stage 3
Total measured at amortised cost
Of which are reported as non-performing loans
Deferred fees, discounts and fair value adjustments
31 December
2022
31 December
2021
€m
€m
18,340
824
19,164
239
401
19,804
17,455
1,699
649
1
19,804
12,568
1,623
14,191
196
358
14,745
11,689
2,239
815
2
14,745
19,118
13,885
36
650
43
817
19,804
14,745
650
310
817
115
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233
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
31 December 2022
Asset quality*
Stage 1
Excellent
Satisfactory
Fair
Standardised
Stage 2
Excellent
Satisfactory
Fair
Standardised
Stage 3
Defaulted
Total measured at amortised cost
31 December 2021
Asset quality*
Stage 1
Excellent
Satisfactory
Fair
Standardised
Stage 2
Excellent
Satisfactory
Fair
Standardised
Stage 3
Defaulted
Total measured at amortised cost
Home loans
Buy-to-let
€m
12,826
4,064
22
-
16,912
79
296
711
-
1,086
342
18,340
€m
65
141
-
-
206
44
107
197
-
348
270
824
Home loans
Buy-to-let
€m
7,096
3,807
20
-
10,923
146
344
735
-
1,225
420
12,568
€m
184
289
1
-
474
209
334
267
-
810
339
1,623
Total
residential
mortgages
€m
12,891
4,205
22
-
17,118
123
403
908
-
1,434
612
19,164
Total
residential
mortgages
€m
7,280
4,096
21
-
11,397
355
678
1,002
-
2,035
759
14,191
Commercial
Consumer
€m
11
17
-
-
28
-
27
161
-
188
23
239
€m
143
61
21
84
309
5
21
26
25
77
15
401
Commercial
Consumer
€m
1
10
-
-
11
7
58
76
-
141
44
196
€m
160
65
6
50
281
2
17
29
15
63
14
358
* The information in the shaded box has not been subject to audit by the Group’s independent auditor.
Total
€m
13,045
4,283
43
84
17,455
128
451
1,095
25
1,699
650
19,804
Total
€m
7,441
4,171
27
50
11,689
364
753
1,107
15
2,239
817
14,745
234
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38. Financial risk management (continued)
The following table provides an aged analysis of customer loans and advances which are past due but not Stage 3.
31 December 2022
0-30 days
31-60 days
61-90 days
Total past due not Stage 3
Fair value of collateral held
Fair value of collateral held
0-30 days
31-60 days
61-90 days
Total past due not Stage 3
31 December 2021
0-30 days
31-60 days
61-90 days
Total past due not Stage 3
Fair value of collateral held
Fair value of collateral held
0-30 days
31-60 days
61-90 days
Total past due not Stage 3
Home loans
Buy-to-let
Commercial
€m
16
4
5
25
25
€m
€m
2
1
-
3
3
-
-
-
-
-
Home loans
Buy-to-let
Commercial
€m
16
4
5
25
€m
€m
2
1
-
3
-
-
-
-
Home loans
Buy-to-let
Commercial
€m
18
4
2
24
24
€m
€m
3
1
2
6
6
-
-
-
-
-
Home loans
Buy-to-let
Commercial
€m
18
4
2
24
€m
€m
3
1
2
6
-
-
-
-
Total
€m
18
5
5
28
28
Total
€m
18
5
5
28
Total
€m
21
5
4
30
30
Total
€m
21
5
4
30
Collateral held against residential mortgages is principally comprised of residential properties; their fair value has been estimated based
upon the last actual valuation, adjusted to take into account subsequent movement in house prices and is capped at the lower of the loan
balance or the valuation amount.
Non-performing loans
Non-performing loans (NPLs) are loans which are credit impaired or loans which are classified as defaulted in accordance with the
Group’s definition of default. The Group’s definition of default considers objective indicators of default including the 90 days past due
criterion, evidence of exercise of concessions or modifications to terms and conditions is designed to be consistent with European
Banking Authority (EBA) guidance on the definition of forbearance.
Foreclosed assets are assets held on the balance sheet which are obtained by taking possession of collateral or by calling on similar credit
enhancements.
Permanent TSB Group Holdings plc - Annual Report 2022
235
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
Non-performing assets are defined as NPLs plus foreclosed assets.
31 December 2022
Stage 3
Home loans
Buy-to-let
Commercial
NPL is < 90 days
NPL is > 90 days and < 1 year past due
NPL is 1-2 years past due
NPL is 2-5 years past due
NPL is > 5 years past due
POCI
Non-performing loans
Foreclosed assets
Non-performing assets
NPLs as % of gross loans
31 December 2021
NPL is < 90 days
NPL is > 90 days and < 1 year past due
NPL is 1-2 years past due
NPL is 2-5 years past due
NPL is > 5 years past due
POCI
Non-performing loans
Foreclosed assets
Non-performing assets
NPLs as % of gross loans
32.8%
9.6%
3.7%
3.3%
Stage 3
Home loans
Buy-to-let
Commercial
€m
118
15
80
28
29
-
270
15
285
€m
17
-
-
-
6
-
23
-
23
€m
177
89
25
10
38
-
339
24
363
€m
40
1
-
-
3
-
44
-
44
Consumer
finance
€m
2
3
2
2
5
1
15
-
15
Total
€m
312
49
113
81
94
1
650
18
668
Consumer
finance
€m
1
6
2
1
2
2
14
-
14
Total
€m
469
128
66
47
105
2
817
28
845
5.5%
€m
175
31
31
51
54
-
342
3
345
1.9%
€m
251
32
39
36
62
-
420
4
424
3.3%
20.9%
22.5%
3.9%
Non-performing loans as a percentage of total loans and advances was 3.3% at 31 December 2022, a reduction from 5.5% at 31 December
2021.
Total portfolio loss allowance: statement of financial position
The tables below outline the ECL loss allowance total at 31 December 2022 in respect of total customer loans and advances.
The impairment charge in respect of the total loans and advances for year ended 31 December 2022 is €7m, compared to a write-back of
€1m for the year ended 31 December 2021.
Loss allowance - statement of financial position
Stage 1
Stage 2
Stage 3
Total loss allowance
31 December
2022
31 December
2021
€m
136
163
222
521
€m
61
238
305
604
236
Permanent TSB Group Holdings plc - Annual Report 2022
38. Financial risk management (continued)
Provision coverage ratio*
Stage 1
Stage 2
Stage 3
Total provisions/total loans
31 December
2022
31 December
2021
%
%
0.8%
9.6%
34.1%
2.6%
0.5%
10.6%
37.3%
4.1%
*Provision coverage ratio is calculated as loss allowance/impairment provision as a percentage of gross loan balance.
Origination profile
Loan origination profile of the residential mortgage loan portfolio before provision for impairment:
The table below illustrates that €2bn or 11% of the residential mortgage portfolio originated before 2006. Between 2006 and 2008
origination was €5bn or 24% of the residential mortgages. The residual of 65% of the residential mortgages were originated between
2009 and 2022.
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1999 and before
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Total
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Residential mortgages portfolio
Stage 3 residential mortgages
portfolio
Number
Balance
Number
1,786
1,483
1,938
2,801
5,360
7,729
11,134
14,396
12,439
7,912
2,301
936
819
1,190
1,673
2,960
4,058
4,664
5,804
7,607
9,633
7,940
8,871
9,409
€m
30
40
66
127
255
514
1,006
1,796
1,730
1,006
213
70
69
110
163
316
471
639
899
1,345
1,863
1,735
2,164
2,537
113
57
79
99
166
220
397
723
740
408
65
14
5
3
4
13
29
23
24
52
37
14
8
4
Balance
€m
4
3
4
6
14
23
57
169
203
90
7
1
1
-
-
3
1
4
4
8
7
1
1
1
134,843
19,164
3,297
612
Permanent TSB Group Holdings plc - Annual Report 2022
237
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
31 December 2021
1998 and before
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Total
Residential mortgages portfolio
Stage 3 residential mortgages
portfolio
Number
Balance
Number
967
754
1,204
1,561
3,485
5,145
7,697
11,173
15,474
13,532
8,712
2,135
889
550
315
716
1,497
1,648
1,811
3,202
4,974
6,282
5,153
7,099
105,975
€m
13
18
38
61
132
273
574
1,105
2,125
2,005
1,207
193
67
44
21
67
156
179
227
487
924
1,306
1,184
1,785
14,191
75
53
73
103
120
189
259
487
881
842
513
79
23
8
5
8
14
39
25
31
48
40
21
18
3,954
Balance
€m
2
2
4
6
6
18
32
76
215
239
111
8
3
1
-
1
3
3
4
5
10
8
1
1
759
Loan-to-value profile
Loan-to-value (LTV) of mortgage lending (index linked):
The LTV ratio is calculated at a property level and is the average of indexed property values in proportion to the outstanding loan balance.
LTV is a key input to the impairment provisioning process. The tables below outline the composition of this ratio for the residential loan
portfolio.
Actual and average LTVs across principal mortgage portfolios:
The tables below outline the weighted average LTVs for the total residential mortgage portfolios analysed across home loan and buy-to-let
facilities by value. The weighted average LTV on the existing residential mortgage portfolios is 54% at 31 December 2022 compared to
58% at 31 December 2021.
The Group’s residential mortgage lending LTVs at December 2022 reflect updated valuations obtained on high-exposure NPLs (largely
impacting on high-exposure buy-to-let properties).
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38. Financial risk management (continued)
31 December 2022
Home loans
Buy-to-let
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Weighted average LTV:
Stock of existing residential mortgages
New residential mortgages
Acquired residential mortgages
Stage 3 mortgages
31 December 2021
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Weighted average LTV:
Stock of residential mortgages
New residential mortgages
Stage 3 mortgages
%
44%
40%
14%
1%
99%
1%
-
-
-
-
-
-
-
-
1%
100%
53%
68%
47%
74%
%
32%
18%
24%
8%
82%
5%
4%
3%
1%
2%
1%
-
-
2%
18%
100%
76%
58%
39%
100%
Home loans
Buy-to-let
%
38%
34%
25%
1%
98%
1%
-
-
1%
-
-
-
-
-
2%
100%
56%
69%
78%
%
32%
16%
21%
11%
80%
6%
4%
3%
2%
1%
1%
1%
-
2%
20%
100%
74%
54%
105%
Total
%
44%
39%
14%
1%
98%
1%
-
-
-
-
-
-
-
1%
2%
100%
54%
68%
47%
85%
Total
%
37%
32%
25%
2%
96%
1%
1%
1%
1%
-
-
-
-
-
4%
100%
58%
69%
90%
Permanent TSB Group Holdings plc - Annual Report 2022
239
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
Analysis by LTV of the Group’s residential mortgage lending which is neither past due nor Stage 3:
The tables below illustrates that 100% of residential home loan mortgages (31 December 2021: 99%) and 94% of residential buy-to-let
mortgages (31 December 2021: 87%) that are neither past due nor Stage 3 are in positive equity as at 31 December 2022.
31 December 2022
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
31 December 2021
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Home loans
Buy-to-let
%
45%
41%
14%
-
100%
-
-
-
-
-
-
-
-
-
-
%
44%
23%
23%
4%
94%
2%
1%
1%
-
1%
-
-
-
1%
6%
Total
%
45%
40%
14%
1%
100%
-
-
-
-
-
-
-
-
-
-
100%
100%
100%
Home loans
Buy-to-let
%
39%
34%
25%
1%
99%
1%
-
-
-
-
-
-
-
-
1%
100%
%
39%
19%
20%
9%
87%
5%
3%
2%
1%
1%
-
-
-
1%
13%
100%
Total
%
39%
34%
25%
2%
99%
1%
-
-
-
-
-
-
-
-
1%
100%
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38. Financial risk management (continued)
Analysis by LTV of the Group’s residential mortgage lending which is classified as Stage 3:
The tables below illustrates that 79% of residential home loan mortgages (31 December 2021: 75%) and 55% of residential buy-to-let
mortgages (31 December 2021: 53%) that are classified as Stage 3 are in positive equity as at 31 December 2022
31 December 2022
Home loans
Buy-to-let
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Stage 3
%
33%
22%
19%
5%
79%
3%
5%
4%
2%
1%
1%
1%
4%
21%
100%
€m
342
-
%
7%
8%
27%
13%
55%
12%
10%
9%
3%
3%
2%
1%
1%
4%
45%
100%
€m
270
31 December 2021
Home loans
Buy-to-let
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Stage 3
%
29%
19%
20%
7%
75%
6%
4%
4%
3%
2%
1%
1%
-
4%
25%
100%
€m
420
%
7%
8%
21%
17%
53%
12%
6%
8%
6%
4%
2%
3%
1%
5%
47%
100%
€m
339
Total
%
22%
16%
22%
8%
68%
7%
7%
6%
2%
2%
2%
1%
1%
4%
32%
100%
€m
612
Total
%
19%
14%
20%
11%
64%
9%
5%
6%
4%
3%
1%
2%
1%
5%
36%
100%
€m
759
(v) Group portfolios: Collateral in possession
Collateral in possession occurs where the obligor either (i) voluntarily surrenders the property or (ii) the Group takes legal ownership due to
the non-repayment of the loan facility. The following tables outline the main movements in this category during the year.
Permanent TSB Group Holdings plc - Annual Report 2022
241
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
Stock of collateral in possession
Residential collateral in possession
Home loans
Buy-to-let
Total
31 December 2022
31 December 2021
Balance
outstanding at
transfer of
ownership
Number
Balance
outstanding at
transfer of
ownership
Number
14
105
119
€m
7
27
34
27
165
192
€m
10
42
52
Collateral in possession assets are sold as soon as practicable. These assets which total €18m as at 31 December 2022 (31 December
2021: €28m) are included in assets held for sale (see note 18 for further details).
