Annual Report 2024
Permanent TSB Group Holdings plc
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. Material economic assumptions underlying the
forward looking statements are discussed further in Market and Regulatory 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.
Strategic Report
Financial Highlights
2
Non-Financial Highlights
3
Chair’s Statement
5
Chief Executive Review
7
Market and Regulatory Context
10
Our Strategy, Business Model and Culture
12
Financial Review
21
Capital Management
30
Risk Management
33
Corporate Governance
Directors’ Report
68
Corporate Governance Statement
74
Directors’ Report on Remuneration
125
Statement Of Directors Responsibilities
130
Sustainability
Sustainability
132
Sustainability Statement Responsibility Statement
136
Independent Practitioner’s Limited Assurance Report
137
Sustainability Statement
140
Annex VI - Template for the KPIs of credit institutions
238
Task Force on Climate related Financial Disclosures
276
Consolidated Financial Statements
Independent Auditor’s Report
292
Consolidated Financial Statements
300
Notes to the Consolidated Financial Statements
306
Company Financial Statements
Company Financial Statements
402
Notes to the Company Financial Statements
406
General Information
Alternative Performance Measures
410
Abbreviations
418
Contents
Strategic Report
Governance
Sustainability
Financial Statements
General Information
14.7%
14.0%
15.2%
2024
2023
2022
1.8%
3.3%
3.3%
2024
2023
2022
€11,494m
€11,546m
€10,627m
2024
2023
2022
66%
84%
74%
2024
2023
2022
€24.1bn
€23.0bn
€21.7bn
2024
2023
2022
€180m
2024
€166m
€45m
2023
2022
2.20%
2.32%
1.54%
2024
2023
2022
€159m
2024
€79m
€267m
2023
2022
7.5%
6.5%
1.4%
2024
2023
2022
Financial Performance
Financial Highlights
Underlying profit €m (a)
2024: €180m
Adjusted cost to income ratio (d)
2024: 74%
CET Ratio (fully loaded basis) (f)
2024: 14.7%
Net interest margin % (b)
2024: 2.20%
Customer deposits (e)
2024: €24.1bn
NPL Ratio (g)
2024: 1.8%
Return on tangible equity % (c)
2024: 7.5%
Risk weighted assets (RWA) (h)
2024: €11,494m
Profit before taxation
2024: €159m
Transformation and simplification
Asset Quality
(a) Operating profit before exceptional and other non-recurring items. See table 1 on page 410 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 after tax less AT1 coupons paid (before exceptional and non-recurring items) expressed as a percentage of targeted CET1 capital.
(d) Defined as total operating expenses (excluding exceptional and other non-recurring items) divided by total operating income.
(e) Defined as the total of current accounts, retail deposits and corporate deposits.
(f) Total common equity tier 1 (CET 1) capital on a fully loaded 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.
PTSB Group Holdings plc - Annual Report 2024
2
Non-Financial Highlights
Environmental
Increased focus on
Sustainability and Climate-
related and Environmental
Risk, with a Board approved
Sustainability Strategy
aligned to the Sustainable
Development Goals (SDGs)*
c.€875 million in green lending
during 2024 +28% YoY,
accounting for 43% of new
Mortgage Lending
First lender to participate
in the SBCI’s Home Energy
Upgrade Loan Scheme,
offering €100 million in loans
Participation in the SBCI’s
Growth and Sustainability
Loan Scheme, offering €70m
in loans
Inaugural €500m Green
Senior HoldCo notes issued
under the Bank’s Green Bond
Framework
Developing the Bank’s
Science-Based Targets (SBTs)
in line with the Science Based
Target Initiative’s (SBTi) V2
Guidance and preparing
a corresponding Carbon
Reduction Plan
Social
c.€19.4 million in funding
provided to the Social
Finance Foundation since
2009**
c.€360,000 in charitable
giving through the PTSB
Community Fund in 2024,
which included matched
funding by the Bank
Multi-year partnership with
AsIAm – Ireland’s Autism
Charity
First Bank in Ireland to
receive Autism-Friendly
Branch accreditation
More than 2000
volunteering hours provided
on the ground last year,
equating to c.€67,000 of in-
kind giving
76% Culture Index Score,
6% above our Culture Index
Target of 70%
Relationship Net Promoter
Score (RNPS)*** +10% YoY
Governance
Appointment of a Chief
Sustainability and
Corporate Affairs Officer
to deliver on the Bank’s
Sustainability Strategy
60% Female Board Gender
Composition and 40% of
Senior Leadership positions
filled by Women
Issuance of the Bank’s
Inaugural Sustainability
Statement
A ‘Low’ ESG Risk Rating
through Sustainalytics
Certified with the ‘Business
Working Responsibly Mark’
for the second time
* The United Nation’s Sustainable Development Goals (SDGs) were launched in 2015 to provide a plan of action for people, planet and prosperity. While we
recognise that we may contribute to all 17 SDGs in some way, we have identified 6 as being core to our Strategy.
** The Social Finance Foundation was established in 2007 by the Irish Government to address the needs of community organisations and social enterprises for loan
funding which was difficult to obtain from mainstream financial institutions. Acting as a ‘wholesaler’, it provides funding to its lending partners Clann Credo and
Community Finance Ireland.
*** A Relationship Net Promoter Score (RNPS) measures the willingness of customers to recommend a company’s products or services to others.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Our Commitment to Building a
Sustainable Business
Our Purpose is to work
together to build trust with our
customers and communities.
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.
Ambitions For 2025 and Onwards
Continue to embed PTSB’s Sustainability Strategy and
evolve the Bank’s Sustainability Maturity.
Increase our focus on ESG Risk management.
Receive validation for our SBTs and Carbon Reduction
Plan from the Science Based Target Initiative.
Elevate our social impact through lending and
partnerships and continuing to support local
communities through our PTSB Community
programming.
Partner with small businesses through our Business
Banking Strategy.
Ensure strong corporate governance, compliance, and
fair business conduct.
Non-Financial Highlights
Chair’s Statement
Our 2024 results show we are reporting
a robust financial performance and
increased profitability. Our underlying
profit before tax has increased by 8%
to €180 million in 2024, while our profit
before tax has doubled to €159 million.
The Bank is competing strongly in the
mortgage market, with significant progress
being made notably in the second half of
the year.
We do not underestimate the responsibility
we have in supporting hundreds of
thousands of customers own their
own homes, and have invested in
the development of both compelling
propositions and digital and in-person
support to ensure a superior customer
experience.
With new mortgage lending in H2’2024
95% ahead of H1’2024, customers
are showing a clear appetite for the
competitive alternative service model that
PTSB offers to the Irish market.
Our results in 2024 also demonstrate the
benefit of our investments in diversifying
our business. We have experienced
significant growth in our business banking
book, with our SME book growing by 16%
and our Asset Finance book growing by
4%. We are also diversifying our income
streams, with net fee and commission
income up 31% compared with 2023.
Given the interest rate environment we are
operating within, we know that prudent
cost management, ongoing operational
efficiency, and income diversification
are more important than ever. For this
reason, they are key components of our
refreshed business strategy which will
see us grow our business further, driving
sustainable profitability for the Bank and
its shareholders.
Our strategy will see us capitalise on
what is different about PTSB. On the
‘Altogether more human’ proposition we
provide to customers throughout Ireland.
A proposition that is rich in heritage with
deep roots in our communities, while also
being modern and contemporary, offering
both digital and human support.
Governance and management
In my role as Chair, one of my priority
areas of focus is to ensure that the
Bank not only has a robust corporate
governance structure in place, but also
that it continuously evolves to ensure it
aligns to the needs and objectives of the
evolving organisation.
PTSB has been through a period of
significant transformation over the past
three years, including being recognised
as an ‘Other Systemically Important
Institution’.
To ensure that the Bank can continue
to meet the increased expectations
of its stakeholders, throughout 2024
we implemented a plan to improve the
effectiveness of governance at Board
and Executive level. This included
enhancements to our strategic planning,
our risk management processes and
capabilities, our data and technology, and
embedding sustainability further into the
business. These are outlined in further
detail in my introduction to the Corporate
Governance Statement on page 74.
I am pleased with the strong progress we
have made in these areas, and the culture
of continuous improvement that has been
fostered which will see that momentum
continue in the years to come.
And we are making this progress despite
the challenging economic conditions and
cost of living pressures that have been
prevalent over the past few years. While
the Irish economy is showing steady
growth and lower inflation, we recognise
that we are in an era of increasing geo-
political tensions, and associated geo-
economic risks are rising.
Given these challenges, it is more
important than ever that we continue to
strengthen our corporate governance
and the way we collectively serve our
customers to meet the needs and
expectations of all stakeholders.
Key to that is ensuring that we as a Bank
are reflective of the communities that we
serve.
In my statement last year, I referenced
the implementation of a comprehensive
Diversity, Equity & Inclusion (DEI) strategy
and our ambition being to ensure
that everyone, regardless of gender,
age, ethnicity, orientation, ability or
socioeconomic status, can feel that they
have true equality of opportunity and
influence at PTSB.
PTSB delivered a strong performance throughout 2024.
As a purpose-driven organisation, we are committed to
working together to build trust with our customers and
communities. We are meeting personal and business
customer needs through our competitive and innovative
propositions, and we are well placed to continue to drive
sustainable business growth and deliver for the Bank
and its shareholders in 2025 and beyond.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
5
In recent times, I have observed that some
organisations are relaxing their approach
towards DEI, stepping back from the
previous ambitious targets they committed
to. I want to be clear that PTSB remains
steadfast in our commitment to building
a Diverse, Equitable, and Inclusive culture
for all colleagues. I fundamentally believe
that in doing so, we will build a stronger
and better bank, which in turn will deliver
value for all our stakeholders. As such, this
remains a priority for me, the Board and
wider management team.
While there is still more work to be done,
we have made significant progress in this
area. In 2024, we achieved 60% female
representation at Board level, and 40% of
our Senior Leadership team positions are
now filled by women.
Our leadership team and colleagues alike
champion our collective commitment
to DEI through their participation in the
Bank’s Employee Resource Groups (ERG).
Each ERG is sponsored by an Executive
Committee member and their respective
committees comprise of colleagues at all
levels from across the organisation who
volunteer to drive internal and external
initiatives in advancing all aspects of DEI
within the organisation.
The benefit and impact of colleague-led
initiatives such as this is evident through
our Culture Index Score and our colleague
Trust score, both of which are above
target.
Our progress has also been recognised
externally, with the Bank successfully
achieving the IBEC KeepWell Mark™ in
2024, a national health and wellbeing
evidence-based accreditation that
recognises organisational commitment to
employee well-being, safety and health.
So, as I reinforce my personal commitment
to DEI, I am extremely proud of the
work being done in PTSB, and have
every confidence that the Bank and
its colleagues will continue to go from
strength to strength in this regard and
that PTSB will be the better for it.
Outlook
Notwithstanding geo-political challenges,
the Irish economy remains resilient, and
PTSB will continue to thrive.
As we deliver our refreshed business
strategy between now and 2027, we will
deepen customer relationships, diversify
our income, and differentiate through
customer experience. We will do this by
driving continuous operational efficiencies
and prudent cost management so we
can continue to grow and generate
sustainable returns for our shareholders.
Looking ahead to 2025, I am confident
that the foundations we have built over
the past number of years have put us in
prime position to provide much needed
competition in the market. We have the
people, the capability, the technology, the
strategy, and above all else, the Ambition
to be successful in doing so.
I would like to express my gratitude to my
colleagues across the Bank, led by our
Chief Executive, Eamonn Crowley, who
show up each and every day to deliver for
our customers. Whether in our branches,
our contact centres, our support offices or
our headquarters, their commitment and
customer-focus is at the heart of what
makes PTSB ‘Altogether more human’, and
will see us continue to prosper and grow
into the future.
Julie O’Neill
Chair
Chair’s Statement
(continued)
“Looking ahead
to 2025, I am
confident that the
foundations we
have built over the
past number of
years have put us
in prime position
to provide
much needed
competition in
the market. We
have the people,
the capability,
the technology,
the strategy, and
above all else,
the Ambition to
be successful in
doing so.”
PTSB Group Holdings plc - Annual Report 2024
6
Chief Executive Review
Introduction
2024 marked another year of significant
progress for PTSB, and we are set to build
on that strong progress in 2025.
Fundamental to that progression, is
focusing on delivering the right customer
outcomes and exceptional customer
experiences. We firmly believe that
doing so will be of benefit not only to
our customers, but also to our wider
stakeholders, including our shareholders.
As such, since the launch of our new
brand and business repositioning in
October 2023, our focus throughout 2024
has been on driving the business forward
by putting our customers at the heart of
our decision making, and delivering on our
promise of being ‘Altogether more human’.
This promise, to bring the best of
technology and our people together to
deliver a better banking experience for
our customers, is how we differentiate
ourselves from our competitors. It is our
commitment to putting customer needs at
the centre of how we think, plan, design
and deliver for them, whether that’s
through our voice, digital or in-person
channels, or a combination of them all.
Throughout 2024, we introduced a
range of new products and competitive
rate changes to meet our customers’
needs. We launched a new 32-Day
Notice deposit product for our business
customers, and for our personal
customers, we launched our innovative
Interest-First deposit account.
We implemented a number of competitive
changes to our personal deposit rates
and to our mortgage fixed-rates, both of
which included market-leading rates. We
have continued the momentum in this
area with further market-leading rates
announced in January 2025 to ensure
that we remain a competitive force for
mortgage customers, while also extending
our 2% monthly cash back offer to all
current account customers, whether they
are existing or new customers.
We have continued to invest in our
technology, strengthening our core
systems so we provide a secure and
resilient service for the ultimate benefit
of all our customers. Customers
are responding positively to these
investments, with mortgage drawdowns
through our online portal increasing by
87% in 2024 compared with 2023 and
€410m of new business savings and
deposit accounts opened through our
digital channels.
We are also obtaining tangible benefits
from our investment in ‘PTSB Protect’. This
global-banking first is a feature of our
mobile banking app which helps prevent
customers falling victim to fraudulent
scams. In 2024 we reduced customers’
exposure to fraud by 64% due to PTSB
Protect.
Taking all this progress into account,
we are well positioned to continue to
provide much needed competition in the
Irish market and achieve our Ambition
to become Ireland’s best personal and
business bank through exceptional
customer experiences.
PTSB’s 2024 Annual Results reflect another year of strong
business and financial performance for the Bank.
With our strong capital and liquidity positions, we are
in prime position to continue to provide much needed
competition in the Irish market and achieve our Ambition
to become Ireland’s best personal and business bank
through exceptional customer experiences.
Business Performance Overview
Funding
Customer Accounts
At 31 December 2024, customer deposit
accounts of €24.1 billion are €1.2 billion
higher than 31 December 2023. Retail
deposit balances of €13.5 billion have
increased by 9% over the course of 2024,
while current accounts of €9.2 billion have
remained in line with 2023. In line with
our funding strategy, the Bank remains
strongly funded by retail deposits and
current accounts, making up 86% of
the total funding profile and reflecting a
strong liquidity and funding position.
Lending
Total gross new lending in the financial
year 2024 was €2.6 billion (2023: €2.8
billion), and this showed great momentum
in H2’24, increasing by 19% versus H2’23.
There was a strong pipeline of activity
across all business lines at the end of the
year, and the Bank is demonstrating good
progress in diversifying income through
growth in SME and Asset Finance lending.
Mortgage lending in 2024 was c.€2.1
billion, with drawdowns in H2 accelerating
to nearly twice the level of H1 as
customers responded positively to the
Bank’s competitive mortgage offering.
This was also reflected in our strong
mortgage market share which reached
20.2% in Q4. The mortgage market in
Ireland was €12.6 billion in 2024, up 4% on
its level for 2023 though still lower than
the €14.1 billion recorded in 2022.
Business Banking lending, inclusive of
both SME and Asset Finance lending, in
2024 was €434 million, an 11% increase
compared with 2023. This demonstrates
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
7
our commitment to offer a meaningful
alternative to business customers seeking
a new banking relationship PTSB. We were
also delighted to extend our Business
Banking offering by joining the SBCI’s
€500 million Growth & Sustainability Loan
Scheme (GSLS) in 2024.
The Bank recorded gross new consumer
term lending pay-outs of €132 million
in 2024. This is an increase of 13%
compared to 2023.
Financial Performance Overview
The Bank reported a Profit Before Tax of
€159 million for 2024 (2023: €79 million).
Net interest income (NII) remained broadly
consistent year on year. Net fee and
commission income is €55m for the year
ended 31 December 2024 an increase of
€13 million compared to 2023.
Operating Income
NII of €612 million has decreased by 1%
year on year and our Net Interest Margin
(NIM) decreased by 12bps to 2.20%. NII
decreased due to higher cost of funds,
primarily due to growth in higher interest-
bearing deposits, offset by increased
interest income due to the re-fixing
of mortgages at higher rates and the
recognition of a full years’ income in 2024
on the Asset Finance business which
migrated in H2 2023.
Net fee and commission income is €55
million for the year ended 31 December
2024, an increase of €13 million compared
to 2023. The increase is primarily due to
additional fee income on current accounts.
Net other income was €5 million for 2024
compared to €6 million in 2023. Other
income is driven by sales of properties in
possession and FX gains.
Operating Expenses
Operating expenses excluding exceptional
and other non-recurring items of
€531m are €27 million higher than prior
year, primarily due to an increase in
staff numbers during 2024, along with
Performance Related Pay increases,
technology licencing costs and cost
inflation pressure.
The Bank is undertaking a Strategic
Business Transformation (SBT)
Programme that focuses on operational
improvements and cost efficiency, the
outcome of which will be improvements in
both customer and colleague experiences
and a reduction in the Bank’s cost base,
both now and into the future.
Initiatives being delivered under the SBT
programme include the introduction
of digital customer correspondence to
reduce paper usage, the development
of an end-to-end, in-life mortgage
servicing platform to enable process
simplification and self-serve capabilities,
a rationalisation of our Software and IT
Suppliers, and the introduction of a new
contact centre platform to improve both
colleague and customer experience.
Impairment
The Bank recorded an impairment write-
back on loans and advances to customers
of €39 million for 2024, compared to a €2
million write-back for 2023. This reflects
the strong underlying performance
and asset quality within the loan book,
together with a favourable macro-
economic environment and improved
collateral values.
Exceptional and other non-recurring
items
The total exceptional and non-recurring
items for 2024 are €21 million, which
include accelerated amortisation on
intangible assets of €9 million and
€9 million impairment on the ‘Glas III’
transaction.
NPLs
Non-performing loans as a percentage
of gross loans were 1.8% at 31 December
2024, a decrease of 150bps compared to
3.3% at 31 December 2023. The decrease
was driven by the non-performing ‘Glas III’
loan portfolio sale during the year.
Capital
The Common Equity Tier 1 (CET1) capital
ratio on a fully loaded basis was 14.7%.
This compares to the Bank’s reported
fully loaded CET1 ratio of 14.0% at 31
December 2023.
The increase of the CET1 ratio (+70bps)
in the year is primarily due to increasing
capital generated from 2024 profit,
partially offset by AT1 coupon payments,
investment in intangible software assets
and RWA reduction due to Glas III. Capital
ratios remain above both management
and regulatory requirements.
Sustainable Business Growth
Delivering sustainable profitability and
incorporating Sustainability into our
business practices and strategic decisions
remains a key priority for the Bank. We are
focused on embedding Sustainability in a
way that is not only good for society, but
good for business too.
To that end and after a competitive
selection process, I was delighted
to announce Leontia Fannin as Chief
Sustainability & Corporate Affairs Officer
in August 2024. The role was newly
created to reflect the Bank’s commitment
to Sustainability as a key driver of its
business strategy and the value it places
on corporate affairs as a driver of internal
and external stakeholder engagement.
Throughout 2024 we continued the strong
and steady progress of recent years
across the four pillars of our Sustainability
Strategy.
We continued to support our customers in
navigating the transition to a low-carbon
economy with €875 million in green
mortgage lending throughout 2024, an
increase of 28% compared with 2023.
This equates to 43% of the Bank’s new
mortgage lending for the year, which
represents an increase of 14% compared to
the previous year.
In addition to supporting business
customers through the SBCI GSLS Scheme,
we were delighted to have been the first
financial institution to participate in the
Strategic Banking Corporation of Ireland’s
(SBCI) Home Energy Upgrade Loan
Scheme (HEULS), offering customers low-
cost loans to upgrade the energy efficiency
of their home.
From a social impact perspective, we were
extremely proud to donate €360,000 to
our six 2024 Community Fund partners.
This is our highest ever donation since the
establishment of the Community Fund, and
included €180,000 in matched funding by
the Bank and represents a 20% increase
on funds donated in 2023. Through
our partnership with the Social Finance
Foundation, we have provided €19.4m in
funding since 2009.
Chief Executive Review
(continued)
PTSB Group Holdings plc - Annual Report 2024
8
Reflecting on the importance of inclusivity,
the Bank was delighted to announce
a multi-year partnership with Ireland's
Autism Charity, AsIAm, as we became the
first bank in Ireland to receive autism-
friendly branch accreditation. Under the
terms of this three-year partnership, PTSB
is providing funding to AsIAm to scale and
grow the supports that the charity offers
throughout Ireland.
A key highlight of our 2024 results is
our first report under the Corporate
Sustainability Reporting Regulations and
we will launch a refreshed Sustainability
Strategy in H1 2025. The bank is also at
the final stages of setting Science Based
Targets and is submitting targets to
the Science Based Targets Initiative for
validation in the coming weeks.
Strategy and Outlook
As part of our Annual Report, we are
announcing the Bank’s Board-approved,
refreshed three-year business strategy for
2025-27.
Over the last three years, PTSB has
transformed into a Bank that is a very
strong competitor amongst two dominant
pillar banks. This competition is needed
in the market, and it is needed for
customers.
Our refreshed Business Strategy 2025-
27 sets out the roadmap to how we will
achieve our Ambition to be Ireland’s best
personal and business bank through
exceptional customer experiences.
It is focused on deepening customer
relationships, diversifying income
and differentiating through customer
experience. We will do this while driving
continuous operational efficiencies and
prudent cost management, so the Bank
can continue to grow and prosper in
a sustainable manner while rewarding
shareholders.
As the Chair stated in her review, we are
operating in a new era of geo-political
tensions. At PTSB, we understand that we
need to adapt and grow in line with this
environment while always being mindful
of the threats and challenges which could
emerge, whether at home or abroad,
and impact on our customers and our
business.
Notwithstanding these challenges, I am
confident that the strong momentum that
exists in PTSB will continue to drive the
Bank forward and make it an even greater
competitive force.
Building on the investments made in
recent years, the Bank is now in prime
position to provide retail and business
banking customers with an attractive
and competitive alternative; one that
is underpinned by both resilient and
innovative technology, and by human
support.
I will conclude by acknowledging the
contributions made by my colleagues
across the Bank throughout 2024. The
dedication and commitment that they
demonstrate each and every day will
ensure we are successful in achieving
our Ambition, and delivering for our
customers, communities, wider Irish
economy, and our shareholders.
Eamonn Crowley
Chief Executive
“Building on the
investments made
in recent years,
the Bank is now in
prime position to
provide retail and
business banking
customers with
an attractive
and competitive
alternative;
one that is
underpinned by
both resilient
and innovative
technology,
and by human
support.”
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
9
Market and Regulatory Context
Retail Banking Trends in Ireland
2024
Over the last year, we have consolidated
our position as the third largest, full-
service retail and business bank in Ireland,
investing in our products, processes
and people to deliver on our Ambition
of being Ireland’s best personal and
business bank through exceptional
customer experiences. Through listening
to our customers and understanding
their banking needs, we are continuing
to deliver new products and exceptional
customer experiences, while growing and
diversifying our business.
In June 2024, the European Central Bank
began to cut rates as inflation across the
euro zone eased. The ECB announced
four rate decreases, bringing the main
borrowing rate to 3.15%, equating to a
reduction of 1.35% during 2024. The
deposit rate was reduced by 100bps to
3%, while the marginal lending facility was
cut to 3.40%.
Mortgage market growth was modest
in 2024, primarily driven by continued
decreases in switcher and mover
purchase activity with market projection
adjusted to €12.5 billion. Market pay-outs
reached €12.6 billion by the year end, with
drawdown volumes falling marginally by
1.3% year on year, while values rose by
4.0%, representing an increase in average
house prices across the country. The
levels of approvals in 2024 were up 2.9%
year on year, coupled with the impact
of ECB rate cuts on mortgage price
competition, provide a positive outlook for
the market in the first half of 2025.
PTSB has taken significant steps to
further enhance our digital banking
offering this year as customers’ desire
for digital capabilities have continued
to increase. Over 26,000 new current
accounts were opened during the
year, 52% of which were through our
app, signalling customers’ continued
preference and adoption of digital
channels. Overall digital channel usage
remains high, with c. 160 million logins
through our App and Website in 2024. In
an environment with evolving methods
and attempts at fraud, we remain
committed to safeguarding our customers.
Since launching ‘PTSB Protect’ in October
2023, we have seen a 55% reduction in
fake website clicks by our customers. This
innovative service won Best Innovation/
New Feature at the Bonkers.ie Awards
and Best Innovation in CX at the Irish CX
Impact Awards.