During the year the ownership of 16 properties were transferred to the Group.
The details of the transfers are provided in the table below:
Home loans
Buy-to-let
Total
During the year 89 properties were disposed. The details of the disposals are provided in the tables below:
Number
-
16
16
Number
13
76
89
Home loans
Buy-to-let
Total
31 December 2022
Collateral in possession
Home loans
Buy-to-let
Year ended 31 December 2022
Balance
outstanding at
transfer of
ownership
Number of
disposals
Gross sales
proceeds
Costs to sell
Pre
provisioning
loss on sale*
€m
€m
€m
€m
13
76
89
3
18
21
2
13
15
-
1
1
1
6
7
* Calculated as gross sales proceeds less balance outstanding at transfer of ownership less costs to sell. These losses are provided for as part of the impairment provisioning
process.
31 December 2021
Collateral in possession
Home loans
Buy-to-let
Year ended 31 December 2021
Balance
outstanding at
transfer of
ownership
Number of
disposals
Gross sales
proceeds
Costs to sell
Pre
provisioning
loss on sale*
€m
€m
€m
€m
23
114
137
7
25
32
5
16
21
-
1
1
2
10
12
* Calculated as gross sales proceeds less balance outstanding at transfer of ownership less costs to sell. These losses are provided for as part of the impairment provisioning
process.
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38. Financial risk management (continued)
(vi) Additional disclosures on forborne loans
The Group operates a number of mechanisms which are designed to assist borrowers experiencing credit and loan repayment difficulties,
which have been developed in accordance with the current Code of Conduct on Mortgages Arrears (CCMA).
The tables below set out the asset quality and volume of loans for which the Group has entered formal temporary and permanent
forbearance arrangements with customers for the years ended 31 December 2022 and 2021. The number and balances of loans in
forbearance arrangements for residential home loan mortgages and buy-to-let residential mortgages are analysed below.
(a) Asset quality
The method of splitting the forborne loans and advances to customers over the different asset quality categories:
• Neither past due nor Stage 3
• Past due but not Stage 3
• Stage 3
31 December 2022
*Stage 2
Excellent
Satisfactory
Fair
Standardised
Stage 3
Defaulted
Total measured at amortised costs
Home loans
Buy-to-let
Total
residential
mortgages
€m
5
33
92
-
130
228
358
€m
-
5
26
-
31
68
99
€m
5
38
118
-
161
296
457
Commercial
€m
Total
€m
-
1
1
-
2
6
8
n
o
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t
a
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5
39
119
-
163
302
465
Where a borrower has been granted a forbearance treatment, the loan is considered to have experienced a significant increase in credit
risk and is classified as Stage 2 for Expected Credit Loss assessment purposes under IFRS 9.
31 December 2021
* Stage 2
Excellent
Satisfactory
Fair
Standardised
Stage 3
Defaulted
Total measured at amortised costs
Home loans
Buy-to-let
Total
residential
Mortgages
€m
6
76
96
-
178
289
467
€m
5
37
30
-
72
94
166
€m
11
113
126
-
250
383
633
Commercial
€m
Total
€m
1
-
3
-
4
33
37
12
113
129
-
254
416
670
* The information in the shaded box has not been subject to audit by the Group’s Independent Auditor.
Permanent TSB Group Holdings plc - Annual Report 2022
243
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
(b) Weighted Average - LTV
LTV on total portfolio in forbearance
The tables below illustrates that 85% of residential home loan mortgages (31 December 2021: 84%) and 69% of residential buy-to-let
mortgages (31 December 2021: 67%) that are neither past due nor Stage 3 are in positive equity as at 31 December 2022.
31 December 2022
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Weighted average LTV:
Stock of residential mortgages
New residential mortgages
Stage 3 mortgages
31 December 2021
Less than 50%
50% to 70%
71% to 90%
91% to 100%
Subtotal
101% to 110%
111% to 120%
121% to 130%
131% to 140%
141% to 150%
151% to 160%
161% to 170%
171% to 180%
Greater than 180%
Subtotal
Total
Weighted average LTV:
Stock of residential mortgages
New residential mortgages
Stage 3 mortgages
Home loans
Buy-to-let
%
37%
27%
17%
4%
85%
3%
3%
3%
1%
1%
1%
1%
-
2%
15%
100%
66%
73%
75%
%
7%
11%
42%
9%
69%
11%
4%
4%
2%
2%
2%
1%
1%
4%
31%
100%
92%
-
97%
Home loans
Buy-to-let
%
33%
25%
20%
6%
84%
4%
3%
2%
2%
1%
1%
1%
-
2%
16%
100%
70%
47%
78%
%
7%
11%
30%
19%
67%
12%
8%
1%
4%
2%
1%
1%
1%
3%
33%
100%
95%
-
104%
Total
%
31%
24%
23%
5%
83%
4%
3%
3%
1%
1%
1%
1%
-
3%
17%
100%
72%
73%
80%
Total
%
26%
21%
23%
9%
79%
6%
4%
2%
2%
1%
1%
1%
1%
3%
21%
100%
76%
47%
84%
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38. Financial risk management (continued)
(c) Forbearance arrangements - residential mortgages
The Group operates a number of mechanisms which are designed to assist borrowers experiencing credit and loan repayment difficulties,
which have been developed in accordance with existing CCMA. These are set out in the table below.
Residential mortgages
The tables below set out the volume of loans for which the Group has entered formal temporary and permanent forbearance
arrangements with customers as at 31 December 2022 and 31 December 2021.
(i) Residential home loan mortgages:
The incidence of the main type of forbearance arrangements for owner occupied residential mortgages are analysed below:
31 December 2022
All loans
Stage 3
Number
Balances
Number
Balances
Interest only
Reduced payment (less than interest only)
Reduced payment (greater than interest only)
Payment moratorium
Arrears capitalisation
Term extension
Hybrid*
Split mortgages
Total
* Hybrid is a combination of two or more forbearance arrangements.
31 December 2021
Interest only
Reduced payment (less than interest only)
Reduced payment (greater than interest only)
Payment moratorium
Arrears capitalisation
Term extension
Hybrid*
Split mortgages
Total
* Hybrid is a combination of two or more forbearance arrangements.
21
34
1,369
32
433
428
277
153
2,747
€m
6
3
192
5
53
32
41
26
358
19
22
782
19
252
209
178
153
1,634
€m
3
2
120
3
31
17
26
26
228
All loans
Stage 3
Number
Balances
Number
Balances
61
35
1,815
64
524
483
378
164
3,524
€m
12
5
255
8
66
38
55
28
467
52
33
1,015
47
264
245
190
164
2,010
€m
8
5
157
6
36
20
29
28
289
The tables above reflect a decrease of 777 cases in the year to 31 December 2022 for the Group in the number of residential home loan
mortgages in forbearance arrangements, a decrease of €109m. The average balance of forborne loans is €0.130m at 31 December 2022
(31 December 2021: €0.133m).
Permanent TSB Group Holdings plc - Annual Report 2022
245
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
(ii) Residential buy-to-let mortgages:
The incidence of the main type of forbearance arrangements for residential buy-to-let mortgages only is analysed below:
31 December 2022
Interest only
Reduced payment (greater than interest only)
Payment moratorium
Arrears capitalisation
Term extension
Hybrid*
Split mortgages
Total
* Hybrid is a combination of two or more forbearance arrangements.
31 December 2021
Interest only
Reduced payment (greater than interest only)
Payment moratorium
Arrears capitalisation
Term extension
Hybrid*
Split mortgages
Total
* Hybrid is a combination of two or more forbearance arrangements.
All loans
Number
Balances
€m
Stage 3
Number
Balances
€m
19
99
1
18
27
70
22
256
8
29
-
8
6
41
7
99
17
76
-
10
12
51
22
188
7
24
-
4
3
23
7
68
All loans
Number
Balances
€m
Stage 3
Number
Balances
€m
54
190
2
62
32
86
23
449
27
58
-
31
6
37
7
166
31
121
2
21
13
56
23
267
15
38
-
11
3
20
7
94
The tables above reflect a decrease of 193 cases in the year to 31 December 2022 for the Group in the number of residential buy-to-let in
forbearance arrangements, a decrease of €67m in balances. The average balance of forborne loans is €0.39m at 31 December 2022 (31
December 2021: €0.37m).
Commercial mortgages
The incidence of the main type of forbearance arrangements for commercial mortgages are analysed below:
Commercial mortgages
Interest only
Reduced payment (greater than interest only)
Payment moratorium
Arrears capitalisation
Term extension
Hybrid*
Split mortgages
Total
* Hybrid is a combination of two or more forbearance arrangements.
31 December 2022
31 December 2021
Number
Balances
€m
Number
Balances
€m
-
11
-
1
7
6
-
25
-
5
-
1
1
1
-
8
-
13
-
5
9
10
-
37
-
23
-
7
4
3
-
37
The table above reflects a decrease of 12 cases in the year to 31 December 2022 for the Group in the number of commercial mortgages in
forbearance arrangements, a decrease of €29m in balances.
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38. Financial risk management (continued)
(d) Reconciliation of movement in forborne loans for all classes
The tables below provide an analysis of the movement of total forborne loans and Stage 3 forborne loans during the year. It outlines the
number and balances of forbearance treatments offered, expired and loans paid down during the year.
(i) Reconciliation of movement of total forborne loans
Residential mortgages
31 December 2022
Home loans
cases
Home loans
balances
Buy -to-let
cases
Buy-to-let
balances
Commercial
cases
Commercial
balances Total cases
Total
balances
Opening balance 1 January
2022
New forbearance extended
during the year*
Deleveraged loans
Exited forbearance
- re-classified to Stage 3
non-forborne
- expired forbearance
treatment
- expired loan paid down
Balance shift**
Closing balance of loans
in forbearance as at 31
December 2022
€m
467
39
(1)
(3)
(106)
(25)
(13)
449
30
(138)
(7)
(34)
(44)
-
3,524
307
(3)
(18)
(816)
(247)
-
€m
166
17
(51)
(4)
(13)
(12)
(4)
2,747
358
256
99
* Balance movements are stated net of portfolio re-classification.
** Balance movements in respect of loans which are in forbearance at the start and end of the year.
€m
37
37
4,010
337
(141)
(25)
(854)
(299)
-
-
-
-
(4)
(8)
-
25
-
-
-
(21)
(8)
-
8
€m
670
56
(52)
(7)
(140)
(45)
(17)
3,028
465
31 December 2021
Home loans
cases
Home loans
balances
Buy -to-let
cases
Buy-to-let
balances
Commercial
cases
Commercial
balances Total cases
Total
balances
Residential mortgages
Opening balance 1 January
2021
New forbearance extended
during the year*
Deleveraged loans
Exited forbearance
- re-classified to Stage 3
non-forborne
- expired forbearance
treatment
- expired loan paid down
Balance shift**
Closing balance of loans in
forbearance as at 31
December 2021
€m
726
62
(115)
(3)
(139)
(49)
(15)
5,066
458
(845)
(16)
(753)
(386)
-
679
76
(214)
(1)
(58)
(33)
-
€m
231
30
(48)
-
(29)
(13)
(5)
3,524
467
449
166
* Balance movements are stated net of portfolio re-classification.
** Balance movements in respect of loans which are in forbearance at the start and end of the year.
€m
20
24
(3)
-
(1)
(2)
(1)
37
€m
977
116
(166)
(3)
(169)
(64)
(21)
5,789
541
(1,063)
(17)
(814)
(426)
-
4,010
670
44
7
(4)
-
(3)
(7)
-
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247
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
(ii) Reconciliation of movement in forborne loans Stage 3
31 December 2022
Opening balance 1 January 2022
New Stage 3 forborne extended
during the year*
Deleveraged loans
Exited forborne Stage 3, now
performing forborne
Exited forbearance
- exited forborne Stage 3, now Stage
3 non-forborne
- expired forbearance treatment
- expired loan paid down
Balance shift**
Closing balance loans in
forbearance as at 31 December
2022
Home loan
cases
Home loan
balances
€m
Buy-to-let
cases
Buy-to-let
balances
€m
Commercial
cases
2,010
354
(3)
(550)
(10)
(19)
(148)
-
289
43
(1)
(70)
(2)
(9)
(18)
(4)
267
29
(32)
(29)
(4)
(4)
(39)
-
94
15
(10)
(11)
(4)
(3)
(11)
(2)
1,634
228
188
68
32
-
-
(4)
-
(1)
(8)
-
19
Commercial
balances Total cases
€m
33
-
-
2,309
383
(35)
(1)
(583)
-
(17)
(8)
(1)
(14)
(24)
(195)
-
Total
balances
€m
416
58
(11)
(82)
(6)
(29)
(37)
(7)
6
1,841
302
* Balance movements are stated net of portfolio re-classification.
** Balance movements in respect of loans which are in forbearance at the start and end of the year.
31 December 2021
Opening balance 1 January 2021
New Stage 3 forborne extended
during the year*
Deleveraged loans
Exited forborne Stage 3, now
performing forborne
Exited forbearance
- exited forborne Stage 3, now Stage
3 non-forborne
- expired forbearance treatment
- expired loan paid down
Balance shift**
Closing balance of loans in
forbearance as at 31 December 2021
Home loan
cases
Home loan
balances
€m
Buy-to-let
cases
Buy-to-let
balances
€m
2,850
438
478
538
-
74
-
77
-
(392)
(46)
(32)
(12)
(112)
(862)
-
(2)
(25)
(146)
(4)
(1)
(76)
(179)
-
2,010
289
267
151
31
-
(13)
-
(19)
(55)
(1)
94
* Balance movements are stated net of portfolio re-classification.
** Balance movements in respect of loans which are in forbearance at the start and end of the year.
Commercial
cases
Commercial
balances Total cases
36
6
-
(1)
-
(1)
(8)
-
32
€m
14
25
-
(1)
-
(1)
(4)
-
33
Total
balances
€m
603
130
-
(60)
(2)
(45)
(205)
(5)
3,364
621
-
(425)
(13)
(189)
(1,049)
-
2,309
416
(vii) Funding profile
The ALCO monitors sources of funding and their respective maturities with a focus on establishing a stable and cost effective funding
profile. Excluding equity, the Group’s funding profile as at the 31 December 2022 can be broken down into the below component parts:
Customer accounts
Long-term debt
Short-term debt
31
December
2022
%
31
December
2021
%
93
4
3
100
94
4
2
100
Long-term debt refers to debt with a maturity greater than 12 months from year-end and short-term debt is that which has a maturity of
less than 12 months from year-end.
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38. Financial risk management (continued)
In accordance with IFRS 7, Financial Instruments: Disclosures, the following tables present the maturity analysis of financial liabilities on
an undiscounted basis, by remaining contractual maturity at the statement of financial position date. These will not agree directly with the
balances on the consolidated statement of financial position due to the inclusion of future interest payments.
31 December 2022
Liabilities
Deposits by banks
Customer accounts
Debt securities in issue
Derivative financial instruments
Subordinated liabilities
Other financial liabilities
Total liabilities
31 December 2021
Liabilities
Deposits by banks
Customer accounts
Debt securities in issue
Derivative financial instruments
Subordinated liabilities
Other financial liabilities
Total liabilities
Up to
1 month
€m
1-3
months
€m
3-6
months
€m
6-12
months
€m
1-2
years
€m
Over 2
years
€m
614
19,906
2
10
1
145
20,678
-
689
4
169
1
-
863
-
261
6
1,343
2
2
1,614
-
385
11
-
4
3
403
Up to
1 month
€m
1-3
months
€m
3-6
months
€m
6-12
months
€m
347
16,032
1
-
1
92
16,473
-
1,416
1
-
1
48
1,466
-
454
2
-
2
1
459
-
575
4
-
4
3
586
-
157
371
-
7
6
541
1-2
years
€m
-
221
7
-
7
4
239
-
342
308
-
300
27
977
Over 2
years
€m
-
405
537
-
304
22
1,268
Total
€m
614
21,740
702
1,522
315
183
25,076
Total
€m
347
19,103
552
-
319
170
20,491
When managing the Group’s liquidity and funding profile, for products where the contractual maturity date may be different from actual
behaviour, the Group uses statistical methodologies to manage liquidity on an expected or behaviourally adjusted basis.
The following table details the Group’s liquidity analysis for derivative instruments that do not qualify as hedging instruments. The table
has been drawn up based on the undiscounted contractual net cash inflows and outflows on derivative instruments that settle on a net
basis and the undiscounted gross inflows and outflows on those derivatives that require gross settlement. When the amount payable or
receivable is not fixed, the amount disclosed has been determined by reference to the projected interest rates from the yield curves at the
end of the reporting year. These will not agree directly with the balances on the consolidated statement of financial position.
31 December 2022
Gross settled:
FX forwards
- inflow
- outflow
Business combinations forwards
- inflow
- outflow
Balance at 31 December 2022
31 December 2021
Gross settled:
FX forwards
- inflow
- outflow
Balance at 31 December 2021
Up to
1 month
€m
1-3
months
€m
3-6
months
€m
6-12
months
€m
1-2
years
€m
Over 2
years
€m
82
(83)
-
(9)
(10)
-
-
-
(169)
(169)
Up to
1 month
€m
1-3
months
€m
-
-
-
(1,343)
(1,343)
3-6
months
€m
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
6-12
months
€m
1-2
years
€m
Over 2
years
€m
84
(84)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Total
€m
82
(83)
-
(1,521)
(1,522)
Total
€m
84
(84)
-
Permanent TSB Group Holdings plc - Annual Report 2022
249
Notes to the Consolidated Financial Statements
(continued)
38. Financial risk management (continued)
(viii) Interest rate gap position
Gap analysis is a technique for measuring the Group’s interest rate risk exposure beginning with a maturity/re-pricing schedule that
distributes interest sensitive assets, liabilities, and derivative positions into “time bands” according to their maturity (if fixed rate), time
remaining to their next re-pricing (if floating rate) or behavioural convention in order to identify any sources of significant mismatches. The
below December 2022 IRRBB profile also includes interest cash flows based on the next re-price date i.e. one month’s interest included for
variable rate products and lifetime interest for fixed rate products.
A summary of the Group’s interest rate gap position is as follows:
Interest rate re-pricing
31 December 2022
Assets
Liabilities
Derivatives
Interest rate re-pricing gap
Cumulative interest rate re-
pricing gap
31 December 2021
Assets
Liabilities
Derivatives
Interest rate re-pricing gap
Cumulative interest rate re-
pricing gap
Not more than
3 months
Over 3 months
but not more
than 6 months
Over 6 months
but not more
than 1 year
Over 1 year but
not more than 5
years
Over 5 years
€m
9,884
(6,048)
81
3,917
€m
697
(996)
-
(299)
€m
1,757
(2,425)
€m
11,516
(12,932)
-
(668)
(1,416)
€m
2,148
(2,836)
-
(688)
3,917
3,618
2,950
1,534 846
Not more than
3 months
Over 3 months
but not more
than 6 months
Over 6 months
but not more
than 1 year
Over 1 year but
not more than 5
years
Over 5 years
€m
12,608
(11,769)
84
923
923
€m
587
(973)
-
(386)
€m
1264
(1,395)
-
(131)
537
406
€m
6505
(6,137)
-
368
774
€m
1079
(1,546)
-
(467)
307
Total
€m
26,002
(25,237)
81
846
Total
€m
22043
-21820
84
307
An increase in ECB interest rates of 100bps would increase net interest income by €58m and a decrease in ECB interest rates of 100bps
would decrease net interest income by €58m.
39. Capital management
The core objective of the Group’s capital management policy is to ensure that the Group complies with its regulatory capital requirements
and maintains sufficient capital to cover its business risks and support its strategy. The Group has established an Internal Capital
Adequacy Assessment Process (ICAAP) to ensure that it is adequately capitalised against the inherent risks to which its business
operations are exposed and to maintain an appropriate level of capital to meet the minimum capital requirements. The ICAAP is subject to
review and evaluation by the Regulator. The management of capital within the Group is monitored by the Board Risk and Compliance
Committee (BRCC) and the Assets and Liabilities Committee (ALCo) in accordance with Board approved policy.
The Group’s regulatory capital comprises of three tiers:
1. CET1 capital, which includes ordinary share capital, share premium, retained earnings and other regulatory adjustments relating to
items that are included in equity but are treated differently for capital adequacy purposes;
2. Additional Tier 1 Capital, which includes qualifying convertible perpetual financial instruments with discretionary coupons; and
3. Tier 2 Capital, which includes qualifying subordinated liabilities, revaluation reserves and other regulatory capital adjustments.
The Group’s 2022 regulatory CET1 (transitional) minimum requirement is 8.94% (December 2021: 8.94%). The CET1 ratio requirement of
8.94% consists of a Pillar 1 CRR requirement of 4.50%, a Pillar 2 Requirement (P2R) of 1.94% (December 2021: 1.94%) and the Capital
Conservation Buffer (CCB) of 2.50%.
The Group’s Total Capital minimum requirement of 13.95% at 31 December 2022 (31 December 2021: 13.95%) consists of a Pillar 1 CRR
requirement of 8%, P2R of 3.45%, and CCB of 2.5%.
250
Permanent TSB Group Holdings plc - Annual Report 2022
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39. Capital management (continued)
These requirements exclude Pillar 2 Guidance (P2G) which is not publicly disclosed.
The following table summarises the composition of regulatory capital and the ratios of PTSB, the primary regulated entity of the Group as
at 31 December 2022 and 31 December 2021 which are calculated in accordance with CRD IV regulatory capital requirements.
The following information has not been subject to audit by the Group’s independent auditor.
31 December
2022
31 December
2021
€m
€m
Common Equity Tier 1 capital
Share capital and share premium
Reserves
Prudential filters
Total qualifying CET1 capital
Additional Tier 1 capital
Total qualifying Tier 1 capital
Tier 2 capital
Subordinated liabilities
Other
Total qualifying Tier 2 capital
Total own funds
Risk weighted assets
Total risk-weighted assets
- Credit risk (including CVA)
- Operational risk
Capital Ratios
Common Equity Tier 1 Capital ratio (Transitional basis)
Total capital ratio (Transitional basis)
The CET1 and Total Capital ratios are calculated and reported to the CBI on a quarterly basis.
The movement in the Group’s regulatory capital is summarised below:
Balance as at 1 January
NatWest Equity Investment
Operating profit/(loss) after tax
Other intangible assets add-back/(deduction)
Deferred tax assets write-back/(deduction)
IFRS 9 phase-in
AT1 securities
Tier 2 Sub Debt
Other movements*
Balance as at 31 December
1,077
940
(299)
1,718
369
2,087
250
32
282
2,369
€m
10,627
9,927
700
16.2%
22.3%
2022
€m
1,870
155
223
(33)
2
(54)
245
(8)
(31)
561
1,104
(208)
1,457
123
1,580
250
40
290
1,870
€m
8,600
7,961
639
16.9%
21.8%
2021
€m
1,779
0
(20)
19
(36)
(28)
(80)
250
(14)
2,369
1,870
*Other movements include AT1 Coupons (-€17m), Calendar Provisioning (-€11m) and Revaluation Reserves (-€5m).
Permanent TSB Group Holdings plc - Annual Report 2022
251
Notes to the Consolidated Financial Statements
(continued)
40. Current/non-current assets and liabilities
The following table provides an analysis of certain asset and liability line items as at 31 December 2022 and 31 December 2021. The
analysis includes amounts expected to be recovered or settled no more than 12 months after the statement of financial position date
(current) and more than 12 months after the statement of financial position date (non-current).
31 December 2022
31 December 2021
Assets
Cash at bank
Items in the course of collection
Loans and advances to banks
Derivative financial instruments
Other assets
Assets classified as held for sale
Debt securities
Equity Securities
Prepayments and accrued income
Loans and advances to customers
Liabilities
Deposits by banks
Customer accounts
Derivative financial instruments
Debt securities in issue
Other liabilities
Accruals
Provisions
Subordinated liabilities
14
14
15
16
17
18
19
20
21
22
28
29
16
30
31
32
33
Note
Current Non-current
€m
€m
Total
€m
58
40
2,123
-
1
18
3,177
30
207
Current Non-current
€m
€m
57
20
4,174
1
310
28
214
-
205
-
-
-
-
-
-
2,280
26
-
Total
€m
57
20
4,174
1
310
28
2,494
26
205
58
40
2,123
-
1
18
735
-
207
-
-
-
-
-
-
2,442
30
-
2,521
17,072
19,593
2,071
12,185
14,256
614
21,240
13
10
149
7
52
3
-
490
-
648
32
-
28
249
614
21,730
347
18,476
13
658
181
7
80
252
-
2
144
8
19
3
-
613
-
522
26
-
36
249
347
19,089
-
524
170
8
55
252
41. Transfer of financial assets
In the ordinary course of business, the Group enters into transactions that result in the transfer of financial assets of loans and advances
to customers. In accordance with note 1.5 (vii), the transferred financial assets continue to be either recognised in their entirety or to the
extent of the Group’s continuing involvement, or are derecognised in their entirety.
The Group transfers financial assets primarily through the following transactions:
1. sale and repurchase of securities; and
2. securitisation activities in which loans and advances to customers are sold to Structured Entities (SEs) that in turn issue notes to
investors which are collateralised by purchased assets.
(a) Transferred financial assets that are not derecognised in their entirety
Sale and repurchase agreements
Sale and repurchase agreements are transactions in which the Group sells a security and simultaneously agrees to repurchase it (or an
asset that is substantially the same) at a fixed price on a future date. The Group continues to recognise the securities in their entirety in
the statement of financial position as loans and advances to customers (note 22) and debt securities (note 19) because it retains
substantially all the risks and rewards of ownership. The cash consideration received is recognised as a financial asset and a financial
liability is recognised for the obligation to pay the repurchase price. As the Group sells the contractual rights to the cash flows of the
securities it does not have the ability to use or pledge as collateral the transferred assets during the term of the arrangement. The carrying
value of repurchase agreements at 31 December 2022 is €611m (31 December 2021: €347m).
252
Permanent TSB Group Holdings plc - Annual Report 2022
41. Transfer of financial assets (continued)
Securitisations
The Group sells loans and advances to customers to SEs that in turn issue notes to investors which are collateralised by the purchased
assets. For the purpose of disclosure in this note, a transfer of such financial assets may arise if the Group sells assets to a consolidated
SE, the transfer of financial assets is from the Group (that includes the consolidated SE) to investors in the notes issued by the SE. The
transfer is in the form of the Group assuming an obligation to pass cash flows from the underlying assets to investors in the notes.
Although the Group does not own more than half of the voting power of the Fastnet entities, it has the power to control the relevant
activities of the SE and the ability to affect the variable returns of the investee and hence these SEs are consolidated. In these cases, the
consideration received from the investors in the notes in the form of cash is recognised as a financial asset and a corresponding financial
liability is recognised.
When the Group transfers assets as part of the securitisation transactions it does not have the ability to use or pledge as collateral the
transferred assets during the term of the arrangement.
The table below sets out an overview of carrying amounts and fair values related to transferred financial assets that are not derecognised
in their entirety and associated liabilities.