Delivering exceptional customer
experiences remains a key focus for
the Bank across our digital, voice and
in-person channels, including our
intermediary channels. We have continued
to evolve our channel mix by investing
in customer journey enhancements
across both onboarding and in-life for
a number of product lines. Customer
needs are at the heart of how we design
innovative products and services and
how we distribute to our customers. Our
‘Reflecting Ireland’ quarterly research
series indicates that Sustainability is
important to our Customers, and in April,
we became the first financial institution
in Ireland to participate in the Strategic
Banking Corporation of Ireland’s (SBCI)
Home Energy Upgrade Loan Scheme,
supporting customers with retrofits to
make their homes more energy efficient.
In June, we launched our innovative
‘Interest First’ deposit account, unique
to the Irish market, enabling customers
to receive interest from savings upfront
as a lump sum, within the first month of
opening the account, instead of waiting
until the end of the 1-year fixed term.
For the second consecutive year, our
‘Explore’ current account was awarded the
“Financial Services Loyalty Programme/
Initiative of the Year” at the Irish Loyalty &
CX Awards.
At PTSB, we are committed to fostering
openness, inclusivity, and to deliver an
exceptional experience to our customers
and communities, especially those that
might require additional support or
are vulnerable. Supporting vulnerable
customers is not just a moral obligation;
it is also a reflection of our commitment
to fairness, inclusivity and building trust,
and we have continued to enhance our
procedures to support those who need it
most. In 2024, we announced a multi-
year partnership with AsIAm, Ireland’s
Autism Charity, and became the first
Irish financial institution to be accredited
with Autism-Friendly branches in key
locations across the country. We have
also introduced easy-to-read guides in
our branches for customers who may
require additional support, and provided
Lámh training for front-line staff, teaching
them a manual signing system to enhance
their engagements with customers with
additional communication needs.
PTSB Group Holdings plc - Annual Report 2024
10
Business Banking Trends in Ireland
2024
The Irish economy has shown robust
strength through the inflationary
challenges of the last 24 months.
Following recent interest rate reductions,
many businesses are eager to grow
and take advantage of robust demand
in the market however the volatility in
raw material and fuel costs represents
a headwind and requires vigilant
management. Key sectors driving growth
in new lending in 2024 include wholesale,
retail, agriculture, and human health.
SMEs are effectively managing their
business models through innovation and
automation, with a focus on sustainability
to enhance business performance.
Initiatives such as the Growth &
Sustainability Loan Scheme (GSLS) by the
Strategic Banking Corporation of Ireland
(SBCI), in which PTSB participates, are
providing key mechanisms to support
SMEs. The SBCI loan guarantee schemes
have been instrumental in enhancing the
Bank's reputation in the SME market and
driving growth across all existing product
ranges.
Tight labour markets and skills shortages
continue to challenge many SMEs, with
the Irish economy nearing full employment
with 2.8 million people now employed.
Inflation and interest rates began to
reduce in 2024, with growth forecasted
for the Irish economy in 2025 outpacing
most other European economies. The SME
economy also benefits from significant
Foreign Direct Investment in Ireland,
with Multinational Companies (MNCs)
continuing to invest and expand their
footprint in the only "English-speaking"
economy in the EU. Irish SMEs play
a crucial role in the value chains for
those MNCs that choose Ireland as a
business hub. The impact of the new US
administration’s trade policy is uncertain
and potential downstream impact on Irish
SMEs needs to be closely monitored.
PTSB has continued to grow business
lending activity through the period while
providing timely support to borrowers in
financial difficulty. The Bank increased
new SME lending by 28% in the year.
Strong volumes of M&A activity are driving
lending needs in the areas of succession
planning and management buyouts, with
refinance activity also remaining high. The
business lending portfolio is well spread
across industry sectors with continued
investment in our capabilities. The Bank
has also bolstered the Business Banking
team with experienced specialists to
support our customers and position PTSB
as one of the top three Business Banks in
the market.
PTSB Asset Finance business have
continued to finance assets across a
wide range of sectors including transport,
agriculture, and manufacturing. The Bank’s
combined SME and Asset Finance books
grew 11% to over €1.1 billion at year end.
“The Irish
economy has
shown robust
strength through
the inflationary
challenges of the
last 24 months.
Following recent
interest rate
reductions, many
businesses are
eager to grow and
take advantage of
robust demand
in the market
however the
volatility in raw
material and fuel
costs represents
a headwind and
requires vigilant
management.”
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
11
Our Strategy, Business Model and Culture
Introduction
PTSB has a long banking history of over 200 years, making us
one of Ireland’s longest serving financial services institutions.
Throughout this time, our focus has been on delivering
exceptional customer experiences and connecting with our local
communities. This remains a core part of the Bank’s Strategy, in a
world where customer needs and behaviours are ever evolving.
After a period of transformational growth,
PTSB has successfully strengthened its
Balance Sheet and established strong
foundations from which the Bank will grow
sustainably. With our strong capital and
liquidity positions, PTSB is well positioned
to continue to provide much needed
competition in the Irish market and
achieve our Ambition of being Ireland’s
best personal and business bank through
exceptional customer experiences.
Building on the investments made in
recent years, the Bank is now in prime
position to challenge the dominant pillar
banks in the Irish market, providing retail
and business banking customers with an
attractive and competitive alternative;
one that is underpinned by both resilient
and innovative technology and by human
support.
The Bank has a clear strategic direction
that is being delivered over three phases;
• Phase 1. Optimise operating model and
offers to become fit for future growth;
• Phase 2. Evolve and develop offers to
deepen customer relationships and
grow income; and
• Phase 3. Drive diversification and
accelerate growth.
Acknowledging market conditions of a
decreasing interest rate environment,
continued price competition in the
mortgage market, and significant
regulatory and mandatory operating
requirements, Phase I of our Strategy
presents an exciting prospect for PTSB.
Under Phase 1, which will be delivered
2025-27, the Bank’s focus will be on
deepening customer relationships,
diversifying income, and differentiating
through customer experience, while
driving continuous operational efficiencies
and prudent cost management.
Our Business Model
PTSB offers Personal and Business
Banking services exclusively in the
Republic of Ireland and this is not
expected to change through the delivery
of our Strategy.
Building on our strong Mortgage offering,
the Bank is focused on diversifying its
income by increasing our share in other
key priority products such as Credit &
Asset Finance products in the Business
Banking market, and Consumer Term
Loans, Deposits & Current Accounts,
Insurance and Pensions & Investments in
the Personal Banking market. This will also
deliver growth in our Non-Interest Income.
The Bank will invest in People, Data,
Technology, AI and Innovation,
while driving continuous operational
efficiencies, to ensure a sustainable cost
base.
PTSB Group Holdings plc - Annual Report 2024
12
Our Strategy
To deliver against Phase I of our strategic direction, the Bank
is launching its Board-approved, refreshed three-year Business
Strategy 2025-27. This will see us deepen customer relationships,
diversify our income, and differentiate through customer
experience.
Business Strategy 2025-27
Our Purpose
Our Ambition
Working together to build trust with our customers and communities
To become Ireland’s best personal and business bank through exceptional customer experiences
Who we serve
Our value
proposition
How we will deliver
Personal Banking
Business Banking
Focused on Micro, Small and Medium-
Sized Enterprises, and Business and
Personal Asset Finance customers
Focused on meeting more of the
needs of our existing 1.3m
customer base
Digital First
Physical
presence and
regulation in
Ireland
Innovative
propositions,
supported by
loyalty rewards
Competitively
priced
Modern and
contemporary
Altogether More
Human brand
Deepening Customer Relationships, Diversifying Income, Differentiating Through Customer Experience
While Driving Continuous Operational Efficiencies and Prudent Cost Management
Own my Home
Manage my
Money (incl.
payments)
Grow & Run my
Business
Transform the
Bank
Strengthen the
Foundations
• Deepening our customer relationships
will mean that we do more business
with the 1.3m customers we already
have, meeting all their financial needs
– whether that be a current account,
mortgage, insurance, wealth service or
all four.
• Diversifying our income will see us
maintain and grow our mortgage market
share, attract new current account
customers, while also grow new areas
such as business banking and asset
finance.
• Differentiating through customer
experience will mean that we provide
a seamless digital first customer
experience, complemented by the very
best human support, while offering our
customers innovative products and
services that meet their needs.
We will do this while driving continuous
operational efficiencies and prudent cost
management, so we can continue to grow
and prosper in a sustainable manner, while
generating returns for our shareholders.
As such, the Bank is undertaking a
Strategic Business Transformation (SBT)
Programme that focuses on operational
improvements and cost efficiency, the
outcome of which will be improvements in
both customer and colleague experiences
and a reduction in costs.
The Bank is expected to remain a
predominantly ‘Deposit-Led Lender’,
reducing further its reliance on external
wholesale funding, while continuing to
meet all regulatory funding requirements,
in as efficient an Issuance strategy as
possible.
Our value proposition can be summarised
as follows: We provide our customers with
a digitally-led experience, complemented
by human support when needed through
our voice and in-person channels. We
offer the right products and propositions,
at the right price, with strong market
share in our target segments.
• We maintain a Digital-First approach,
meaning we prioritise our App & Online
channels for investment and delivery,
and we provide our customers with a
digitally-led experience
• We are a robust and well-managed
Bank with a Physical presence and
regulated in Ireland by the Central Bank
of Ireland
• We offer innovative propositions,
supported by loyalty rewards
• Our products and propositions are
competitively priced
• We leverage our modern and
contemporary ‘Altogether More
Human’ brand, which drives Brand
Awareness, Consideration and Affinity
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
13
Our Strategy, Business Model and Culture
(continued)
Delivering Our Strategy
The organisation has an
integrated plan in place
between 2025-27 to ensure our
resources and investment are
prioritised to deliver against
our strategy.
To ensure we can achieve our objectives,
our strategy will be delivered under five
Value Streams:
• Own My Home – Further enhance
our mortgage and consumer finance
offerings to ensure we can meet the
needs of our customers at every stage
of their home journey
• Manage My Money – Improve our digital
experience and launch innovative new
products while maximising customer
engagement
• Grow & Run My Business – Diversify
our business by evolving our business
banking capabilities and propositions
• Transform the Bank – Drive efficiencies
through simplification, while investing
in people, data, technology, AI
and innovation, and elevating our
sustainability agenda.
• Strengthen the Foundations – Secure
customer interest through robust risk
management, and maturing our cyber,
technology and operational resilience
We have set out detailed three-year
delivery plans for each of the Value
Streams, and we will track and monitor
our performance against key performance
indicators throughout our delivery.
2025-27 will again see capital investment
of >€100m per annum as we continue
to deepen our customer relationships,
diversify our income, and differentiate
through customer experience, while
driving continuous operational efficiencies
and prudent cost management.
Our Culture – Bringing the lived
experience to life
At PTSB, we describe our
culture as the way we do things:
We are Open. We are Inclusive.
We build trust. We are One
PTSB.
Delivery Through Five Value Streams
Deepening Customer Relationships, Diversifying Income, Differentiating Through Customer Experience
While Driving Continuous Operational Efficiencies and Prudent Cost Management
Own My Home
Manage My Money
(Incl. Payments)
Grow & Run My
Business
Transform the Bank
Strengthen the
Foundations
New Digital Mortgage
Servicing with Self-Serve
Capability
Optimise Digital, Voice and
in-person Channels to Drive
Acquisition
Introduce new Customer
Offerings, including Retrofit
Maximise Customer
Engagement to increase
Average Product Holding
Expand App and Payment
Capabilities and Drive
Digital Adoption
Develop Innovative
Customer Propositions that
Reward Loyalty
Evolve SME and Asset
Finance Capabilities and
Propositions
Develop Digital Credit
Proposition for Micro-SMEs
Compete through
Enhanced Customer
Service
Drive Efficiencies Through
Strategic Business
Transformation Programme
Elevate Sustainability with
Strategic Focus on the
Social Agenda
Ongoing Transformation
and Investment in People,
Data, Technology, AI and
Innovation
Prepare for Transition to
SSM and Deliver IRB Model
Review
Protect Customer Interests
Through Robust Risk
Management
Mature Cyber, Technology &
Operational Resilience
Culture is the DNA of a company. Our
culture shows up in our behaviours - how
we work, how we treat our customers
and each other, what we focus on, and
how we live our Values. Our culture is
unique and special. It makes us who we
are – friendly, customer and colleague
focused, inclusive and caring. We
manage risk and comply with regulations,
where everyone works to meet our
goals and is proud of the part they play.
Every colleague influences our culture at
PTSB. How we each think, behave and act
makes a difference here. A great culture
brings people together by imparting a
strong sense of meaning, direction, and
passion. Our Culture unites us together
as one team to deliver for our customers.