31 December 2022
31 December 2021
Sale and
repurchase
agreements Securitisations
Sale and
repurchase
agreements Securitisations
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Carrying amount of assets
Carrying amount of associated liabilities
Liabilities that have recourse only to the transferred financial
assets
Fair value of assets
Fair value of associated liabilities
Net position
€m
678
612
654
612
42
€m
-
-
-
-
-
€m
724
745
732
745
(13)
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€m
153
172
150
172
(22)
(b) Transferred financial assets that are derecognised in their entirety
The Group has not transferred any financial assets that were derecognised in their entirety where the Group has continuing involvement in
a transferred asset.
42. Offsetting financial assets and financial liabilities
In accordance with IAS 32, Financial Instruments: Presentation, the Group reports financial assets and financial liabilities on a net basis on
the statement of financial position only if there is a legally enforceable right to set off the recognised amounts and there is an intention to
settle on a net basis, or to realise the asset and settle the liability simultaneously. This is disclosed in the table below in the “Effect of
offsetting on the statement of financial position” section.
The gross amounts of derivative assets and liabilities and their net amounts disclosed in the below tables have been measured in the
statement of financial position at fair value.
The tables below also disclose (in the “Related amounts not offset in the statement of financial position” section) the impact of master
netting agreements and other similar agreements on all derivative financial instruments and similar financial instruments that are subject
to master netting agreements or similar agreements, but do not qualify for netting on the balance sheet. The similar financial agreements
include securitisations and sale and repurchase agreements. The similar agreements include global master repurchase agreements. It
highlights the amounts that could be potentially offset on the statement of financial position and those amounts covered by collateral
placed with or by counterparties to these trades.
The tables highlight the amounts that have been offset on the statement of financial position and those amounts covered by collateral
placed with or by counterparties to these trades. It does not highlight where right of offset is available in the event of a default, as allowed
under ISDA master agreements.
Permanent TSB Group Holdings plc - Annual Report 2022
253
Notes to the Consolidated Financial Statements
(continued)
42. Offsetting financial assets and financial liabilities (continued)
The tables below also provide analysis of derivative financial assets and liabilities subject to offsetting, enforceable master netting
agreements and similar agreements:
Effect of offsetting on the statement of financial
position
Related amounts not offset in the statement of
financial position
Gross financial
assets/
(liabilities)
recognised
Gross financial
(liabilities)/
assets offset
Net amounts
reported on the
statement of
financial
position
Financial
instruments Cash collateral
Net amount
€m
€m
€m
€m
€m
€m
-
-
1
1
-
-
-
-
-
-
1
1
-
-
-
-
-
-
-
-
-
-
1
1
Effect of offsetting on the statement of financial
position
Related amounts not offset in the statement of
financial position
Gross financial
assets/
(liabilities)
recognised
Gross financial
(liabilities)/
assets offset
Net amounts
reported on the
statement of
financial
position
Financial
instruments Cash collateral
Net amount
€m
€m
€m
€m
€m
€m
1
1
-
-
-
-
-
-
1
1
-
-
-
-
-
-
-
-
-
-
1
1
-
-
31 December 2022
Assets
Derivative financial instruments
Total
Liabilities
Derivative financial instruments
Total
31 December 2021
Assets
Derivative financial instruments
Total
Liabilities
Derivative financial instruments
Total
43. Commitments and Contingencies
The table below gives the contractual amounts of irrevocable credit commitments. Even though these obligations are not recognised in
statement of financial position they do involve credit risk. The maximum exposure to credit loss under commitments is the contractual
amount of the instrument in the event of non-performance by the other party where all counter claims, collateral or security prove
worthless. The transfer of economic resources is uncertain and cannot be reasonably measured to be recognised on the SOFP.
Credit commitments
Guarantees and irrevocable letters of credit
Commitments to extend credit
- less than 1 year
- 1 year and over
Total commitments to extend credit
Total credit commitments
31 December
2022
31 December
2021
€m
2
1,284
56
1,340
1,342
€m
2
1,113
66
1,179
1,181
254
Permanent TSB Group Holdings plc - Annual Report 2022
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43. Commitments and Contingencies (continued)
Other contingencies
The Group, like all other banks, is subject to litigation in the normal course of its business. Based on legal advice, other than matters
referred to in note 32, the Group does not believe that any such litigation will have a material effect on its income statement or SOFP.
A number of different statutory and regulatory bodies, including the CBI, commenced investigations into a series of transactions involving
deposits placed by Irish Life Assurance plc with Irish Bank Resolution Corporation (formerly Anglo Irish Bank) (on 31 March 2008, 26
September 2008, 29 September 2008 and 30 September 2008). While these investigations commenced a number of years ago, they
were put on hold pending the determination of criminal proceedings against a number of individuals in respect of the same transactions.
The Bank understands that those criminal proceedings have concluded and so the Bank is waiting to see if the investigations, which, from
the Bank’s perspective, have been dormant for some time will now be re-commenced.
As part of the agreement in August 2011 to dispose of Irish Life International Limited, the Group provided certain indemnities and
warranties to the purchaser under a number of identified scenarios.
Like other banks, in the normal course of business, customers bring complaints to the Financial Services and Pensions Ombudsman
(FSPO) in relation to a variety of issues. The Bank considers the applicability of FSPO decisions and findings to other customers in similar
circumstances. The Bank provides for these cases, where based on legal advice, the directors believe that it is more likely than not that an
outflow of resources embodying economic benefits, will be required to settle a present obligation arising from a past event. The Bank has
recently commenced appeals against two FSPO decisions in tracker mortgage related complaints to the High Court and, while the timing
and outcome of these appeals is uncertain, based on legal advice received, no provision has been made for these cases. However, if the
Bank is unsuccessful in these appeals the impact on the financial statements could be material.
ECL held against commitments are reported under loans and advances to customers.
In June 2021 PTSB committed to participate in the First Home Scheme along with the State and AIB and Bank of Ireland. PTSB has
engaged with these parties over the last year to determine the structure of the Scheme as well as the mechanism for funding the
operations of the scheme. The Group committed €54m in funding to the Joint venture. €10m was recognised in the Statement of
Financial Position in respect of the scheme as at 31 December 2022.
44. Related parties
Related parties include individuals and entities that can exercise significant influence on operational and financial policies of the Group.
The Group has a related party relationship with its Directors, Senior Executives, the Group’s pension schemes, the Minister for Finance and
with the Irish Government and Irish Government related entities on the basis that the Irish Government is deemed to have control over the
Group.
(a) Directors’ and Secretary’s interest
The interests of the Directors and the Company Secretary, including interests of their close family members in the share capital of the
Company are as follows:
Number of beneficial ordinary shares held
31 December 2022 31 December 2021
Robert Elliott
Eamonn Crowley
Position
Chairman
Chief Executive Officer
Nicola O’Brien (appointed 04 August 2022)
Chief Financial Officer
Michael Frawley (retired 31 March 2022)
Chief Risk Officer
Conor Ryan
Donal Courtney
Ronan O’Neill
Andrew Power
Ken Slattery
Ruth Wandhöfer
Marian Corcoran
Paul Doddrell
Celine Fitzgerald
Anne Bradley
Company Secretary
Non-Executive Director
Non-Executive Director
Non-Executive Director
Non-Executive Director
Non-Executive Director
Non-Executive Director
Non-Executive Director
Non-Executive Director
Non-Executive Director
Permanent TSB Group Holdings plc - Annual Report 2022
Ordinary
shares
16,500
50,000
-
-
10
-
4
-
Ordinary
shares
16,500
50,000
-
-
10
-
4
-
10,000
10,000
-
-
-
-
-
-
-
-
-
-
255
Notes to the Consolidated Financial Statements
(continued)
44. Related parties (continued)
Conor Ryan, as trustee of the employee benefit trust set up under the terms of the long-term incentive plan, has non-beneficial interest in
4,580 shares held in the plan (31 December 2021: 4,580).
There were no transactions in the above Directors’ and Secretary’s interests between 31 December 2022 and 28 February 2023.
Details of the Directors’ remuneration is included in the Directors’ Remuneration Report on pages 142 to 146.
(b) Transactions with key management personnel
Key management personnel are those persons having authority and responsibility for planning, directing and controlling the activities of
the Group. Key management personnel include Non-Executive Directors, Executive Directors and members of the Executive Committee
(ExCo). The Executive Directors and members of the ExCo are listed below:
Members of the ExCo at 31 December 2022
Eamonn Crowley
Nicola O’Brien
Patrick Farrell
Tom Hayes
Ger Mitchell
Andrew Walsh
Peter Vance
David Curtis
Chief Executive
Chief Financial Officer
Retail Sales Director
Chief Technology Officer
CHRO and Corporate Development Director
Chief Legal Officer
Chief Operations Officer
Interim Chief Risk Officer
During the year ended 31 December 2022, the following key management personnel changes occurred;
Nicola O’Brien was appointed as Chief Financial Officer following the retirement of Declan Norgrove as Interim Chief Financial Officer.
David Curtis was appointed Interim Chief Risk Officer following the retirement of Michael Frawley as Chief Risk Officer.
Declan Norgrove, Breege Timoney and Shane O’Sullivan retired as members of the ExCo during 2021. Their details are included in the
comparative figures for 2021.
Non-Executive Directors are compensated by way of fees. In certain circumstances, expenses incurred by Non-Executive Directors during
the normal course of business are paid by the Group and are included in taxable benefits. The compensation of Executive Directors and
members of the ExCo comprises salary and other benefits together with pension benefits. Previously they also participated in the Group’s
profit sharing, share option schemes and long-term incentive plans. No awards have been issued under these schemes and plans since
2008.
Number of key management personnel as at year end is as follows:
Non-Executive Directors
Executive Directors and Senior Management
31 December
2022
31 December
2021
10
8
18
10
8
18
256
Permanent TSB Group Holdings plc - Annual Report 2022
44. Related parties (continued)
(b) (i) Total compensation to Executive and Non-Executive Directors is as follows:
Fees
Taxable benefits
Salary and other benefits
Pension benefits
- defined contribution
Total
Total compensation to other key management personnel is as follows:
Year ended
Year ended
31 December
2022
31 December
2021
€’000
1,044
2
742
106
1,894
€’000
946
2
856
122
1,926
Year ended
Year ended
31 December
2022
31 December
2021
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Taxable benefits
Salary and other benefits
Pension benefits
- defined contribution
CFO Fees
Total
€’000
5
2,395
332
-
2,732
€’000
2
2,221
282
359
2,864
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There were no connected persons to key management personnel employed by the group during 2022 or 2021,
(b) (ii) Balances and transactions with key management personnel:
In the normal course of its business, the Group had loan balances and transactions with key management personnel and their connected
persons. The loans are granted on normal commercial terms and conditions with the exception of certain home loans where Executive
Directors and Senior Managers may avail of subsidised loans on the same terms as other eligible management of the Group. All of the
loans in the scope of the related party guidelines as outlined under the Companies Act 2014, the Central Bank Related Party lending code
2013 and IAS 24 Related party disclosures are secured, and all interest and principal due at the statement of financial position date has
been repaid on schedule and therefore, no provision for loan impairment is required. Total outstanding balances of loans, credit cards,
overdrafts and deposits are as follows:
Balances
Loans
Unsecured credit card balances and overdrafts
Deposits
Transactions during the year
Loan advances
Loan repayments
Interest received on loans
Interest paid on deposits
Permanent TSB Group Holdings plc - Annual Report 2022
31 December
2022
31 December
2021
€’000
€’000
1,059
1
3,354
1,948
-
4,663
Year ended
Year ended
31 December
2022
31 December
2021
€’000
€’000
-
892
41
(1)
660
327
43
(1)
257
Notes to the Consolidated Financial Statements
(continued)
44. Related parties (continued)
Loans to Directors
31 December 2022
Ronan O’Neill*
31 December 2021
Marian Corcoran
Ronan O’Neill*
Balance as at 1
Jan
Advances
during year Principal repaid
€’000
€’000
€’000
652
652
-
-
12
12
Balance as at 1
Jan
Advances
during
year Principal repaid
€’000
€’000
€’000
248
-
248
-
660
660
248
8
256
Balance
as at
31 Dec
€’000
640
640
Balance
as at
31 Dec
€’000
-
652
652
Interest
paid
€’000
16
16
Interest
paid
€’000
2
11
13
Maximum
balance
€’000
652
652
Maximum
balance
€’000
248
660
908
* Represents a loan for a person connected with this Director in accordance with section 307(3) of the Companies Act 2014.
(c) Irish Government and Irish Government related entities
The Minister for Finance continues to be the majority shareholder of the Group (and the ultimate controlling party per IAS 24). The Irish
Government is recognised as a related party as the Government is deemed to have control over the Group as defined by IAS 24. The Group
has applied the amended IAS 24 which exempts an entity from the related party disclosure requirements in respect of the Government
and Government related entities unless transactions are individually or collectively significant. In the normal course of business, the Group
has entered into transactions with the Government and Government related entities involving deposits and senior debt.
The following are transactions and balances between the Group and the Government and Government related entities that are collectively
significant:
• The Group holds securities issued by the Government of €1,734m (31 December 2021: €1,463m).
•
In May 2021, PTSB plc borrowed €250m from the Group at a fixed rate of 3% per annum plus a margin of 0.181% per annum which
mature on 19 August 2031. The loan is subordinated and ranks as Tier 2 capital notes with interest paid annually in arrears on 19
August.
• The Group had an investment in associated undertakings of €13m for the year ended 31 December 2022 involving participants that are
deemed related parties due to the common ownership by the Government. The amount and nature is referenced in note 24.
• The Group entered into banking transactions in the normal course of business with local Government and Semi-State Institutions such
as local authorities and county councils. These transactions principally include the granting of loans, the acceptance of deposits and
clearing transactions.