We have been continuous and proactive in
working to improve and evolve our culture
since 2015; keeping and enhancing the
PTSB Group Holdings plc - Annual Report 2024
14
elements that make us unique and special,
whilst altering any aspects that don’t
align with our Values and Purpose. We
have a made a lot of progress, and we are
focused on continuously evolving culture
across the Bank.
Cultural evolution is imperative as it
influences how people experience our
Bank; what it’s like for customers to
engage with us, for our colleagues to work
with us and for our communities to live
with us. At PTSB, we describe our culture
as the way we do things. Our goal is to
create a culture of building trust, where all
colleagues have a consistent experience
regardless of their role, tenure, location,
ways of working or function. Our culture
is made up of our Purpose, Ambition and
Values. Our Values are articulated through
behaviour articles, which help colleagues
to understand how to role model our
Values. Through our behaviours and the
way colleagues work together to support
our customers and our communities we
live our Values. They are demonstrated in
how we handle day-to-day operations, our
everyday communication and tasks that
create the PTSB way of doing things.
In 2023, we announced a major overhaul
of our brand and business repositioning
as a full-service, customer-focused
personal and business bank. This
included a complete rebranding of the
Bank from Permanent TSB to PTSB,
and the introduction of a new brand
promise, ‘Altogether More Human’, which
emphasises PTSB’s intentions as a full-
service personal and business bank to
bring the best of technology and our
people together to solve real customer
needs and deliver a better banking
experience.
Our Purpose
Working together to build trust with our customers and communities.
Our Ambition
To become Ireland’s best personal and business bank through exceptional customer experiences.
Our Promise
Altogether more human.
Our Culture
We are Open. We are Inclusive. We build trust. We are One PTSB.
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.
Aligned to our brand and business
repositioning, our CEO, together with our
Executive Committee and Board, evolved
our Purpose and our Ambition in 2023.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
15
Our Strategy, Business Model and Culture
(continued)
Living our values and managing risk
builds trust. We nurture an accountable
and supportive workplace where
everyone is encouraged to contribute
meaningfully, as we become Ireland’s
best personal and business bank through
exceptional customer experiences. We
are committed to creating a supportive
and inclusive environment where
everyone is welcome and respected.
When colleagues can be their authentic
selves, they bring their best selves to
work. This creates better experiences
for all colleagues and leads to leads
to exceptional experiences for our
customers.
Our Simplified Culture Charter ensures
that all colleagues have a consistent
understanding of our culture and the
expectations of them as well as reflecting
our evolved Purpose and Ambition,
and our promise to be ‘Altogether
more human’. It sets out our Purpose,
Values and beliefs that guide colleague
interactions to support the delivery of our
Ambition. Our 12 culture enablers help to
nurture and improve our culture.
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 colleagues can be themselves,
where they can be at their best, where
their contribution is encouraged and
valued, and where they are welcomed,
respected, recognised, and supported,
we will consistently deliver ethical
decision making, fair customer outcomes
and risk management in everything that
we do.
2024 Culture Reflection – embedding our brand promise of being
Altogether More Human.
The 2024 implementation of the Individual Accountability Framework (IAF), represents a
pivotal step forward for the Irish Banking sector, strengthening a culture of transparency
and responsibility. By clarifying individual roles and fostering accountability, IAF
supports a positive workplace culture aligned with our core values and regulatory
standards. 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 espoused culture.
We are making improvements to our culture:
Our Purpose and
Values continue
to resonate with
colleagues
88.9% of colleagues tell us that they understand our
Purpose and Values. (Source: Every Voice Counts
2024).
Our culture Index is
above target
It is 76% (+6% above target) (Source: Every Voice
Counts 2024).
We are proud of our
Gender Pay Gap
progress to date
It is 16.9%. We have published our Gender Pay Gap
Report for the fifth year, and we acknowledge our focus
on this area must continue.
We have been
awarded the IBEC
KeepWell Mark™
As part of our Wellbeing Strategy, we successfully
achieved the IBEC KeepWell Mark™, a national health
and wellbeing evidence-based accreditation that
recognises organisational commitment to employee
well-being, safety and health.
Trust in our Bank is
above target
71.5% of colleagues trust PTSB to do the right thing
(+1.5% above target), and above the external industry
benchmark of 63%. (Source: Every Voice Counts 2024).
We won the CIPD Award for Elevating the colleague
experience (Large Org).
84.7% of colleagues have told us they understand their role, while 87.2% of colleagues
say their teams work effectively across functions to deliver for our customers and our
communities. Our Risk Culture Index remains strong at 76% (Source: Every Voice Counts
2024).
We have 12 cultural enablers
which help shape and guide
our cultural journey, and
include:
We have continued to focus on improving
our culture by embracing 12 cultural
enablers, and by being committed to
identifying and over-coming cultural
blockers. Our dynamic culture diagnostic
enables us to include transparent
tracking, measurement and reporting of
Engagement and Culture on a sustained
basis as part of our Risk Appetite. Our 12
cultural enablers include:
Living as Leaders - Join the
Conversation
2024 marked the fourth 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. 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. By utilising the self-
reflective roundtable approach with our
behaviour articles, colleagues become
more self-aware of their own actions and
PTSB Group Holdings plc - Annual Report 2024
16
characteristics. Our Values guide the
behaviours we expect of our colleagues.
Behaviours practiced over time become
habits, which in turn become mind-set.
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
foundational in influencing our culture and
is included in our Induction Programme for
all new joiners. With the implementation
of the IAF in 2024, Living as Leaders is
even more important as it provides a
practical self-reflective framework to help
our colleagues understand the behaviours
expected of them aligned to our Values. It
supports the improvement of our culture
as lived behaviours overtime become
habits, which in turn become mind-set.
The programme is evolving further in
2025, with each People Leader across the
Bank required to run a Living As Leaders
roundtable with their team on a monthly
basis.
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 PTSB’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 have further expanded on our
partnership with LIFT Ireland to become
one of five sponsors of their ‘Changing
futures for the better – Schools Initiative’.
LIFT are already active in over 360
of Ireland’s secondary schools where
students and teachers have adopted
the LIFT Ireland Programme, with the
curriculum being delivered to more than
26,000 students in communities across
the country in 2024 (86,000 students
since LIFT started in 2018).
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) and Micropulse surveys
which ask the question “where I work,
people can share their opinion without
fear of negative consequences”. The 2024
EVC survey found 74.3% of colleague
respondents felt psychologically safe and
the Micropulse 2024 survey found 74% of
colleague respondents felt psychologically
safe in the Bank. 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.
To continue our embedding plan, in 2024
we delivered a number of initiatives to
further educate, track and highlight
examples of speaking up. Most notably
was the Bank’s Speak Freely week
which saw significant engagement
from colleagues across the business
on the various initiatives taking place
including videos, physical and digital
material, training, information sessions
and external speakers. During the week,
there was a significant increase in
colleague engagement demonstrating
the importance of a psychological safety
campaign.
In addition to this, the embedding plans
also include:
• Training People Managers and Speak
Freely Champions on Speak Freely and
Protected Disclosure procedures, and
colleague conduct;
• Mandatory 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 and the Bank’s Team
Culture Charter;
• Regular Reporting on Speak Freely
concerns to the Exco and Board;
• Developing and sharing of Speak
Freely Management Information with
colleagues and acting on feedback
from the bank wide Every Voice Counts
survey and ‘Speak Freely’ Micro-Pulse
survey and subsequent focus groups;
and
• Customer Focus – this year also saw
a greater link with the customer and
ensuring that colleagues are raising
process improvements for customers
through dedicated Customer Speak
Freely Champions.
Ways of Working (Hybrid Flexible
Working)
In 2020 the Bank introduced a Smart
Working Framework 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 that Framework, we sought to
create a reimagined, customer-centric
PTSB work environment which fits our
strategic design criteria across the areas
of Organisational Design, Property,
Technology and New Ways of Working. It
includes 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.
To support smarter working, we have
rolled out several initiatives to enable
adoption including Infographics, Team
Commitment Charters, Collaboration
Zones, Colleague Personas and Kits, new
Ways of Learning, and a No Meeting Slot.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
17
Throughout 2024 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. We have created 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 continue to enable the Flexible
& Hybrid Workplace in 2024, a Hybrid
Working Group was established
comprised of representatives from HR
Business Partnering, People Experience,
Group Technology and Facilities. This
Working Group supports the ongoing
review of Hybrid Working arrangements
for colleagues under the mentioned
dimensions and address colleague’s
needs. Feedback from the Bank’s
respective surveys are used to receive
colleague feedback and understand what
areas need to be addressed based on
colleague feedback.
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 PTSB 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
‘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 Everyday
Recognition (which is available all year
around enabling colleagues to say
thank you every day). With over 2,400
nominations received, 2024 marked the
highest level of recognition to date since
the VIP Annual Awards were launched
seven 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 were over 2,650
VIP Everydays sent in 2024, which were
received by over 1,350 colleagues.
People Experience Council (PEC)
As a group of leaders within the
organisation, across multiple levels and
functions, PEC members are empowered
and mandated by their ExCo member to
work with teams in their area as they seek
to drive and support positive cultural and
behavioural change. The PEC members
listen to elevate colleague feedback and
work to support the culture evolution
in their function to address behavioural
inconsistencies across the Bank, and
to improve trust with our customers.
As respected colleagues both, in their
division and across the bank, they lead
the development of their Every Voice
Counts (EVC) action plan to address areas
of improvement.
The Individual Accountability
Framework (IAF) & How the Bank
Provides Assurance on Culture
IAF plays a critical role in driving cultural
change by embedding accountability at
the individual level. IAF is designed to
foster a culture of accountability, where
senior leaders must actively demonstrate
and promote ethical behaviour,
transparency, and regulatory compliance
throughout the organisation. This focus
on personal responsibility encourages a
culture where decisions are made with a
greater sense of diligence and alignment
with the organisation’s values, reinforcing
a culture of accountability across all levels.
IAF is a positive enabler, helping to create
an environment where culture is not just
a shared commitment but a standard of
conduct that is actively monitored and
upheld. The IAF Conduct Standards are
also embedded into the agendas of key
governance committees within PTSB.
This includes, but is not limited to, the
Nomination, Culture and Ethics Committee
(NomCo), the Colleague Conduct
Committee and Customer Committee
which have all been updated to support
the IAF Conduct Standards obligations for
the Bank.
Our Strategy, Business Model and Culture
(continued)
“At PTSB 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.”
PTSB Group Holdings plc - Annual Report 2024
18
The Irish Banking Culture Board
(IBCB)
Established in 2018, the IBCB is an
independent industry initiative funded by
the three retail banks in Ireland. Its aim
is to rebuild trust in the sector through
demonstrating a change in behaviour
and overall culture. PTSB were delighted
to support in the launch of the inaugural
the IBCB Pride in Banking Awards in
2024. PTSB colleagues received 158
nominations recognising a total of 330
PTSB colleagues.
We also continued embedding 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 look forward to
continuing our work with the IBCB in 2025
and beyond, as we work hard to re-build
trust in the banking sector together.
Our Customer Yes Checks
- Enabling comprehensive
consideration & ensuring fair
outcomes when decisions are made
at PTSB.
We are building a trustworthy and
sustainable business - one that has
the best interests of colleagues and
customers at heart, and one that
makes a positive and lasting impact on
our community. Our Culture Charter
guides how we make decisions through
our Purpose and Values. However,
sometimes decisions are not simple
and/or straightforward and in 2022 we
developed and piloted ‘Our Customer Yes
Checks’ to help colleagues weigh up the
impact and consider the consequences of
our decisions, so that we make the best
decisions each day, every day.
Our Customer Yes Checks are designed
to enable good debate, ensuring that no
strategic decision is taken before different
views have been considered and the
related risks have been assessed. Ethical
dilemmas are difficult, especially when
there is no obvious ‘right thing to do’. We
recognise that we have more to do to help
colleagues to act ethically every day, by
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
19
creating a safe space to talk about ethical
dilemmas and judgement calls more
frequency. We need to encourage the use
of the DECiDE framework for day-to-day
decision-making, embedding it in to how
we operate our business.
In 2024, we further iterated our Yes
Checks, based on Committee feedback,
research and best practice, and
incorporated a Customer Wheel. In
addition, we evolved the name to be Our
Customer Yes Checks. Following approval
by the Nominations and Ethics Committee,
Our Customer Yes Checks are rolling out
across all Tier 1-4 Committees.
Culture in 2025 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 2024, to
embed our new Brand, the delivery of
our evolved Purpose and Ambition and
embedding our Culture Statement.
Our key activities to continue our culture
evolution will include:
• Living as Leaders: Role-modelling our
Values through our actions and words
by Living as Leaders every day.