• A bank levy imposed by the Government through the Finance Bill 2014 is payable in the second half of each calendar year. A bank levy
payable to government, is provided for on the occurrence of the event identified by the legislation that triggers the obligation to pay the
levy. In 2022, the amount recognised in the income statement was €22m (31 December 2021: €22m). As announced by the Minister by
Finance in October 2022, the bank levy was extended to 2023.
• During 2022, the Group also paid €19m DGS fees to the CBI (2021: €17m) as part of the Deposit Guarantee Scheme.
• During 2013, following the Transfer Order requested by the Central Bank and issued by the High Court dated 10 November 2013, the
Group acquired certain assets, liabilities, books and records of NCU and all its employees transferred to the Group. As part of this
transaction, along with the assets and liabilities of NCU, a cash financial incentive of €23m was paid from the Credit Institutions
Resolution Fund, which forms part of the Financial Incentives Agreement (FIA) signed between the Central Bank and the Group dated
10 November 2013. It was also agreed in the FIA that the Central Bank will use the Credit Institution Resolution Fund to compensate the
Group for 50% of any future impairment losses incurred on NCU loans and advances to customers. Similarly, it was also agreed that if
any provision write-backs or future recoveries of previously written off NCU loans and advances to customers occurs, the Group will pay
a cash amount equivalent to 50% of the provision write-back or the recoveries to the Credit Institutions Resolution Fund. As per the FIA,
this arrangement will continue for ten years from the transfer date. At 31 December 2022, the Group had recorded a payable of €2.3m
due under the FIA (31 December 2021: €2m).
258
Permanent TSB Group Holdings plc - Annual Report 2022
44. Related parties (continued)
The Government also has a controlling interest in Allied Irish Bank plc including EBS Limited. Due to the Group’s related party relationship
with the Irish Government as described above, balances between these financial institutions and the Group are considered related party
transactions in accordance with IAS 24. There are no balances between these entities as at 31 December 2022 or 31 December 2021. As at
31 December 2022, the Irish Government no longer has significant influence over Bank of Ireland.
(d) Other related party transactions
• At 31 December 2022 the Company had an intercompany balance of €658m (31 December 2021: €352m) with its principal subsidiary
•
PTSB plc relating to the MREL issuance.
In November 2020, the Company made an investment of €123m in PTSB. This investment was through the issuance of AT1 securities
by the Company. In October 2022, the Company made an additional investment of €245m in PTSB through the issuance of AT1
securities by the Company.
45. Sale of loans and advances to customers
Project Glenbeigh IV
On 21 September 2022, the Group agreed the sale of a predominately performing buy-to-let loan portfolio (’Glenbeigh IV’). The portfolio
gross balance on the Statement of Financial Position was €767m with a net book value of €703m.
In line with IFRS 9, the assets have been derecognised from the Statement of Financial Position.
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As a result of the transaction, an impairment write-back on the sale of the portfolio of €8m was recorded through the impairment line of
the Income Statement. On 17 November 2022, the deal completed with the receipt of the sales proceeds.
Project Glenbeigh III
On 9 November 2021, the Group agreed the sale of a predominately NPL portfolio (‘Glenbeigh III’). The portfolio gross balance on the
Statement of Financial Position was €390m with a net book value of €305m.
In line with IFRS 9, the assets were derecognised from the 2021 Statement of Financial Position and a receivable of €310m was recorded
for the cash consideration. As a result of the transaction, an impairment write-back on the sale of the portfolio of €11m was recorded
through the 2021 Income Statement. On 21 February 2022, the deal completed with the receipt of the sales proceeds.
46. Principal subsidiary undertakings and interest in subsidiaries and structured entities
Under IFRS 10 ‘Consolidated financial statements’, the Group has control over an entity when it has the power to direct relevant activities
that significantly affect the investee return, it is exposed or has rights to variable returns from its involvement in the investee and has the
ability to affect those returns through its powers over the entity.
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A subsidiary is considered material if the value of the consolidated total assets at the end of the financial year of the subsidiary and the
entities it controls (if any) is more than 1% of the total assets of the Group.
The key subsidiary of the parent meeting the criteria outlined above is:
Name and registered office
Held directly by the company:
Permanent TSB plc
Nature of
Incorporated % of ordinary
business
in
shares held
56-59 St. Stephen’s Green, Dublin 2
Retail banking
Ireland
100
In presenting details of the principal subsidiary undertakings, the exemption permitted by section 315 (a) (i) of the Companies Act 2014 in
relation to disclosing related undertaking net assets or profit or loss, has been availed of, and the Company will annex a full listing of Group
undertakings to its annual return to the Companies Registration Office.
The reporting date for each of the Group’s principal subsidiary entities is 31 December.
The principal country of operation of each company is the country in which it is incorporated.
The registered office of Permanent TSB Group Holdings plc is 56-59 St. Stephen’s Green, Dublin 2.
Permanent TSB Group Holdings plc - Annual Report 2022
259
Notes to the Consolidated Financial Statements
(continued)
46. Principal subsidiary undertakings and interest in subsidiaries and structured entities (continued)
(A) Company’s interest in subsidiary undertakings
The Company is the ultimate holding company of the Group while PTSB is a 100% subsidiary of the Company. The investment in PTSB is
carried at the recoverable amount in the holding company’s statement of financial position.
At 31 December 2022 the investment amounted to €2,346m (31 December 2021: €888m). The Group carried out an impairment
assessment using a combination of internal group models and externally available data to inform their view of the recoverable amount of
investment. As the value in use was higher than the carrying value, in line with IAS 36, no impairment charge was taken (31 December
2021: impairment charge €66m). A write back of €697m was taken as the value in use calculation indicated that there was sufficient
evidence for management to reverse the impairment losses taken in prior years. See company SOFP on page 263 for further details.
(B) Structured entities (SEs)
A structured entity is an entity in which voting or similar rights are not the dominant factor in deciding control. SEs are generally created to
achieve a narrow and well defined objective with restrictions around their on-going activities. Depending on the Group’s power to direct
the relevant activities of the investee and its exposure or rights to variable returns from its involvement in the investee and the ability to
use its power over the investee to affect the amount of the investor’s return, it may consolidate the entity.
Control and voting rights
The Directors of the individual SEs are independent of the Group and neither the Group nor any of its subsidiaries have voting rights in the
share capital of these entities. The Group initiated the setup of these SEs and, as architect dictated the terms relating to the operation of
these SEs. The Group, as administrator, provides services to the individual SEs. The Group, as administrator, has power to:
• Exercise rights, powers and discretions of the Issuers in relation to the mortgage loans and their related security and to perform its
duties in relation to the mortgage loans and their related securities: and
• To do or cause to be done any and all other things which it reasonably considers necessary, convenient or incidental to the
administrator of the mortgage loans and their related security or the exercise of such rights, powers and discretions.
The key activities performed by the Group’s subsidiaries as administrator is:
• To manage the credit risk associated with the mortgages contained in the individual SEs; and
• To determine and set rates of interest applicable to loans on each rate setting date in accordance with the terms of the loans and
negotiate the cost of funds associated with these mortgages which may result in a variable return in the entity.
These two items highlight the power the Group has to direct the relevant activities of these entities that significantly affect the investee
returns and the ability to use its power to affect variable returns of investors.
The Group provides funding to each of these vehicles by way of a subordinated loan and has an entitlement to deferred consideration.
Through the subordinated loan and the deferred consideration the Group is exposed to the variable returns of the SEs.
The Group currently has six SEs in issue in the ROI the details of which are outlined below. During 2022, Fastnet Securities 12 DAC which
collapsed in 2021 went into liquidation, Fastnet Securities 13 DAC was collapsed and subsequently went into liquidation and Fastnet
Securities 18 DAC was set up:
SEs setup with ROI Residential Mortgages
- Fastnet Securities 11 DAC
- Fastnet Securities 14 DAC
- Fastnet Securities 15 DAC
- Fastnet Securities 16 DAC
- Fastnet Securities 17 DAC
- Fastnet Securities 18 DAC
Sub loan
provided
√
√
√
√
√
√
Although the Group does not own more than half of the voting power, it has the power to control the relevant activities of the SE and the
ability to affect the variable returns of the investee and hence these SEs are consolidated. In these cases, the consideration received from
the investors in the notes in the form of cash is recognised as a financial asset and a corresponding financial liability is recognised.
At 31 December 2022, restricted cash of €405m (31 December 2021: €329m) relates to cash held by the Group’s securitisation.
260
Permanent TSB Group Holdings plc - Annual Report 2022
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47. Reporting currency and exchange rates
The consolidated financial statements are presented in millions of Euro.
The following table shows the closing and average rates used by the Group for the current year-end and prior year-end
€ / £ exchange rate
Closing
Average
€ / US$ exchange rate
Closing
Average
31 December
2022
31 December
2021
0.8869
0.8549
1.0666
1.0500
0.8403
0.8583
1.1326
1.1814
48. Events after the reporting period
Subsequent to the statement of financial position date the Group paid €41m in relation to the equity cash component amount and the
Branch Properties were transferred from Ulster Bank for consideration of €9m in January 2023. The SME assets were acquired in
February 2022 and cash of €162m was paid. See note 3 for further detail.
No other items, transactions or events that would materially impact the consolidated financial statements and require adjustment or
disclosure to these consolidated financial statements have occurred between the reporting date of 31 December 2022 and the date of the
approval of these financial statements by the Board of Directors of 28 February 2023.
Permanent TSB Group Holdings plc - Annual Report 2022
261
Company Financial Statements and Notes to the Company Financial Statements
Index:
Statement of Financial Position
Statement of Changes in Equity
Statement of Cash flows
A Accounting policies
B Loans and advances to banks
C Investment in subsidiary
D Debt securities in issue
E Subordinated liabilities
F Share capital and reserves
G Related parties
H Audit fees
Page
263
264
265
266
266
267
267
268
268
268
268
262
Permanent TSB Group Holdings plc - Annual Report 2022 Company Statement of Financial Position
As at 31 December 2022
Assets
Loans and advances to banks
Investments in subsidiary undertakings
Total assets
Liabilities
Debt securities in issue
Other liabilities
Subordinated liabilities
Total liabilities
Equity
Share capital
Share premium
Retained earnings
Shareholders’ equity
Other equity instruments
Total equity
Total liabilities and equity
Notes
31 December
2022
31 December
2021
€m
€m
B
C
D
E
911
2,346
3,257
658
1
252
911
273
804
901
1,978
368
2,346
3,257
604
888
1,492
352
1
252
605
227
333
204
764
123
887
1,492
The Company’s profit for the financial year determined in accordance with IFRS was €707m (2021: €56m loss).
On behalf of the Board:
Robert Elliott
Chairman
Eamonn Crowley
Chief Executive
Nicola O’Brien
Chief Financial Officer
Conor Ryan
Company Secretary
263
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Company Statement of Changes in Equity
For the year ended 31 December 2022
Company
Attributable to equity holders of the parent
Share capital
Share premium
Retained
earnings
Other equity
instrument
Balance as at 1 January 2021
Loss for year ended 31 December 2021
Other comprehensive income, net of tax
Total comprehensive expense for the year
Transactions with owners, recorded directly in equity:
Contributions by and distributions to owners
AT1 coupon paid
Loss on redemption of AT1 securities
Total contributions by and distributions to owners
Balance as at 31 December 2021
Balance at 1 January 2022
Profit for the year ended 2022
Other comprehensive income, net of tax
Total comprehensive income for the year
Transactions with owners, recorded directly in equity:
Issue of share capital
Issue of other equity instruments
Issuance cost of share capital and other equity
AT1 coupon paid
Total contributions by and distributions to owners
Balance as at 31 December 2022
€m
227
.
-
-
-
-
-
-
227
227
-
-
-
46
-
-
46
273
€m
333
-
-
-
-
-
-
333
333
-
-
-
472
(1)
-
471
804
€m
270
(56)
-
(56)
(10)
-
(10)
204
204
707
-
707
-
(10)
(10)
901
€m
126
-
-
-
-
(3)
(3)
123
123
-
-
-
250
(5)
-
245
368
Total
€m
956
(56)
-
(56)
(10)
(3)
(13)
887
887
707
-
707
518
250
(6)
(10)
752
2,346
264
Permanent TSB Group Holdings plc - Annual Report 2022 Company Statement of Cash Flows
For the year ended 31 December 2022
Cash flows from operating activities:
Operating profit/(loss) / profit/(loss) before taxation
Adjusted for non-cash items and other adjustments
Increase in operating assets:
Loans and advances to banks
(Increase)/decrease in operating liabilities:
Debt securities in issue
Other liabilities
Net cash inflow/(outflow) from operating activities before tax
Tax paid
Net cash inflow/(outflow) from operating activities
Cash flow from investing activities
Investments in subsidiary undertakings
Net cash flow from investing activities
Cash flow from financing activities
Issuance of AT1 securities (net of issuance costs)
Proceed from T2 capital notes
Interest paid on T2 capital notes
AT1 Coupon payment
Net cash flow from financing activities
Increase in cash and cash equivalents
Analysis of changes in cash and cash equivalents
Cash and cash equivalents as at 1 January
Increase in cash and cash equivalents
Cash and cash equivalents as at 31 December
Reconciliation of liabilities arising from financing activities
1 January
Financing cash flows:
Issuance of Tier 2 capital notes
Interest paid on T2 capital notes
Interest accrued on T2 capital notes
31 December
31 December
31 December
2022
€m
2021
€m
707
(688)
19
(56)
65
9
(307)
(253)
306
-
18
-
18
(245)
(245)
245
-
(8)
(10)
227
-
-
-
-
1
1
(242)
-
(242)
-
-
-
252
-
(10)
(242)
-
-
-
-
31 December
31 December
2022
2021
252
-
(8)
8
252
-
252
-
252
265
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Notes to the Company Financial Statements
A. Accounting policies
The accounting policies adopted by Permanent TSB Group Holdings plc (‘Company’) are the same as those of the Group as set out in note
1 to the consolidated financial statements where applicable. These financial statements reflect the financial position of the Company
only and do not consolidate the results of any subsidiaries.
The individual financial statements of the ultimate holding company, Permanent TSB Group Holdings plc have also been prepared in
accordance with IFRS as adopted by the EU and comply with those parts of the Companies Act 2014. In accordance with section 304
(2) of the Companies Act 2014, the Company is availing of the exemption from presenting its individual income statement to the Annual
General Meeting and from filing it with the Registrar of Companies.
B. Loans and advances to banks
Held at amortised cost
Funds placed with subsidiary, Permanent TSB plc (‘PTSB’)
ECL allowance
Loans and advances to banks
31 December
2022
31 December
2021
€m
912
(1)
911
€m
605
(1)
604
Funds placed with the principal subsidiary, PTSB are stage 1 under IFRS 9. The ratings for PTSB are as follows:
• Standard & Poor’s (S&P): Long-Term Rating “BBB” with Outlook “Positive”;
• Moody’s: Long-Term Rating “A2” with Outlook “Stable”; and
• DBRS: Long-Term Rating “BBBL” with Outlook “Stable”.
In June 2022, the Company subscribed to the €300m of Senior Unsecured Medium Term Note issued by PTSB to meet the subsidiary’s
internal MREL requirements, which represents down streaming of the proceeds raised by the Company via the external Senior
Unsecured issuance. The terms of the Non-Preferred Senior loan were a placement at a base rate of 5.25% plus a margin of 0.14% per
annum maturing on 30 June 2025. The interest is received annually in arrears on 30 June.
During 2021, the Company subscribed to the €250m of subordinated loan issued by PTSB to meet the subsidiary’s internal MREL
requirements, which represents down streaming of the proceeds raised by the Company via the external subordinated Tier 2 capital note
issuance. The terms of the subordinated loan were a placement at a base rate of 3% plus a margin of 0.181% per annum maturing on 19
August 2026. The interest is received annually in arrears on 19 August.
During 2020, the Company subscribed to the €51m Non-Preferred Senior loan issued by PTSB to meet the subsidiary’s internal MREL
requirements, which represents down streaming of the proceeds raised by the Company via the external Senior Unsecured issuance.
The terms of the Non-Preferred Senior loan were a placement at a base rate of 1.659% plus a margin of 0.211% per annum maturing on
26 September 2024. The interest is received annually in arrears on 26 September.
During 2019, the Company subscribed to the €300m Non-Preferred Senior loan issued by PTSB to meet the subsidiary’s internal MREL
requirements, which represents down streaming of the proceeds raised by the Company via the external Senior Unsecured issuance.
The terms of the Non-Preferred Senior loan were a placement at a base rate of 2.149% plus a margin of 0.211% per annum maturing on
26 September 2024. The interest is received annually in arrears on 26 September.
The maximum exposure to credit risk for financial assets carried at amortised costs at 31 December 2022 is €911m (31 December 2021:
€604m).
The expected credit losses on these placements were €1m at 31 December 2022 (31 December 2021: €1m).
The fair value of the loans and advances to banks closely equates to their amortised costs.
266
Permanent TSB Group Holdings plc - Annual Report 2022 C. Investment in subsidiary
At 1 January
Additional Investment
AT1 Securities redeemed
Additional Tier 1 securities - net of the transaction costs
Write-back/(Impairment) of investment
At 31 December
31 December
2022
31 December
2021
€m
888
516
-
245
697
2,346
€m
956
-
(2)
-
(66)
888
The Company is the ultimate holding company of the Group while PTSB is a 100% subsidiary of the Company. The investment in PTSB
is carried at the recoverable amount in the holding company’s statement of financial position. At 31 December 2022, the investment
amounted to €2,346m (31 December 2021: €888m).
The Company carries its investment in its subsidiary undertaking at cost and reviews whether there is any indication of impairment
at each reporting date. Impairment testing involves comparing the carrying value of the investment to its recoverable amount. The
recoverable amount is the higher of the investment’s fair value or its value-in-use (VIU).
An impairment charge arises if the carrying value exceeds the recoverable amount and where the carrying value is not supported by the
estimated discounted future cash flows of the underlying business. The recoverable amount of the investment is the higher of its fair
value less costs to sell or it’s VIU. The carrying value of the subsidiary undertaking before the impairment write-back of the investment
was €1,649m. The recoverable amount based on the VIU exceeds the carrying amount after reversal of previous impairment charges. On
this basis, €697m of an impairment write back was recognised for the year (31 December 2021: impairment charge €66m).
Following the completion of the business combination on 7 November 2022 the net assets of PTSB Company increased by €516m
therefore increasing the value of the Investment in subsidiary by Permanent TSB Group Holdings plc. See notes 2 and 3 of the
consolidated financial statements for further detail.
While the recoverable amount based on the VIU exceeds market capitalisation at the 31 December 2022, the depressed share price is a
result of the overall subdued banking environment currently in which the entity operates along with various entity specific factors that
affect the liquidity of the shares.
The VIU is the present value of the future free cash flows expected to be derived from the investment, based upon a VIU calculation that
discounts expected post-tax free cash flows at a discount rate appropriate to the investment.
On 19 October 2022, PTSBGH plc (‘Company’) issued additional €245m AT1 Fixed Rate Reset Perpetual Contingent Temporary Write
Down Securities. The first reset date for the fixed rate is 26 April 2028.
See note 2 to the consolidated financial statements for a sensitivity analysis on the key assumptions used in the calculation.
D. Debt securities in issue
At amortised cost
Bonds and medium-term notes
Maturity analysis
Repayable in less than 1 year
Repayable in greater than 1 year but less than 5 years
Repayable in greater than 5 years
31 December
2022
31 December
2021
€m
€m
658
658
10
648
–
658
352
352
2
350
-
352
Bonds and medium-term notes
In June 2022, PTSBGH issued €300m of Senior Unsecured Medium Term Notes priced at Euro 5 year mid-swaps +375bps, which
equates to a yield of 5.238%, maturing on 30 June 2025. Interest is payable on the nominal amount annually in arrears on the coupon
date.
267
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Notes to the Company Financial Statements
(continued)
E. Subordinated liabilities
At amortised cost
€250m Tier 2 capital notes due August 2031, Callable 2026
Maturity analysis
Repayable in less than 1 year
Repayable in greater than 1 year but less than 5 years
Repayable in greater than 5 years
31 December
2022
31 December
2021
€m
€m
252
252
3
-
249
252
252
252
3
-
249
252
Tier 2 capital notes – PTSBGH
In May 2021, PTSBGH issued €250m of Tier 2 capital notes at a fixed rate of 3% per annum. The notes mature on 19 August 2031 with a
call date of any date from and including 19 May 2026 to and including 19 August 2026 with the call subject to approval of the regulatory
authorities, with approval conditional on meeting the requirements of the EU CRR.
The interest rate will be reset, in the event that the securities are not called, on 19 August 2026 to Euro 5 year Mid Swap rate plus a
margin of 3.221% per annum. The loan is subordinated and ranks as Tier 2 capital with interest paid annually in arrears on 19 August
(short first coupon period). The loan may be subject to the exercise of Irish Statutory loss absorption powers by the relevant resolution
authority.
In the event of winding up of PTSBGH, the Tier 2 capital notes will be:
•
junior in right of payment to all Senior Claims;
• pari passu with all other subordinated claims against PTSBGH which constitute, or would but for any applicable limitation on the
amount of such capital constitute, Tier 2 capital notes or that rank or are expressed to rank pari passu with the obligations of PTSBGH
under Tier 2 capital notes; and
•
in priority to PTSBGH ordinary shares, preference shares and junior subordinated obligations or other securities of PTSBGH which by
law rank, or by their terms are expressed to rank, junior to the Tier 2 capital notes.
F. Share capital and reserves
The share capital of Permanent TSB Group Holdings plc is detailed in note 35 to the consolidated financial statements, all of which
relates to Permanent TSB Group Holdings plc.
G. Related parties
Related parties include individuals and entities that can exercise significant influence on operational and financial policies of the Group.
The Group has a related party relationship with its Directors, Senior Executives, the Group’s pension schemes, the Minister for Finance
and with the Irish Government and Irish Government related entities on the basis that the Irish Government is deemed to have control
over the Group.
Related parties of Permanent TSB plc include subsidiary undertakings, associated undertakings, joint undertakings, post-employment
benefit schemes, Key Management Personnel and connected parties. The Irish Government is also considered a related party by virtue
of its effective control of Permanent TSB. See note 44 of the consolidated financial statements for further details.
At 31 December 2022, the Company had an intercompany balance of €658m (31 December 2021: €352) with its principal subsidiary
PTSB relating to the MREL issuance and €252m (31 December 2021: €252m) relating to Tier 2 capital issuances.
H. Audit Fees
€0.04m audit fees were paid to the auditors, PwC, for services relates to the audit of the financial statements of PTSBGH during the year
to 31 December 2022 (31 December 2021: €0.04m).
268
Permanent TSB Group Holdings plc - Annual Report 2022 APPENDIX
269
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Alternative Performance Measures (unaudited)
The financial performance of the Group is assessed by Management using various financial measures, some of which are not defined
by IFRS and do not have a standard guidance for calculation. Therefore, these measures may not be directly comparable to other peers.
Management believes that these measures provide useful information in assessing the Group’s financial performance. Preference
should be given to IFRS measures over non-IFRS measures when assessing financial performance of the Group.
The definitions and calculation methodology for the Alternative Performance Measures noted below are consistent with the prior year.
1. Underlying profit
The underlying profit is the measure of adjusted profits realised by the Group. This measure is used by the Group for its strategic
planning process and reflects the true economic substance of the Group’s financial performance. The table below details the calculation
of underlying profit. Exceptional items and non-recurring items are excluded from the operating expenses as Management considers
these items as non-reflective of core operating costs.
Operating profit / (loss) per IFRS income statement
Other exceptional items
Non-IFRS adjustments
Other non-recurring items
Underlying profit/(loss) per management income statement
Year ended
Year ended
31 December
2022
31 December
2021
€m
267
(265)
43
45
€m
(21)
23
15
17
Management’s definition of underlying profit excludes exceptional items and other items that Management view as non-recurring. In the
current year, Non-recurring items include the Day 1 ECL booked as part of the purchase of the Ulster Bank transaction and additional
impairment charges that are as a result of deleveraging.
2. Exceptional and Other Non-Recurring Items
A reconciliation of exceptional costs as set out in the financial statements and exceptional and other non-recurring costs as set out in the
Financial Review is detailed below.
Gain on bargain purchase
Restructuring and other costs
Costs incurred in relation to Ulster Bank transaction
Exceptional impairment write-back arising from deleveraging of loans
Exceptional items
Other non-recurring items
Exceptional and other non-recurring items
Source/Cross
Reference
Income Statement
Income Statement
Income Statement
Income Statement
Financial Review
Financial Review
31 December
2022
31 December
2021
€m
(362)
13
92
(8)
(265)
43
(222)
€m
-
14
28
(19)
23
15
38
3. Adjusted cost income ratio
Operating expenses (excluding exceptional, other non-recurring items and regulatory charges) divided by total operating income.
Management considers adjusted cost income ratio to be an important metric to assess the profitability of the Group after adjusting for
non-controllable costs.
Total operating expenses
Exceptional items (included within total operating expenses)
Non-recurring items (included within total operating expenses)
Bank levy
Regulatory charges
Total operating expenses (excluding exceptional, other non-recurring items and
regulatory charges)
Total operating income (excluding gain on bargain purchase)
Adjusted cost income ratio
270
Source/Cross
Reference
Income statement
Financial Review
Note 9
Note 10
Note 10
Financial Review
Income statement
31 December
2022
31 December
2021
€m
509
(105)
(9)
(22)
(29)
344
409
84%
€m
402
(42)
(15)
(22)
(28)
295
361
82%
Permanent TSB Group Holdings plc - Annual Report 2022
4. Headline cost income ratio
Total operating expenses (excluding exceptional items) divided by total operating income. The difference between adjusted cost to
income ratio and headline cost income ratio is due to regulatory charges and bank levy.
Total operating expenses
Exceptional and other non-recurring items
Non-recurring items (included in total operating expenses)
Total operating expenses (excluding exceptional and other non-recurring items)
Total operating income
Headline cost income ratio
Source/Cross
Reference
Income statement
Financial review
Note 9
Income statement
Financial review
31 December
2022
31 December
2021
€m
€m
509
(105)
(9)
395
409
96%
383
(42)
(15)
345
361
96%
5. CET 1 fully loaded basis*
Total common equity tier 1 capital on a fully loaded basis divided by total risk weighted assets on a fully loaded basis. CET1 ratio provides
an insight into how well the Bank can withstand financial stress and remain solvent.
Common equity tier 1
Risk weighted assets
CET 1 fully loaded
31 December
2022
31 December
2021
Fully Loaded
Fully Loaded
€m
€m
1,616
10,627
15.2%
1,265
8,603
14.7%
Source/Cross
Reference
Capital
Management
Capital
Management
Capital
Management
* The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
6. CET 1 transitional basis*
Total CET 1 capital on a transitional basis divided by total RWAs on a transitional basis. CET1 ratio provides an insight into how well the
bank can withstand financial stress and remain solvent.
Common equity tier 1
Risk weighted assets
CET 1 transitional basis
* The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
31 December
2022
31 December
2021
Transitional
Transitional
€m
€m
1,718
10,627
16.2%
1,457
8,600
16.9%
Source/Cross
Reference
Capital
Management
Capital
Management
Capital
Management
271
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Alternative Performance Measures
(continued)
7. Leverage ratio*
The leverage ratio is calculated by dividing Tier 1 capital by gross balance sheet exposures (total assets and off balance sheet exposures).