• Speak Freely: Creating an environment
where everyone feels safe to Speak
Freely and to develop an innovative
mindset.
• Diversity, Equity & Inclusion: Building
a bank where everyone is included and
encouraged to share different views
and perspectives.
• Smart Working Framework: Supporting
colleagues with new trust-based ways
of working on a sustainable basis.
• Wellbeing: Supporting colleagues to
bring their best selves to work in all
aspects of their working day.
• Customer Focus: Building trust-based
relationships with customers with due
care and consideration always.
• Risk Integration & Management:
Providing the supports and tools to help
integrate and manage risk in all that we
do every day.
• Strong Stakeholder Engagement:
Listening and actioning feedback to
align our Colleagues, Customers and
Community.
• Quality Communications (Internal):
Communicating in a way which is
simple, clear and connects with every
colleague.
• Reputation Management (External):
Protecting, enhancing, and measuring
our reputation in the community.
• Brand: Positioning PTSB to bring our
Purpose to life.
• Culture Measurement: Encouraging
colleagues to share their feedback to
improve the colleague experience.
• 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.
What are we focusing on next?
Since our cultural journey began in 2015,
we have worked hard to make and sustain
improvements, recognising that there
is more work to do across the Bank.
We know that our cultural journey will
continue as we seek to create a consistent
cultural experience for all colleagues with
customer trust at the heart.
As we look ahead, the key areas of focus
for us will be to continue:
• Integrating a Customer-Centric mindset
• Embedding Ethical Decision-Making
• Building a Culture of Individual
Accountability
• Creating a consistent colleague
experience focused on culture
integration.
• Creating a More Diverse, Equitable, and
Inclusive PTSB
Our Strategy, Business Model and Culture
(continued)
PTSB Group Holdings plc - Annual Report 2024
20
The Group has returned an underlying
profit of €180m for the year ended 31
December 2024, which is an increase of
€14m from in 2023. Net interest income
has decreased by 1% compared with last
year. Total operating expenses (excluding
exceptional and other non-recurring
items) have increased by 5% year on year,
primarily driven by higher headcount.
Strong underlying performance and
robust asset quality within the loan book,
together with the favourable macro-
economic environment and improved
collateral values have resulted in an
impairment write-back of €39m on loans
and advances to customers for the year
ended 31 December 2024, compared to
an impairment write-back of €2m in 2023.
The above are the main items which result
in the Group delivering an overall profit
before tax for the year of €159m, which is
an increase of €80m compared to 2023.
The Group continued to manage its
capital and liquidity positions prudently
during the year. The liquidity and capital
positions of the Group remain well above
all minimum regulatory requirements, with
CET1 and total capital sitting at 14.7% and
20.4% respectively. The liquidity cover
was ratio was 255%, and the net stable
funding ratio was 166%.
Financial Review
Asset quality has continued to remain
strong during 2024. Our customers
have continued to manage the impacts
of inflation and higher interest rate
environment. The Group’s NPL ratio for the
year ended 31 December 2024 is 1.8%,
a decrease of 150bps compared with
2023. The Group continues to monitor and
manage carefully the impact of inflation
on our customers and any expected credit
losses.
The outlook for the Bank remains
strong, and the Group expects to deliver
sustainable profitability over the medium
term.
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 2024.
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 in the Alternative
Performance Measures.
A reconciliation between the underlying
profit and operating profit on an IFRS
basis is set out on page 410.
Management has provided further
information on IFRS and non-IFRS
measures including their calculation in the
Alternative Performance Measures (APM)
section on pages 410 to 417.
The Group’s strong financial performance in 2024 has been
supported by the positive macroeconomic environment, robust
employment, improved collateral values and strong asset quality.
The continued high interest rate environment has generated an
increase in average rates across the Group’s mortgage products
resulting in higher gross interest income. This is offset by an
increase in cost of funds due to the growth in deposit volumes
which was primarily in higher interest-bearing retail deposits,
including market-leading rates on six-month and one-year
deposits. The expansion and diversification of the Group’s
business banking offering has also contributed to the overall
growth in interest income.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
21
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
Year ended
Year ended
Table
31 December
2024
31 December
2023
€m
€m
Net interest income
1
612
620
Net fee and commissions income
55
42
Net other income
5
6
Total operating income
672
668
Total operating expenses (excl. exceptional items and other non-recurring items,
bank levy and other regulatory charges)
3
(498)
(444)
Bank levy and other regulatory charges
(33)
(60)
Underlying profit before impairment*
141
164
Impairment write-back on loans and advances to customers
4
39
2
Underlying profit before exceptional and other non-recurring items
180
166
Exceptional items comprise:
5
-
(28)
Costs incurred in relation to Ulster Bank transaction
-
(31)
Impairment write-back arising from deleveraging of loans pre-2021
2
5
Restructuring and other costs
(2)
(2)
Other non-recurring items comprise:
5
(21)
(59)
Impairment charge on Ulster Bank transaction
-
(52)
Impairment charge on deleveraging of loans
(9)
-
Charges in relation to legacy legal cases
(3)
(2)
Other
(9)
(5)
Profit before taxation
159
79
Taxation
3
(11)
Profit for the year
162
68
*
See table 1 in the Alternative Performance Measures on page 410 for a reconciliation of underlying profit to operating profit on an IFRS basis.
Financial Review
(continued)
PTSB Group Holdings plc - Annual Report 2024
22
Management performance summary consolidated income statement - key highlights
• Total operating income has increased by €4m during 2024 primarily due to:
- Net interest income decreased by €8m (1%) during 2024 to €612m. The decrease is driven by increases in volume and
underlying cost of retail deposits and increases in cost of wholesale funding, exceeding increases in interest income on loans and
advances to customers.
- Net fee and commission income is €55m for the year ended 31 December 2024, an increase of €13m compared to 2023. The
increase is primarily due to additional fee income on current accounts.
- Net other income is €5m for the year ended 31 December 2024 compared to €6m at 31 December 2023. Net other income
primarily comprises sale of properties and FX gains.
• Total operating expenses (excl. exceptional items and other non-recurring items, bank levy and other regulatory charges) are
€498m for the year ended 31 December 2024 compared to €444m at 31 December 2023. The increase is driven by increased staff
costs due to higher average headcount, the increase in technology licencing costs, and cost inflation pressure.
• Impairment is a write-back of €39m on loans and advances to customers for the year ended 31 December 2024, compared to a
write-back of €2m for the year ended 31 December 2023. This write-back reflects the strong underlying performance and robust
asset quality within the loan book, together with a favourable macro-economic environment.
• Bank levy and other regulatory charges amounted to €33m for the year ended 31 December 2024, compared to €60m for the
year ended 31 December 2023. The decrease is primarily due to a €28m reduction in the Deposit Guarantee Scheme (DGS) fees
for 2024, due to the DGS fund reaching its target level in 2024. Additionally, the Single Resolution Fund fee for the year ended 31
December 2024 was €nil (31 December 2023: €4m).
• Other non-recurring items amount to a charge of €21m for the year ended 31 December 2024. They comprise €3m in provisions
relating to legacy legal cases, an impairment charge of €9m in relation to the Glas III loan portfolio sale, and €9m in accelerated
amortisation of intangible assets.
Net interest income
Net interest margin
€612m
2.20%
Table 1: Net interest income
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Interest income
899
778
Interest expense
(287)
(158)
Net interest income
612
620
Net interest margin (NIM)
2.20%
2.32%
Net Interest Income
Net interest income of €612m for the year ended 31 December 2024 decreased by €8m (1%), compared to the prior year. This is
mainly driven by the following:
• higher cost of funds due to growth in deposit volumes primarily in higher interest-bearing retail deposits, and an increase in
wholesale funding costs, offset by;
• higher interest income from lending, due to higher average rates across mortgage products driven by the higher interest rate
environment over the past number of years, and
• an increase in interest income due to a recognition of a full year’s income in 2024 on the Asset Finance business which migrated in
H2 2023.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
23
Table 2: Average balance sheet*
Year ended 31 December 2024
Year ended 31 December 2023
Average
balance
Interest
Average yield/
rate
Average
balance
Interest
Average yield/
rate
€m
€m
%
€m
€m
%
Interest-earning assets
Loans and advances to customers
21,221
747
3.52%
20,547
661
3.22%
Debt securities
3,855
65
1.69%
3,242
36
1.11%
Loans and advances to banks
2,610
87
3.33%
2,795
81
2.90%
Total average interest earning assets
27,686
899
3.25%
26,584
778
2.94%
Non interest earning assets
1,000
937
Total assets
28,686
899
27,521
778
Interest-bearing liabilities
Customer accounts
23,541
139
0.59%
22,340
43
0.20%
Debt securities in issue
1,686
115
6.82%
1,222
71
5.81%
Lease liabilities
34
1
2.94%
29
1
3.41%
Subordinated liabilities
250
9
3.60%
254
8
3.15%
Deposits by banks
567
23
4.06%
1,051
35
3.33%
Total average interest-bearing liabilities
26,078
287
1.10%
24,896
158
0.64%
Non-interest-bearing liabilities
151
201
Total liabilities
26,229
287
25,097
158
Total average equity attributable to
owners
2,457
2,424
Total equity and liabilities
28,686
27,521
Net interest margin
2.20%
2.32%
*
Where applicable, 2024 line items include hedging derivative balances and hedging income and expense
Net interest margin
NIM decreased by 12bps to 2.20% for the year ended 31 December 2024 compared to 2.32% for the prior year. The NIM of the Group
has decreased due to increases in deposit costs and wholesale funding. This is partially offset by higher interest income.
Interest income/average interest earning assets
• Interest income on loans and advances to customers increased by €86m driven by increased average rates across mortgage
products driven by the higher interest rate environment over the past number of years, and the migration of the Asset Finance
business in H2 2023.
• Interest income on debt securities increased by €29m due to lower yielding debt securities being replaced by higher yielding
assets, reflecting market movements. The asset mix has a similar risk profile to those being replaced.
• Interest income on loans and advances to banks increased by €6m due to higher yields on excess liquidity held with the central
bank and treasury activity.
Interest expense/average interest bearing liabilities
• Interest expense on customer accounts has increased by €96m. This increase reflects an increase in average balances and
migration to higher rate term deposit accounts.
• Interest expense on debt securities in issue increased by €44m during the year due to higher average volumes and the full year
impact of the 2023 issuances. A €500m MREL-eligible Green Bond was issued in April 2024.
• The average balance of subordinated liabilities remained consistent year on year. The average balance of deposits by banks
reduced from the prior period due to a reduction in repurchase activity.
Financial Review
(continued)
PTSB Group Holdings plc - Annual Report 2024
24
Table 3: Total operating expenses
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Staff costs
Wages and salaries (including commission paid to sales staff)
190
165
Social insurance
22
19
Pension costs
21
17
Total staff costs
233
201
Other general and administrative expenses1
183
176
Administrative, staff and other expenses
416
377
Depreciation of property and equipment
29
27
Amortisation of intangible assets2
53
40
Total operating expenses (excluding exceptional and other non-recurring items, bank levy and
regulatory charges)
498
444
Bank levy
23
22
Other regulatory charges
10
38
Total operating expenses (excluding exceptional and other non-recurring items items)
531
504
Headline cost to income ratio3
79%
75%
Adjusted cost to income ratio4
74%
66%
Closing staff numbers5 6
3,359
3,330
Average staff numbers6
3,349
3,055
1
Excludes €3m of cost relating to legacy legal cases presented in non-recurring items.
2
Excludes €9m amortisation presented in non-recurring items.
3
Defined as total operating expenses (excluding exceptional and other non-recurring items) divided by total operating income.
4
Defined as total operating expenses (excluding exceptional, other non-recurring items, bank levy and regulatory charges) divided by total operating income.
5
Closing staff numbers are calculated on a full time employee basis.
6
Includes staff on long-term absence, career breaks and maternity leave.
Operating expenses
Staff costs
Staff costs have increased by €32m during 2024, primarily due to an increase in average FTE of 294 across the Bank during 2024,
along with increases in average salaries as a result of performance related pay.
General and administrative expenses
Other general and administrative expenses have increased by €7m during 2024, due to the increase in technology licencing costs and
cost inflation pressures.
Amortisation of intangible assets
Amortisation has increased by €13m when compared to 2023. This is mainly due to increased investment spend in recent years,
which is primarily driven by investment in the Bank’s Digital Banking programme. An additional €9m of accelerated amortisation on
intangible assets was recognised as a non-recurring item during the year.
Adjusted cost income ratio
Total operating expense (excluding exceptional and other non-recurring items, bank levy and regulatory charges) of €498m and total
operating income of €672m for the year ended 31 December 2024 results in an adjusted cost income ratio of 74% for 2024, compared
to an adjusted cost income ratio of 66% for the year ended 31 December 2023. The adjusted cost income ratio has increased during
the year as a result of higher operating costs, with operating income remaining in line with 2023.
Bank levy and other regulatory charges
Bank levy and other regulatory charges amounted to €33m for the year ended 31 December 2024. Other regulatory charges
include €4m for the Central Bank Industry Funding Levy (31 December 2023: €4m) and €2m related to other regulatory charges (31
December 2023: €2m).
Deposit Guarantee Scheme (DGS) fees were €nil (31 December 2023: €28m). The DGS fund reached its target level during 2024, and
therefore future contributions will be based on maintaining the fund at that level. The Single Resolution Fund fee for the year ended 31
December 2024 was €nil (31 December 2023: €4m).
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
25
Impairment
€39m write-back
Table 4: Impairment
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Total impairment write-back on loans and advances to customers
39
2
The impairment write-back is €39m on loans and advances to customers for the year ended 31 December 2024, compared to a write-
back of €2m for the year ended 31 December 2023. This write-back reflects the strong underlying performance and asset quality
within the loan book, together with a favourable macro-economic environment and improved collateral values. €9m of impairment on
deleveraging is presented in non-recurring items.
Exceptional and other
non-recurring items
€21m
Table 5: Exceptional and other non-recurring items
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Exceptional items
Costs incurred in relation to Ulster Bank transaction
-
31
Impairment write-back arising from deleveraging of loans pre-2021
(2)
(5)
Restructuring and other costs
2
2
Other non-recurring items
Impairment charge on Ulster Bank transaction
-
52
Impairment charge on deleveraging of loans1
9
-
Other items2
12
7
Exceptional items and other non-recurring items
21
87
1 Included in IFRS impairment charge
2 €3m included in IFRS administrative, staff and other expenses and €9m included in amortisation of intangible assets relating to 2024
Exceptional items
Exceptional and other non-recurring items, as viewed by Management for the year ended 31 December 2024 is a charge of €21m
which comprises:
Impairment arising from the deleveraging of loans pre-2021
€2m has been released in relation to warranty provisions held on deleveraging transactions that the Group executed in prior years.
Restructuring and other costs
Restructuring and other costs of €2m relate to costs arising in respect of a previous disposal of a business (€1m) and a provision
release.
Other non-recurring items
Impairment charge on deleveraging of loans
An impairment charge of €9m was recognised on the sale of the Glas III portfolio during the year.
Other items
Include accelerated amortisation on intangible assets of €9m and €3m in charges relating to legacy legal cases.
Financial Review
(continued)
PTSB Group Holdings plc - Annual Report 2024
26
Summary consolidated statement of financial position
Table
31 December
2024
31 December
2023
€m
€m
Assets
Home loans
19,629
19,574
Buy-to-let
389
590
Total residential mortgages
20,018
20,164
Commercial mortgages
443
371
Consumer finance (including finance leases and hire purchase receivables)
962
892
Total loans and advances to customers (net of provisions)
6
21,423
21,427
Debt securities
4,327
3,256
Remaining asset balances
3,182
3,072
Total assets
28,932
27,755
Liabilities and equity
Current accounts
9,187
9,329
Retail deposits
13,465
12,320
Corporate and institutional deposits
1,468
1,317
Total customer accounts
8
24,120
22,966
Debt securities in issue
1,731
1,512
Remaining liabilities
549
858
Total liabilities
26,400
25,336
Total equity
2,532
2,419
Total equity and liabilities
28,932
27,755
Liquidity coverage ratio1
255%
220%
Net stable funding ratio2
166%
155%
Loan to deposit ratio3
89%
93%
Return on tangible equity4
7.5%
6.5%
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 after tax less AT1 coupons paid (before exceptional and non-recurring items) expressed as a percentage of targeted CET1 capital
Summary consolidated statement of financial position - key highlights
• Loans and advances to customers (net of provisions) are €21,423m as at 31 December 2024, remaining in line with 2023. An
increase in performing exposures driven by new lending volumes is offset by the reduction of the non-performing loan book due to
the Glas III portfolio sale during the year.
• Debt securities are €4,327m as at 31 December 2024, an increase of €1,071m from €3,256m at 31 December 2023 due to the
purchase of additional bonds in 2024.
• Remaining asset balances are €3,182m as at 31 December 2024, an increase of €110m from €3,072m at 31 December 2023. This
is primarily due to an increase in deposits held with the CBI.
• Customer accounts are €24,120m at 31 December 2024, an increase of €1,154m from 31 December 2023, reflecting a strong
performance in acquiring and retaining Customer deposits.
• Remaining other liabilities decreased by €309m primarily due to a reduction in repurchase agreements at year end when
compared to 2023.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
27
Table 6(a): Summary of movement in loans and advances to customers
31 December
2024
31 December
2023
€m
€m
Gross loans and advances to customers 1 January
21,688
19,804
New lending1
2,442
2,337
Loans migrated1
-
1,490
Redemptions and repayments of existing loans
(2,252)
(1,923)
Write-offs and restructures
(22)
(19)
Net movement from non-performing and other2
(341)
(1)
Gross loans and advances to customers 31 December
21,515
21,688
1 Net of repayments during the year
2 2024 includes Glas III loan portfolio sale
Table 6(b): Composition of loans and advances to customers
31 December
2024
31 December
2023
€m
€m
Residential mortgages:
Home loans
19,539
19,557
Buy-to-let
464
749
Total residential mortgages
20,003
20,306
Commercial
493
437
Consumer finance
553
499
Finance leases and hire purchase receivables
466
446
Gross loans and advances to customers
21,515
21,688
Of which are reported as non-performing loans
382
718
Deferred fees, discounts and business combination related fair value adjustments
300
309
Provision for impairment
(392)
(570)
Total loans and advances to customers
21,423
21,427
Total loans and advances
to customers (net)
€21,423m
Total loans and advances to customers (after provisions for impairment) of €21,423m at 31 December 2024, remained in line with
2023. An increase in performing exposures driven by new lending volumes is offset by the reduction of the non-performing loan book
due to the Glas III portfolio sale during the year.
Total gross new lending for the year ended 31 December 2024 amounted to €2,622m, down 7% from €2,831m in 2023. New
mortgage lending represented 78% of gross total new lending, compared to 82% in 2023, as volumes decreased 12% year-on-year.
However, there was a notably strong performance in the second half of the year where volumes almost doubled those in the first half.
Mortgage applications (+19%) and mortgage approvals (+13%) increased compared to 2023, driven by this strong performance in
H2 2024. PTSB’s mortgage drawdown market share dropped from 19.2% in 2023 to 16.4% in 2024, however closed with a strong Q4
2024 share of 20.2%.
Housing supply has increased based on most recent data showing there were over 60,000 new homes commenced during 2024, up
84% from the circa 33,000 recorded in 2023.
SME lending for 2024 was €213m, which is a 28% increase compared to SME lending for 2023. Asset finance lending for 2024 was
€221m, commercial business to business lending was up 9%, the motor division saw stronger growth in unit stock to the forecourts,
while retail motor finance was marginally back on 2023.
The Group recorded gross new term lending of €132m in 2024. This is a 13% increase compared to 2023.
Financial Review
(continued)
PTSB Group Holdings plc - Annual Report 2024
28
NPLs
NPLs as a %
of gross loans
€382m
1.8%
Table 7: NPLs
31 December
2024
31 December
2023
€m
€m
Home loans
259
403
Buy-to-let
71
267
Commercial
24
20
Consumer finance
20
16
Finance leases and hire purchase receivables
8
12
Non-performing loans
382
718
NPLs as % of gross loans
1.8%
3.3%
Foreclosed assets*
7
11
Non-performing assets (NPAs) **
389
729
NPAs as % of gross loans
1.8%
3.4%
*
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.
NPLs as a percentage of gross loans were 1.8% at 31 December 2024, an improvement of 150bps compared with 2023. The decrease
was driven by the non-performing Glas III loan portfolio sale during the year. We remain committed to providing ongoing support to
our customers as they navigate the impact of increased living costs and higher interest rates.
Customer accounts
€24,120m
Table 8: Customer accounts
31 December
2024
31 December
2023
€m
€m
Current accounts
9,187
9,329
Retail deposits
13,465
12,320
Total retail deposits
22,652
21,649
Corporate deposits
1,468
1,317
Total customer deposits
24,120
22,966
Loan to deposit ratio*
89%
93%
*
Defined as the ratio of loans and advances to customers compared to customer accounts as presented in the SOFP.
At 31 December 2024, customer accounts increased to €24,120m from €22,966m at 31 December 2023, reflecting a strong
performance in acquiring and retaining customer deposits, an increase of 5% since December 2023.
The loan to deposit ratio has decreased due to the increase in customer accounts.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
29
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 to comply with prevailing regulatory
capital requirements at all times. The
policy requires the Group 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. Directive 2013/36/EU
(‘CRD IV’) has been 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’s imposed on the
Group as part of the supervisory SREP
assessment.
Implementation of the CRD IV legislation
commenced on a phased basis from
1 January 2014. The CRD IV transition
rules resulted in a number of deductions
from CET1 capital being introduced on a
phased basis, all of which are now fully
implemented. The ratios outlined in this
section reflect the Group’s interpretation
of the CRD IV rules as published on 27
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,
Capital Management
among other things, will see changes
to the Credit Risk and Operational Risk
frameworks. The Commission expectation
is that the new rules will enhance the
European Union’s banking sector’s
resilience, increase financial stability and
provide the basis for stable funding of the
economy. The amendments will implement
the final Basel III standards, harmonise
supervisory authority powers, introduce
an RWA output floor for banks adopting
an Internal Rating Based (IRB) approach
and bring ESG considerations into risk
assessment. The final elements of the
implementation of Basel III in the European
Union have been agreed and endorsed
by the Council and Parliament and will
be implemented in EU law. In December
2024, the preparatory bodies of the
Council and Parliament have endorsed the
banking package consisting of:
• a legislative act to amend the Capital
Requirements Directive (Directive
2013/36/EU); and
• a legislative act to amend the Capital
Requirements Regulation (Regulation No
(EU) 2013/575).
Co-legislators confirmed that the new
CRR rules will be applicable from 1
January 2025.
The Central Bank increased the
Countercyclical Buffer (“CCyB”) to 1.5% in
June 2024. This is in line with the Central
Bank’s objective of building up the CCyB
to 1.5% when risk conditions are deemed
to be neither elevated nor subdued.
Future CCyB rate decisions will be based
on macro-financial conditions in a manner
consistent with this strategy.
On 26 September 2023, the Central Bank
informed the Group of the outcome of the
annual assessment of Other Systemically
Important Institutions (O-SIIs) in Ireland.
As a result of the assessment, the Central
Bank has assessed the Group as an O-SII
and requires the Group to maintain a 0.5%
O-SII buffer from 1 January 2025.
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 31 December 2024 capital
requirements have been updated to
reflect the Group’s most recent SREP
Assessment.
The Group’s Common Equity Tier1 (CET1)
Capital Requirement of 10.33% (31
December 2023: 9.83%) is comprised of
a Pillar 1 minimum requirement of 4.5%,
P2R of 1.83%, Capital Conservation Buffer
(CCB) of 2.5% and CCyB increased from
1.0% to 1.5% in June 2024.
The Group’s Total Capital Requirement
of 15.25% (31 December 2023: 14.75%)
is comprised of a Pillar 1 minimum
requirement of 8%, P2R of 3.25%, CCB of
2.5% and CCyB of 1.5%.
These requirements exclude Pillar 2
Guidance (P2G) which is not publicly
disclosed.
Capital ratios at 31 December 2024
At 31 December 2024, the regulatory
CET1 is 14.7% (31 December 2023:
14.3%) and total capital ratio is 20.4%
(31 December 2023: 20.0%), exceeding
the Group’s 2024 capital requirement of
10.33% CET1 and 15.25% total capital.
The increase in the transitional CET1 ratio
(+40bps) in the year is primarily due to
increasing capital generated from 2024
P&L profit, partially offset by AT1 coupon
payments, investment in intangible
software assets, and RWA reduction due
to NPL Disposal (Glas III).
The 31 December 2024 leverage ratio
is 7.1% (31 December 2023: 7.3%). The
decrease in the year is primarily due to
increased balance sheet growth, partially
offset by an increase in Tier 1 Capital.
Table 9 outlines the Group’s regulatory
transitional and fully loaded capital
positions under CRDIV/CRR2. At 1
January 2024, all transitional prudential
adjustments are fully phased in and,
therefore, Fully Loaded and Transitional
Capital Ratios are equal.