Leverage ratios give an insight to the Group’s financial health and its capability to meet its financial liabilities and obligations.
Tier 1 Capital
Gross balance sheet exposures
Leverage ratio exposure measure
Leverage ratio
31 December 2022
31 December 2021
Transitional
Fully Loaded
Transitional
Fully Loaded
€m
€m
€m
€m
2,090
1,984
1,580
1,388
25,979
25,876
22,323
22,132
8.0% 7.7%
7.1%
6.3%
Source/Cross
Reference
Capital
Management
Capital
Management
* The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
8. Liquidity coverage ratio (LCR)
Calculated based on the Commission Delegated Regulation (EU) 2015/61. The Group uses this measure to assess the resistance of the
liquidity profile of the Group over a 30 day stressed horizon.
31 December
2022
31 December
2021
Source / Cross
Reference
€m
€m
Liquidity coverage ratio
Financial Review
178%
274%
9. Net stable funding ratio (NSFR)
Defined as the ratio of available stable funding to required stable funding. The NSFR is a liquidity standard requiring banks to hold
sufficient stable funding over a 1 year time horizon. A minimum 100% requirement became binding in June 2022.
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Net stable funding ratio (minimum 100%)
Financial Review
154%
170%
10. Loan to deposit ratio (LDR)
Ratio of loans and advances to customers compared to customer accounts as presented in the statement of financial position. LDR
reflects the Group’s ability to cover loan losses and withdrawals by its customers. Management considers LDR to be an important metric
for assessing liquidity.
Loans and advances to customers
Customer accounts
Loan to deposit ratio
Source / Cross
Reference
31 December
2022
31 December
2021
Note 22
Note 29
€m
€m
19,593
21,730
90%
14,256
19,089
75%
272
Permanent TSB Group Holdings plc - Annual Report 2022
11. Net interest margin (NIM)
NIM is derived by dividing the net interest income by the average interest earning assets. Management considers NIM to be an important
operating metric and reflects the differential yield over the average interest earning assets and cost of funding those assets.
Net interest income
Total average interest earning assets
Net interest margin (NIM)
Source / Cross
Reference
31 December
2022
31 December
2021
Income Statement
Financial Review
€m
€m
362
23,469
1.54%
313
20,731
1.51%
12. Non-performing loans (NPLs)
NPLs are loans which are credit impaired or loans which are classified as defaulted in accordance with the Group’s definition of default.
Management considers NPLs to be an important metric as it reflects the risk profile of the Group.
Residential:
-Home loans
-Buy to let
Commercial
Consumer finance
Non-performing loans
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Note 23
Note 23
Note 23
Note 23
342
270
23
15
650
420
339
44
14
817
13. Foreclosed Assets
Foreclosed assets are defined as assets held on the balance sheet, which are obtained by taking possession of collateral or by calling on
similar credit enhancements.
Foreclosed assets
Note 38
€m
18
€m
28
Source / Cross
Reference
31 December
2022
31 December
2021
14. Non-performing assets (NPAs)
NPAs are NPLs plus foreclosed assets.
Foreclosed assets are defined as assets held on the balance sheet, which are obtained by taking possession of collateral or by calling on
similar credit enhancements.
Non-performing loans
Foreclosed assets
Non-performing assets
Source / Cross
Reference
31 December
2022
31 December
2021
Note 23
Note 38
€m
650
18
668
€m
817
28
845
273
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Alternative Performance Measures
(continued)
15. Return on equity
Loss for the year after tax (before exceptional items) expressed as a percentage of total average equity. Management considers return on
equity to be an important metric for assessing profitability.
Profit / (Loss) for the year after tax
Exceptional items and other non-recurring items
Profit/(loss) for the period after tax (before exceptional items)
Total average equity
Return on equity
16. Risk weighted assets (RWAs)
RWAs are the Group’s assets or off balance sheet exposures, weighted according to risk.
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Income Statement
Financial Review
Financial Review
223
(222)
1
1,885
0.05%
(20)
38
18
1,853
0.97%
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Risk weighted assets
Note 39
10,627
8,600
17. Total capital ratio (fully loaded basis)*
The total capital ratio is the ratio of a bank’s total capital (Tier 1 and Tier 2 capital) to its RWAs.
Tier 1 Capital
Tier 2 Capital
Total Capital
Risk weighted assets
Total capital ratio (fully loaded basis)
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Capital
Management
Capital
Management
Capital
Management
Capital
Management
Capital
Management
1,985
282
2,267
10,627
21.3%
1,388
290
1,678
8,603
19.5%
*The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
18. Total capital ratio (transitional basis)*
The total capital ratio is the ratio of a bank’s total capital (Tier 1 and Tier 2 capital) to its RWAs.
Tier 1 Capital
Tier 2 Capital
Total Capital
Risk weighted assets
Total capital ratio (transitional basis)
*The full year loss recognised in the year end capital ratios remain subject to approval by the Regulator.
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Capital
Management
Capital
Management
Capital
Management
Capital
Management
Capital
Management
2,087
282
2,372
10,627
22.3%
1,580
290
1,870
8,600
21.8%
274
Permanent TSB Group Holdings plc - Annual Report 2022
19. Average interest earning assets
Interest earning assets include loans and advances to banks, loans and advances to customers, debt securities and derivative assets.
Average balances on interest earning assets are calculated as the average of the monthly interest earning asset balances from
December 2021 to December 2022, thirteen months in total.
Average interest earning assets
Loans and advances to banks
Loans and advances to customers
Debt securities and derivative assets
Total average interest earning assets
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Financial Review
Financial Review
Financial Review
5,521
15,099
2,849
23,469
3,940
14,258
2,533
20,731
20. Average interest bearing liabilities
Interest bearing liabilities include customer accounts, deposits by banks, debt securities in issue, and lease liabilities.
Average balances on interest bearing liabilities are calculated as the average of the monthly interest bearing liabilities balances from
December 2021 to December 2022, thirteen months in total.
Average interest bearing liabilities
Customer accounts
Debt securities in issue and derivative financial instruments
Lease liabilities
Subordinated liabilities
Deposits by banks
Total average interest bearing liabilities
Source / Cross
Reference
31 December
2022
31 December
2021
€m
€m
Financial Review
Financial Review
Financial Review
Financial Review
Financial Review
20,171
628
29
252
1,377
22,457
18,606
705
31
155
134
19,631
21. Average yield on average interest earning assets
Average yield on average interest earnings assets is defined as the average interest income on interest earning assets, divided by the
total average interest earning assets balances.
Average interest income on interest earning assets is calculated as the average of the interest income arising on each of the interest
earning assets from December 2021 to December 2022, thirteen months in total.
31 December
2022
31 December
2021
Source / Cross
Reference
€m
€m
Average interest income on interest earning assets
Loans and advances to customers
Debt securities and derivative assets
Loans and advances to banks
Total average interest income from interest-earning assets
Negative interest earning assets – loans and advances to banks
Total average interest from assets
Total average earning assets
Average yield on average interest earning assets
Financial Review
Financial Review
Financial Review
Financial Review
Financial Review
Financial Review
387
15
15
417
-
417
23,469
1.79%
346
7
-
353
(14)
339
20,731
1.64%
275
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022
Alternative Performance Measures
(continued)
22. Average rate on average interest bearing liabilities
Average rate on average interest bearing liabilities is defined as average interest expense on interest bearing liabilities divided by the total
average interest bearing liabilities balances.
Average interest expense on interest bearing liabilities is calculated as the average of the interest expense arising on each of the interest
bearing liabilities from December 2021 to December 2022, thirteen months in total.
Average interest expense on interest bearing liabilities
Customer accounts
Debt securities in issue
Subordinated liabilities
Deposits by banks
Total average interest income on interest bearing liabilities
Negative interest earning liabilities – deposits by banks
Total average interest from liabilities
Total average bearing liabilities
Average rate on average interest bearing liabilities
31 December
2022
31 December
2021
Source / Cross
Reference
€m
€m
Financial Review
11
14
Financial Review
Financial Review
Financial Review
Financial Review
Financial Review
16
8
20
55
-
55
22,457
0.24%
8
5
-
27
(1)
26
19,631
0.13%
23. NPLs as % of gross loans
NPLs as % of gross loans are defined as NPLs divided by gross loans and advances to customers. Management considers NPLs as % of
gross loans to be an important metric as it reflects the risk profile of the Group.
Non-performing loans
Gross loans and advances to customers
NPLs as % of gross loans
31 December
2022
31 December
2021
Source / Cross
Reference
€m
€m
Note 23
Note 23
650
19,804
3.3%
817
14,745
5.5%
24. Average equity attributable to owners
This is an average of the equity position of each individual month from December 2021 to December 2022, thirteen months in total.
Management considers average equity attributable to owners to be an important metric for assessing profitability and generation of
returns from its investments.
Average equity attributable to owners
Financial Review
1,885
1,853
31 December
2022
31 December
2021
Source / Cross
Reference
€m
€m
276
Permanent TSB Group Holdings plc - Annual Report 2022
Abbreviations
The following information has not been
subject to audit by the Group’s Independent
Auditor.
ALCO Asset and Liability Committee
AFS Available For Sale
AGM Annual General Meeting
AIMRO Association of Irish Market
Research Organisations
ALM Asset Liability Management
API Application Programming Interfaces
ASAI Advertising Standards Association
of Ireland
AT1 Additional Tier 1
BAC Board Audit Committee
BCM Business Continuity Management
BITCI Business in the Community Ireland
BRCC Board Risk and Compliance
Committee
BRRD Banking Recovery and Resolution
Directive
BTL Buy-to-let
C&M Classification & Measurement
CAC Capital Adequacy Committee
CBI Central Bank of Ireland
CCB Capital Conservation Buffer
CCMA Code of Conduct on Mortgage
Arrears
CCyB Counter Cyclical Buffer
CDF Career Development Framework
CEO Chief Executive
CFO Chief Financial Officer
CET 1 Common Equity Tier 1
CFP Contingency Funding Plan
CODM Chief Operating Decision Maker
CPI Consumer Price Index
CRD IV Capital Requirements Directive IV
CRE Commercial Real Estate
CRO Chief Risk Officer
CRR Capital Requirements Regulation
CSAs Credit Support Annex
CSO Central Statistics Office
CSR Corporate Social Responsibility
CVA Credit Valuation Adjustment
DDI Debt to Disposable Income
DGS Deposit Guarantee Scheme
DIRT Deposit Interest Retention Tax
DoF Department of Finance
DTA Deferred Tax Asset
DVA Debit Valuation Adjustment
EAR Earnings at Risk
EBA European Banking Authority
EC European Commission
ECAI External Credit Assessment
Institution
ECB European Central Bank
ECL Expected Credit Loss
EIR Effective Interest Rate
ELG Eligible Liabilities Guarantee
ESG Environmental Social Governance
ESMA European Securities and Markets
Authority
ESRI Economic & Social Research Institute
EU European Union
EV Economic Valuation
EWI Early Warning Indicator
ExCo Executive Committee
FIA Financial Incentives Agreement
FLI Forward looking information
FSPO Financial Services and Pensions
Ombudsman Bureau of Ireland
FTE Full Time Equivalent
FVOCI Fair value through other
comprehensive income
FVTPL Fair value through profit or loss
FX Foreign Exchange
GCC Group Credit Committee
GDP Gross Domestic Product
GIA Group Internal Audit
GPPC Global Public Policy Committee
GRC Group Risk Committee
GRMA Group Risk Management
Architecture
GRMF Group Risk Management Framework
HFT Held for Trading
HICP Harmonised Index of Consumer
Prices
HPI House Price Index
HTC Hold to Collect
HTC&S Hold to Collect and Sell
HTM Held to Maturity
HQLA High Quality Liquid Assets
IAS International Accounting Standards
IASB International Accounting Standards
Board
IBCB Irish Banking Culture Board
IBNR Incurred But Not Reported
ICAAP Internal Capital Adequacy
Assessment Process
IFRIC International Financial Reporting
Standards Interpretations Committee
IFRS International Financial Reporting
Standards
IIA Institute of Internal Auditors
ILAAP Internal Liquidity Adequacy
Assessment Process
IMF International Monetary Fund
IOB Institute of Banking
IOM Isle of Man
IPP Integrated Planning Process
IRB Internal rating based approach
IRRBB Interest Rate Risk in the Banking
Book
ISA International Standards on Auditing
ISDA International Swaps and Derivatives
Association
LCR Liquidity Coverage Ratio
LDR Loan to Deposit Ratio
LGD Loss Given Default
L&R Loans and Receivables
LSI Less Significant Institution
LTIP Long Term Incentive Plan
LTV Loan to value
MCO Maximum Cumulative Outflow
MGC Model Governance Committee
MREL Minimum Requirement for own
funds and Eligible Liabilities
MRP Mortgage Redress Programme
MTN Medium Term Note
MTP Medium Term Plan
NCU Newbridge Credit Union
NII Net Interest Income
NIM Net Interest Margin
NPL Non Performing Loan
NPS Net Promoter Score
NSFR Net Stable Funding Ratio
OCI Other Comprehensive Income
OTC Over the counter
P2G Pillar 2 Guidance
P2R Pillar 2 Requirement
PBI PBI Limited (formerly Permanent Bank
International Limited)
PD Probability of Default
PDH Principal Dwelling House
POCI Purchased or Originated Credit
Impaired
PSD2 Payment Services Directive 2
PTSB Permanent TSB plc.
PTSBGH Permanent TSB Group Holding
plc.