PTSB Group Holdings plc - Annual Report 2024
30
Table 9: Regulatory capital
31 December 2024
31 December 2023
Transitional
Fully loaded
Transitional
Fully loaded
€m
€m
€m
€m
Capital Resources:
Common Equity Tier 1
1,684
1,684
1,647
1,616
Additional Tier 1
368
368
368
368
Tier 1 Capital
2,052
2,052
2,015
1,984
Tier 2 Capital
292
292
290
290
Total Capital
2,344
2,344
2,305
2,274
Risk Weighted Assets
11,494
11,494
11,546
11,546
Capital Ratios:
Common Equity Tier 1 Capital
14.7%
14.7%
14.3%
14.0%
Tier 1 Capital
17.9%
17.9%
17.5%
17.2%
Total Capital
20.4%
20.4%
20.0%
19.7%
Leverage Ratio*
7.1%
7.1%
7.3%
7.2%
* The leverage ratio is calculated by dividing Tier 1 Capital by gross balance sheet exposure (total assets and off-balance sheet exposures).
Table 10 sets out a reconciliation from the statutory shareholders’ funds to the Group’s regulatory CET1 Capital
Table 10: CET1 Capital
31 December 2024
31 December 2023
Transitional
Fully loaded
Transitional
Fully loaded
€m
€m
€m
€m
Total Equity
2,532
2,532
2,419
2,419
Less: AT1 Capital
(368)
(368)
(368)
(368)
Adjusted Capital
2,164
2,164
2,051
2,051
Prudential Filters:
Intangibles
(144)
(144)
(95)
(95)
Deferred Tax
(312)
(312)
(277)
(308)
Calendar Provisioning
(17)
(17)
(24)
(24)
AT1 Distribution Accrual
(7)
(7)
(7)
(7)
Others
-
-
(1)
(1)
Common Equity Tier 1
1,684
1,684
1,647
1,616
Regulatory capital
The 31 December 2024 regulatory CET1 capital increased by €37m to €1,684m (31 December 2023: €1,647m). The increase is
primarily due to profit recognised in the year (c.+€161m) partially offset by increased prudential deduction for Intangible Assets
(-€49m) and annual phasing of Deferred Tax Asset (-€35m) and AT1 Coupon payments (-€43m).
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
31
Minimum Requirement for Own Funds & Eligible Liabilities (MREL)
The Group’s fully phased in MREL Minimum Regulatory and Combined Buffer Requirement at 31 December 2024 is 28.60% (31
December 2023: transitional of 25.48%) of Total Risk Exposure Amount (TREA) and 5.91% on a Leverage Ratio basis (31 December
2023: 5.91%). The MREL Minimum Regulatory and Combined Buffer Requirement consists of SRB requirement of 24.60% and the
Group’s CBR of 4.0% at 31 December 2024 comprising the CCB of 2.5% and CCyB of 1.5%.
The Group’s MREL position at 31 December 2024 is 35.2% on an RWA basis and 14.0% on a leverage basis. The Group maintains an
internal management buffer over its MREL requirements at all times.
Risk weighted assets (RWAs)
Table 11 sets out the Group’s RWAs at 31 December 2024 and 31 December 2023.
Table 11: Risk Weighted Assets
31 December 2024
31 December 2023
Transitional
Fully loaded
Transitional
Fully loaded
€m
€m
€m
€m
RWAs
Credit risk
9,705
9,705
9,693
9,693
Counterparty credit risk*
112
112
136
136
Securitisation Risk
-
-
-
-
Operational risk
946
946
873
873
Other**
731
731
844
844
Total RWAs
11,494
11,494
11,546
11,546
*
Counterparty credit risk includes Treasury, Repo & CVA RWAs
**
Other consists primarily of Property and Equipment, Deferred Acquisition Costs and Prepayments
The 31 December 2024 RWA’s decreased by €52m to €11,494m (31 December 2023: €11,546m). The decrease is primarily driven by
prepayments partially offset by increased Operational Risk RWAs reflecting profitability of the Bank and increased Credit Risk RWAs
reflecting net loan book growth partially offset by derecognition of NPL disposal (Glas III) RWAs.
Capital Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
32
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 key risks faced by the Group are
appropriately identified, assessed 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
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,
Climate Related and Environmental Risk
(‘CRE’).
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 Bank’s Risk Appetite Statement
(‘RAS’) documents are owned by the
Board, supported by the Chief Risk
Officer (‘CRO’), and describe the Bank’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 Bank’s risk is communicated clearly
and well understood by both Senior
Management and Bank employees so that
risk management is continually embedded
into the Bank’s culture.
The structure of the RAS enables the Bank
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
Bank’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 Bank 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 distinct
key risk categories defined, including
qualitative expressions of risk appetite as
well as quantitative measures i.e., key risk
indicators (‘KRIs’) supporting qualitative
expression. KRIs are monitored and
reported to ensure prompt and proactive
assessment of their impact on adherence
with the Board-approved risk appetite.
The Bank has a straight-forward business
model, to deliver a full-service Retail and
SME Bank with a medium risk appetite
exclusively focused on the Republic of
Ireland.
Risk Governance
The Bank’s risk governance structure
establishes the authority, responsibility,
and accountability for risk management
across the Bank 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 Internal Control Framework (“ICF”),
the Board Manual and the Group Risk
committees’ Terms of Reference.
The design of the Bank’s risk governance
structure is informed by a set of risk
governance principles that 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 Bank. Criteria for
establishing risk sub-committees give
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
Executive and Non-Executive Directors
whose role is to support the Board
in overseeing risk management and
overseeing and challenging Senior
Management’s decisions.
Risk Management
The information in Section 3.1, 3.2 and 3.3 on pages 53 to 66 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 307. All other
information in Risk Management is additional information and
does not form part of the audited financial statements.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
33
Board (Tier 1)
Board Committees (Tier 2)
ExCo and GRC (Tier 3)
ExCo Sub-Committees (Tier 4)
ExCo Indirect Sub-Committees (Tier 5)
Forums (Tier 6)
MA Steering Groups (Tier 6)
Meets as Requires
Board
BRCC
BAC
REMCO
NOMCO
CEO
Executive Committee
ALCO
ESMT
Colleague
Conduct
Committee
Customer
Committee
Group
Expenditure
Committee
Sustainability
Committee
Resilience
Committee
GRC
Tracker
Complaints
Review
Committee
Model
Governance
Committee
Disclosures
Committee
Group Credit
Committee
Operational
Risk
Management
Committee
Impairment
Reporting
Review
Forum
CIE
Resolution
Forum
AMU Credit
Committee
Business
Information
Security &
Technology
Forum
Transactional
Committee
Group Data
Governance
Committee
• Management Committee: Bring
together senior managers in the Bank
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 Bank.
• Independence Safeguards: The
risk governance structure features
safeguards to protect the independence
of key relationships between Senior
Executives and the Board. In this
respect, the ExCo may not override
or modify decisions of the Assets and
Liabilities Committee (ALCo), Group
The diagram below depicts the Bank’s risk governance structure.
Risk Governance Structure
Risk Committee (‘GRC’) or 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 Board Risk and
Compliance Committee (‘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 Bank, the length of time per
meeting, the number of meetings per
year, and the number of meetings
each Director/Executive attends are
appropriate to the Bank’s resources
and business model. This should be
reviewed on a regular basis and the
feedback of the committee members
should be sought.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
34
Key Risk Governance Roles and Responsibilities
Committee/Role
Key Responsibilities
Board
Responsible for the Bank’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 Bank is exposed and establishing a documented Risk
Appetite for the Bank;
• 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.
•
The Board is collectively responsible for the governance of the Bank. Various Committees
assist the Board and Executive Committee in managing and monitoring the risks and opportunities
that sustainability (including CR&E Risk) present. Within the Bank, sustainability is coordinated at
an enterprise-level, with the functions and business segments sharing responsibility for addressing
risks and opportunities.
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 Bank of a supportive
culture in relation to the
management of risk and
compliance.
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 Bank 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 Bank’s risk profile, both current
and emerging, encompassing all relevant risks categories as described in the Enterprise 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;
• Support the Board in ensuring that strategic decisions take into account resolution-related
interconnections impacting resolvability;
• Oversee the achievement of the resolution objectives and the operationalisation of the bank’s
resolution strategy;
• Monitoring and escalating positions outside Risk Appetite to the Board, within agreed
timeframes and approving and overseeing proposed Remediation Plans aimed at restoring the
Bank’s risk profile to within the approved Risk Appetite;
• Reviewing and approving the key components of the Bank’s Risk Management Architecture and
relevant supporting documents;
• Communicating all issues of material Bank 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 Bank’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;
• To oversee the Bank’s approach to complying effectively with its legal/regulatory obligations on
Anti-Money Laundering (AML) and Countering the Financing of Terrorism & Financial Sanctions
(CFT/FS);
• Assess the introduction and management of regulatory developments and horizon risks in
relation to Operational Resilience, Digital Operational Resilience and Third Party resilience.
Communicate material resilience issues to the Board as appropriate;
• Review any changes to the risk strategy resulting from, changes in the business model, market
developments or recommendations made by the risk management function;
• Assess the impact of Climate-Related and Environmental Risk (including financial and credit
risks) on the Bank’s overall Risk Profile;
• Review and monitor the performance, effectiveness and independence of the Risk Function and
the Chief Risk Officer, to whom there shall be solid reporting lines from all Risk and Regulatory
Compliance Functions across the Bank;
• Review and monitor the performance, effectiveness and independence of the Compliance
function and the Head of Regulatory Compliance and Conduct Risk; and
• Promoting a sound Risk Culture across the Bank.
•
The BRCC has delegated responsibility from the Board to assess the impact of CR&E risk
on the Bank’s overall Risk Profile. The BRCC consists of 5 Non-Executive Directors, one of whom
chairs the Committee. The BRCC has approved and provides oversight on the execution of an
enterprise-wide ESG Risk Strategy.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
35
Committee/Role
Key Responsibilities
Executive Committee (ExCo)
ExCo is the Senior
Management Executive
Committee for the Bank and
is the custodian of the Bank’s
collective Strategic Plan,
Medium Term Plan and Risk
Management Architecture as
developed through the annual
Strategic Planning Process
(SPP).
ExCo is the accountable body
for the Bank’s operations,
compliance and performance;
defining the Bank’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 Bank’s
activities are undertaken.
The committee is chaired by
the Chief Executive Officer
(CEO) who is accountable to
the Board.
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 Plan 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 save for those matters reserved for the Board
or its Committees; and
• Ensuring that the operations, compliance and performance (through delivery of the Strategic
Plan and Medium Term Plan, as well as policies, practices and decisions of the Group) are
carried out appropriately, are correctly aligned to the Bank’s Purpose / Ambition and to the
interests of its key stakeholders (customers, colleagues, and shareholders) while operating
within applicable regulatory and legal requirements
• The Executive Committee (ExCo) is the ultimate management committee responsible for
the development and implementation of the Bank’s Sustainability Strategy and CR&E risk
implementation. This will include consideration of the Bank’s sustainability-related IROs.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
36
Committee/Role
Key Responsibilities
Assets and Liabilities
Committee (ALCo)
On delegated authority
from the Board Risk and
Compliance Committee
(BRCC), ALCo reviews, and is
responsible for the oversight
of all activities relating to
Asset & Liability Management
(ALM), Liquidity & Funding
Risk and Market Risks
(including Interest Rate Risk,
Treasury Counterparty risk
and Foreign Exchange Risk),
and Capital Management.
The Committee discharges
this responsibility by
providing governance over
policies, methodologies
and framework documents
deployed to manage the
above risks; and via the
oversight of the activities and
assumptions related to the
coordination of the Bank’s
ICAAP, ILAAP, Recovery Plan
and Resolution Planning.
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.
In addition, ALCo is
responsible for approving
the pricing of new product
offerings or applying material
changes to the pricing of
existing products. ALCo is an
ExCo Sub‐Committee and is
accountable to ExCo.
Key roles and responsibilities of the ALCo, but are not limited to:
• Provision of information to, and production of, the macro-economic assumptions; stress scenario
development; and capital, liquidity & funding elements within the Bank’s Medium-Term Planning
Process (‘MTP’).
• Initial governing body responsible for developing and maintaining the Bank’s recovery plan,
ensuring the accurate and timely reporting of all information required for recovery and resolution
purposes; the implementation of measures necessary to achieve the operationalisation of
recovery and resolution planning strategies, and for overseeing the co-ordination of the Bank’s
compliance in those respects.
• Responsible for overseeing Resolution Planning activity which involves delivering the prescribed
templates/annual submissions and responding to ad hoc information requests, as well as
addressing the priorities identified by the SRB/CBI in their letters to the Bank.
• Provision of information to, and production of, the Internal Capital Adequacy Assessment
Process (ICAAP) and Internal Liquidity Assessment Process (ILAAP); and review, challenge,
provide oversight and submission onward for approval by the Board.