PwC PricewaterhouseCoopers
RAF Risk Appetite Framework
RAS Risk Appetite Statement
RCA Root Cause Analysis
RCSA Risk and Control Self Assessment
RMBS Residential Mortgage Backed
Securities
RNPS Relationship Net Promoter Score
ROI Republic of Ireland
RP Restructuring Plan
RPA Robotic Process Automation
RPPI Residential Property Price Index
RWA Risk Weighted Assets
SBCI Strategic Banking Corporation of
Ireland
SE Structured Entities
SEAI Sustainable Energy Authority of
Ireland
SEI Social Entrepreneurs Ireland
SFS Standard Financial Statement
SFT Securities Financing Transaction
SICR Significant increase in Credit Risk
SID Senior Independent Director
SME Small and medium sized enterprises
SOFP Statement of Financial Position
SPP Strategic Performance Priorities
SPPI Solely Payments of Principle and
Interest
SPV Special Purpose Vehicle
SREP Supervisory Review & Evaluation
Process
SSM Single Supervisory Mechanism
TCPID Trinity Centre for People with
Intellectual Disabilities
TME Tracker Mortgage Examination
TRIM Targeted Review of Internal Models
UK United Kingdom
VIP Values in Practice
VIU Value in Use
WTO World Trade Organisation
277
Strategic ReportGovernance Financial StatementsGeneral InformationPermanent TSB Group Holdings plc - Annual Report 2022 Definitions
The following information has not been
subject to audit by the Group’s Independent
Auditor.
AFS Available for sale (AFS) are non
derivative financial investments that are
designated as available for sale and are not
classified as a (i) loan receivable (ii) held
to maturity investments or (iii) financial
assets at fair value through profit or loss.
Arrears Arrears relates to any interest
or principal payment on a loan which
has not been received on its due date.
When customers are behind in fulfilling
their obligations with the result that an
outstanding loan is unpaid or overdue, they
are said to be in arrears.
Basel III Basel III is a global, voluntary
regulatory framework on bank capital
adequacy, stress testing and market
liquidity risk.
Basis point One hundredth of a per cent
(0.01%), so 100 basis points is 1%. It is the
common unit of measure for interest rates
and bond yields.
Brexit is an abbreviation of the term
“British Exit”. It refers to the United
Kingdom’s withdrawal from the European
Union.
Buy-to-let Residential mortgage
loan provided to purchase residential
investment property to rent it out.
CET 1 ratio Ratio of a bank’s core equity
capital compared to its total risk-weighted
assets.
Company Permanent TSB Group Holdings
plc or PTSBGH
Commercial property Commercial
property lending focuses primarily on the
following property segments:
a) Apartment complexes;
b) Develop to sell;
c) Office projects;
d) Retail projects;
e) Hotels; and
f) Selective mixed-use projects and special
purpose properties.
278
Common Equity Tier 1 Common Equity
Tier 1 (CET1) capital is recognised as the
highest quality component of capital.
It is subordinated to all other elements
of funding, absorbs losses as and when
they occur, has full flexibility of dividend
payments and has no maturity date. It
is predominately comprised of common
shares; retained earnings; undistributed
current year earnings; but may also
include non-redeemable, non-cumulative
preferred stock.
Concentration risk The risk that any single
(direct or indirect) exposure or group of
exposures has the potential to produce
losses large enough to threaten the
institution’s health or its ability to maintain
its core business.
Contractual Maturity Date on which a
scheduled payment is due for settlement
and payable in accordance with the terms
of a financial instrument.
CVA Credit Valuation Adjustment (CVA)
is the difference between the risk-free
portfolio value and the true portfolio value
that takes into account the possibility of a
counterparty’s default.
Customer accounts Money deposited
with the Group by counterparties other
than banks and classified as liabilities.
This includes various types of unsecured
deposits, credit current and notice
accounts.
Debt securities Instruments representing
certificates of indebtedness of credit
institutions, public bodies and other
undertakings. Debt securities can be
secured or unsecured.
Debt securities in issue Transferable
certificates of indebtedness of the Group to
the bearer of the certificates. They include
commercial paper, certificates of deposit,
bonds and medium-term notes.
Cost to income ratio Total operating
expense divided by total operating income.
Credit Default Risk The event in which
companies or individuals will be unable to
make the required payments on their debt
obligations.
Default When a customer fails to make
timely payment of interest or principal on
a debt security or to otherwise comply
with the provisions of a bond indenture.
Depending on the materiality of the default,
if left unmanaged it can lead to loan
impairment.
CRD Capital Requirements Directives
(CRD) is statutory law implemented by the
European Union for capital adequacy. CRD
have introduced a supervisory framework
in the European Union which reflects
the Basel II and Basel III rules on capital
measurement and capital standards.
Credit-related commitments
Commitments to extend credit, standby
letters of credit, guarantees and
acceptances which are designed to meet
the requirements of the customers.
Credit risk The risk of loss resulting from
a counterparty being unable to meet
its contractual obligations to the Group
in respect of loans or other financial
transactions.
Credit Risk Mitigation Methods to reduce
the credit risk associated with an exposure
by the application of credit risk mitigants.
Examples include: collateral; guarantee;
and credit protection.
DVA Debt Valuation Adjustments (DVA)
an adjustment made by an entity to the
valuation of over-the-counter derivative
liabilities to reflect, within fair value, the
entity’s own credit risk.
Eurozone The Eurozone, is a monetary
union of 19 of the 28 European Union
(EU) member states which have adopted
the euro (€) as their common currency
and sole legal tender. The other nine
members of the European Union continue
to use their own national currencies. The
Eurozone consists of Austria, Belgium,
Cyprus, Estonia, Finland, France, Germany,
Greece, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, the Netherlands,
Portugal, Slovakia, Slovenia and Spain.
Exposure at Default Exposure at default
(EAD) is the gross exposure under a facility
upon default of an obligor.
Fair value The price that would be received
to sell an asset, or paid to transfer a liability,
in an orderly transaction between market
participants at the measurement date.
Permanent TSB Group Holdings plc - Annual Report 2022 Forbearance Forbearance occurs when
a borrower is granted a temporary or
permanent concession, or agreed change
to a loan, for reasons relating to the actual
or apparent financial stress or distress
of that borrower. Forbearance strategies
are employed in order to improve the
management of customer relationships,
maximise collection opportunities and, if
possible, avoid foreclosure or repossession.
Such arrangements can include extended
payment terms, a temporary reduction in
interest or principal repayments, payment
moratorium and other modifications.
Foreclosed assets Foreclosed assets are
defined as assets held on the balance
sheet and obtained by taking possession
of collateral or by calling on similar credit
enhancements.
Foreign currency exchange risk The risk
of volatility in earnings resulting from
the retranslation of foreign currency (e.g.
Sterling and US dollar) denominated assets
and liabilities from mismatched positions.
GDP Gross Domestic Product (GDP) is a
monetary measure of the value of all final
goods and services produced in a period of
time (quarterly or yearly). GDP estimates
are commonly used to determine the
economic performance and standard of
living of a whole country or region, and to
make international comparisons.
Group Permanent TSB plc Group Holdings
plc and its subsidiary undertakings.
Guarantee A formal pledge by the Group to
pay debtor’s obligation in case of default.
HTM Held to maturity (HTM) non derivative
financial assets with fixed or determinable
payments and fixed maturity that an entity
has the positive intention and ability to hold
to maturity.
ILAAP Internal Liquidity Adequacy
Assessment Process (ILAAP) is a
supervisory review and an evaluation
process to assess the Group’s own
calculations and the adequate liquidity
which the Group consider necessary to
cover the risks they take and which they
are exposed to.
IRBA The Internal Ratings Based Approach
(IRBA) allows banks to use their own
estimated risk parameters for the purpose
of calculating regulatory capital for credit
risk to estimate probability of default
(PD), loss given default (LGD), exposure
at default (EAD), maturity (M) and other
parameters required to arrive at the total
risk weighted assets (RWA).
ISDA Master Agreements A standard
agreement used in over-the-counter
derivatives transactions. The ISDA Master
Agreement, published by the International
Swaps and Derivatives Association
(ISDA), is a document that outlines the
terms applied to a derivatives transaction
between two parties. Once the two parties
agree to the standard terms, they do
not have to renegotiate each time a new
transaction is entered into.
Loan to deposit ratio The ratio of loans
and receivables compared to customer
accounts, as presented in the statement of
financial position.
LCR Liquidity Coverage Ratio (LCR) is the
ratio to ensure that bank has an adequate
amount of high quality liquid assets in
order to meet short-term obligations under
a stress scenario lasting for 30 days. The
LCR will be phased in over a number of
years, with credit institutions obliged to
hold 60% of their full LCR in 2015, 70% in
2016, 80% in 2017 and 100% in 2018, as
per CRD IV.
Home loan A loan provided by a bank,
secured by a borrower’s primary residence
or second home.
LGD Loss Given Default (LGD) is the share
of an asset that is lost when a borrower
defaults on a loan.
Hybrid A combination of two or more
forbearance arrangements.
ICAAP Internal Capital Adequacy
Assessment Process (ICAAP) is a
supervisory review and an evaluation
process to assess the Group’s own
calculations and the adequate capital
which Group considers necessary to cover
the risks they take and which they are
exposed to.
Liquidity risk The risk that the Group may
experience difficulty in financing its assets
and/or meeting its contractual obligations
as and when they fall due, without incurring
excessive cost.
LTV Loan to Value (LTV) is a lending risk
assessment ratio of mortgage amount to
value of property.
Market risk The risk of change in fair value
of a financial instrument due to adverse
movements in equity prices, property
prices, interest rates or foreign currency
exchange rates.
Medium term notes Medium term notes
(MTNs) are debt notes issued by the Group
which usually mature in five to ten years.
They can be issued on a fixed or floating
coupon basis.
NAMA National Asset Management
Agency (NAMA) was established in 2009
as one of a number of initiatives taken by
the Irish Government to address the Irish
financial crisis and the deflation of the Irish
bubble.
NII Net Interest Income (NII) is the
difference between interest earned on
assets and interest paid on liabilities.
NIM Net Interest Margin (NIM) is a
performance metric that measures the
difference between interest income
generated on lending and the amount of
interest paid on borrowings relative to the
amount of interest-earning assets.
Non-performing assets Non-performing
assets are defined as NPLs plus foreclosed
assets.
NPLs Non-performing loans are loans
which are credit impaired or loans which
are classified as defaulted, in accordance
with the Group’s definition of default. The
Group’s definition of default considers
objective indicators of default including
the 90 days past due criterion, evidence of
exercise of concessions or modifications
to terms and conditions; and are designed
to be consistent with European Banking
Authority (EBA) guidance on the definition
of forbearance.
NSFR Net Stable Funding Ratio (NSFR) is
designed to act as a minimum enforcement
mechanism to complement the shorter
term focused liquidity coverage ratio.
Operational Risk The risks inherently
present in the Group’s business, including
the risk of direct or indirect loss resulting
from inadequate or failed internal and
external processes or systems and human
error, fraud, or from external events.
PD Probability of Default (PD) is a financial
term describing the likelihood that a
borrower will be unable to meet its debt
obligations.
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(continued)
Repurchase agreement A short term
funding agreement that allows a borrower
to create a collateralised loan by selling
a financial asset to a lender. As part of
the agreement, the borrower commits to
repurchase the security at a date in the
future repaying the proceeds of the loan.
For the counterparty to the transaction, it is
termed a reverse repurchase agreement or
a reverse repo.
Structured securities Structured
securities are complex lending
arrangements created to meet needs that
cannot be met from traditional financial
instruments available in the markets,
through the structuring of assets or debt
issues in accordance with customer and/
or market requirements. Structured debt
securities have the potential to decrease
risk, create liquidity, and increase yield.
Tier 1 capital A term used to describe the
capital adequacy of a bank. Tier 1 capital
is core capital; this includes equity capital
and disclosed reserves.
Tier 2 capital Tier 2 capital is
supplementary bank capital that includes
items such as revaluation reserves,
undisclosed reserves, hybrid instruments
and subordinated term debt.
Tracker mortgage A mortgage which
follows the base rate of interest set by the
European Central Bank and will be fixed at
a certain percentage above this rate.
RMBS Residential Mortgage Backed
Securities (RMBS) are debt obligations that
represent claims to the cash flows from
pools of mortgage loans, most commonly
on residential property.
RWAs Risk weighted assets (RWAs) is a
measure of amount of bank’s assets or
off-balance sheet exposures which are
weighted according to risk on prescribed
rules and formulas as defined in the under
Basel Banking Accord.
Securitisation Securitisation is the
process of taking an illiquid asset, or
group of assets, and through financial
engineering, transforming them into a
security.
Settlement Risk The risk that the
Group delivers a sold asset or cash to a
counterparty and then does not receive the
corresponding cash or purchased asset as
expected.
SSM The Single Supervisory Mechanism
(SSM) is a mechanism which has granted
the European Central Bank (ECB) a
supervisory role to monitor the financial
stability of banks based in participating
states. The main aims of the SSM are to
ensure the safety and soundness of the
European banking system and to increase
financial integration and stability in Europe.
SPE/SPV Special purpose entity (SPE)
is a legal entity which can be a limited
company or a limited partnership created
to fulfil specific or temporary objectives.
SPEs are typically used by companies to
isolate the firm from financial risk. This
term is used interchangeably with SPV
(Special Purpose Vehicle).
Stress testing A technique used to
evaluate the potential effects on an
institution’s financial condition of an
exceptional but plausible event and/or
movement in a set of financial variables.
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We are a community serving the communityMembers of the Irish Olympic Team and the Irish Paralympic Team pictured at the launch of Permanent TSB’s title sponsorship of Team Ireland for the 2024 Games in Paris.