• Monitor the minimum capital requirements set by the Bank's Regulators and the Basel III
minimum Solvency rules, as implemented by the CRD IV Directive and Regulation, detailing the
Pillar 1 minimum capital ratios that the Bank needs to hold.
• Review the Bank's capital position, including an assessment of trends in Pillar 1 and Pillar 2
capital requirements and the Pillar 1 Plus position.
• Maintain oversight and management of the on-going execution of capital-impacting stress
testing exercises. While the Board maintains overall responsibility for the stress testing
programme, it delegates detailed execution responsibilities to ALCo, which scrutinizes practical
aspects including methodologies, translation of macro-economic variables to internal risk
parameters, and assessment of risk correlations/concentrations.
• Consider both the quality and quantity of capital held by the Bank, including the composition
of the Bank's total capital resources (i.e., the preferred split of CET 1, Tier 1, and Tier 2 capital)
while remaining within the parameters of the Risk Appetite Framework, and recommend any
remedial actions to ExCo/Board accordingly.
• Maintain, monitor, and enforce adherence to the Bank’s Risk Management Frameworks and
Policies for all Liquidity, Market, and Capital related risks.
• Oversee and monitor the ALM, Treasury, and Market and Capital risks to which the Bank is
exposed, and consider and approve strategies to mitigate such risks.
• Maintain and assess the ALM, Treasury, and Market, and Capital Risk profiles against set limits
and propose remediation plans to restore Risk Appetite where required.
• Approve the pricing for new products or material changes to the pricing for existing products
which have interest rate or capital implications, as recommended, including overseeing the
inputs for the Bank’s pricing models.
• Approve Funds Transfer Pricing (FTP) methodology, ensuring the process is economically fair,
transparent, and incentivizes appropriate behaviour in accordance with FTP Policy.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
37
Committee/Role
Key Responsibilities
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 Bank-wide
risk management issues and
maintains oversight across
all of the Bank’s key Risk
Categories, excluding those
which fall directly under the
remit of the ALCo.
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 Bank and maintaining a Risk Register of
Top and Emerging risks facing the Bank, together with an assessment of the probability and
severity of those risks;
• Monitoring and reporting on regulatory developments and upstream/horizon risks in relation to
all relevant risk categories and communicating all material issues to the BRCC or the Board as
appropriate;
• Monitoring and assessing the Bank’s risk profile and action trackers against risk appetite and
recommending remediation plans to restore risk appetite where required;
• Reporting any breaches of approved RAS thresholds in accordance with agreed Risk Appetite
Framework;
• Recommending proposed changes to the Bank’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.
Customer Committee
(CustCo)
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.
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 aligned to the Bank’s
strategy;
• 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.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
38
Committee/Role
Key Responsibilities
Sustainability Committee
(SusCo)
SusCo is led by the Board,
and on delegated authority
from the ExCo, the SusCo 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.
The SusCo is chaired by
the Chief Sustainability and
Corporate Affairs Officer
and includes representation
from Executive Committee
members and Senior Leaders
representing business units
across the organisation.
The SusCo is responsible for the delivery of PTSB’s Sustainability Strategy by ensuring that there is
sufficient governance, alignment, oversight and challenge of activity across each of the key area of
focus of the Bank’s Sustainability Programme.
Key activities of the SusCo include, but are not limited to:
• Leading on the implementation and embedding of the Bank’s Board approved Sustainability
Strategy, ensuring that all activity is embedded in the Bank’s ambition, purpose, culture,
corporate strategy and strategic priorities;
• Establishment and oversight of the Bank’s SBTs and delivery of the associated Carbon Reduction
Plan and associated Policies;
• Identifying key stakeholder groups that will be required to deliver on Sustainability Strategy
objectives;
• Assigning business owners to manage and deliver sustainability programming across the key
areas of focus set out within the Sustainability Strategy;
• Developing sustainability Key Performance Indicators (KPIs) and processes that enable the Bank
to effectively measure and manage them; and
• Monitoring and reporting progress to the Board and Executive Committee at regular intervals
throughout the year.
Group Credit Committee
(GCC)
GCC oversees and is
accountable for the execution
and delivery 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 Bank are
approved and are enforced.
It operates as the forum for
Bank-wide portfolio credit
risk management issues
across the full Credit Risk
Management Lifecycle. GCC
is a sub-committee of GRC.
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 Bank’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.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
39
Committee/Role
Key Responsibilities
Operational Risk
Management Committee
(ORMC)
ORMC is a sub-committee of
the Group Risk Committee
(GRC), established with
delegated authority to
operate and make decisions
in accordance with the Terms
of Reference approved by
GRC. GRC retains overall
responsibility for the
oversight of Operational and
Information Communication
Technology (ICT) risks.
ORMC is responsible for supporting GRC in monitoring the Operational and ICT risks to which the
Bank is exposed and for overseeing risk mitigation performance and prioritisation related to the
management and control of these risks. It supports the activities of the GRC in it’s monitoring and
enforcing adherence to the Bank’s Risk Frameworks, Policies and Limits. In fulfilling this role, 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 assessments (including New
Product Approval (NPAP) and Third Party Risk Management (TPRM) assessments), monitoring
and testing activities to create awareness of commonly experienced Operational and ICT risk
matters, to share learnings and to enhance the control environment across the Bank. The key
responsibilities of the ORMC include, but are not limited to:
• Oversee the implementation of the Bank’s Operational and ICT Risk Management Frameworks,
including compliance with relevant Operational and ICT risk policies and procedures;
• Monitor the implementation of policies and ensure ongoing adherence through operational
controls;
• Review and approve Operational and ICT Risk policies, as agreed with the Chair of GRC,
(via delegated authority from GRC) and recommend approval of Operational and ICT Risk
Frameworks to the GRC (and subsequently BRCC);
• Review and recommend approval of qualitative and quantitative Operational and ICT Risk
appetite metrics and limits/thresholds to GRC, report any breaches in accordance with the
agreed process and recommend remediation plans where required;
• Appraise Material Operational and ICT 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 Operational and ICT Risk
events;
• Develop, review and recommend approval of scenarios relating to potential Operational and ICT
risk events in order to inform the Bank’s capital assessment processes (e.g. ICAAP and Stress
Testing) and submit these to the GRC for their review and approval; and
• Review and evaluate Operational and ICT risk developments including peer, regulatory, and
industry developments, and external incidents that may impact the Bank directly, or relate to
potential risks.
Role of the Chief Risk Officer (CRO)
The CRO has independent oversight of the Bank’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 Bank is, or may become, exposed. The CRO is a
member of the ExCo and directly manages the Bank’s Risk function.
The CRO has a direct reporting line to the Board and the Board Risk and Compliance Committee. In line with this reporting mandate,
the Chief Risk Officer has a right of escalation and can refer any decision of ExCo or the ExCo Committees/Sub-Committees to the
Board Risk and Compliance Committee (or Board) for review.
The CRO has overall responsibility for overseeing the development and implementation of the Bank’s Risk function (incl. Compliance
function), including overseeing development of the Enterprise Risk Management Framework, supporting frameworks, policies,
processes, models and reports and ensuring these are sufficiently robust to support delivery of the Bank’s strategic objectives and all
of its risk-taking activities.
The CRO is accountable for developing and maintaining the Group’s RAS Framework, 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 Group. 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
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
40
independent review and participation in the Group’s Strategic Planning Process (SPP), capital and liquidity planning and the
development and approval of new products. Specifically, the CRO is tasked with:
• Providing Second Line Of Defence assurance to the Board across all key risk categories;
• Providing independent advice to the Board on all key 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, 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 structure.
• 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 risk appetite and
managers take risks appropriately.
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 clear 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.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
41
Line Of Defence
High-Level Roles And Responsibilities
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.
Second Line – Group Risk Function
• Developing and monitoring the implementation of the 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.
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 insights into risk, governance and control measures which may
strengthen the bank’s system of internal control in a carefully structured manner
such that GIA’s independence is preserved.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
42
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 GRC, BRCC and
Board and is used to ensure identification,
measurement, management and
monitoring of all material risks.
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.
The challenging conditions in global
markets arise due to factors including the
Middle East and Ukraine-Russia conflict,
inflationary pressures, 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 several of
these are outside of the Group’s control.
As at 31 December 2024, the following are
the top three emerging risks considered
by the Bank.
• Political, regulatory and supervisory
disruption: political polarisations will
increasingly impair geo-political stability
and create an uncertain business
environment. Sound regulation and
supervision are important for the
financial sector stability, with high
expectation from all stakeholders
that regulatory requirements are
delivered within prescribed timeframes
(Payments). Not complying with
requirements will be met with potential
fines and supervisory measures.
Compliance to requirements can crowd
out other strategic investments that
impacts competitive position relative to
less regulated digital disruptors / non-
bank lenders.
• Process & Ability to Execute risk:
process and execution risk can
significantly impact PTSB’s operational
risk, leading to higher loss risk,
impacting operational resilience,
customer dissatisfaction, a loss of
trust and limit’s ability to realise stated
ambition (especially against the risk
of optimistic bias in forecasting). Risk
is linked with internal complexity, a
high volume of change, increasing
collaboration with third parties and
outsourcing providers, people risk
and transition speed. Making end to
end processes more digitally straight
forward is necessary to reduce
complexity and embed / automate
controls, and consistent customer
service quality.
• Technology disruption / New Market
entrants: new technologies are
disrupting the traditional financial
landscape, directly impacting the
intermediary (banks) at their core.
Central banks are actively exploring
digital currencies which could allow
them to directly fund customers and
by-pass the traditional role of banks,
especially impacting traditional retail
deposit banks like PTSB. Technology
change combined with regulatory
change Payment Services Directive
2 (PSD2) provides core insights to
new entrants and accelerates access
to market, with potentially significant
competitive disruption.
Economist Update
Introduction
The geopolitical backdrop has become
much more uncertain in the last year.
While the conflicts in Ukraine and the
Middle East remain unresolved, there is
political upheaval in Europe as it struggles
with anaemic growth. The prospect of a
trade war with the US complicates the
outlook still further.
Inflation Rates and Interest Rates
Whereas the ECB raised its deposit rate
from 0% to 4.5% over the year starting
in September 2022 to dampen inflation,
it is now focused on reducing rates to
address weak growth. Inflation in the
Eurozone was below 3% throughout 2024
having peaked at 10.6% in October 2022.
Although inflation remains above the
ECB’s 2% target, nevertheless the market
expects the ECB to reduce the deposit
rate to 2% by the end of 2025.
The CSO reports that the Irish consumer
price index “rose by 1.4%” during 2024
compared with 4.6% a year earlier.
However, the Irish Fiscal Advisory Council
(IFAC) highlights that falling energy prices
have masked increases in domestic prices
such as “rent, restaurants and cafés.” The
IMF notes that while global disinflation
continues, “there are signs that progress
is stalling in some countries and that
elevated inflation is persistent in a few
cases.”
Economic Outlook / Growth
Eurostat reports that EU GDP grew by just
1.1% in 2024 compared to a rate of 2.8%
in the US. Although Irish GDP contracted
by 1.1% in 2024 “on the back of large
intellectual property investment outflows
and increased imports”, the ESRI notes
that modified domestic demand grew by
3.2% in 2024 and it expects it to grow
by 4.1% in 2025 “driven by real income
growth and higher housing investment.”
The IMF projects global growth “at
3.3% both in 2025 and 2026, below the
historical (2000–19) average of 3.7%” and
Euro area and US growth in 2025 of 1.0%
and 2.7%, respectively.
Davy suggests that “real economic growth
in excess of 4% a year is attainable for
the Irish economy this decade.” It notes
that “growth momentum has picked up,
helped by rising real household incomes
as inflation declined and wages grew.”
But it cautions that “Ireland, being a
small open economy with an outsized
proportion of US multinationals is at risk
from a worsening relationship between
the US and EU.” The NTMA emphasises
that Ireland has a younger population than
the European average and notes that this
“helps growth potential”.
While the Services PMI fell from 57.1
in December 2024 to 53.4 in January
2025 as growth slowed, firms remained
“strongly positive for 2025”. The
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
43
Manufacturing PMI rose from 49.1 to
51.3 over the same period having spent
much of 2024 below the 50 breakeven
mark. The December 2024 PMI readings
for services and manufacturing for the
Eurozone were 49.6 and 45.1, respectively.
Government Finances
The NTMA reports that Ireland’s Debt-to-
GNI (modified gross national income) was
69% at the end of 2024 down from 76% a
year earlier. With an average interest rate
of 1.4%, an average maturity of 10.2 years,
a fiscal surplus of €8bn for 2024 and a AA
rating all the major rating agencies, NTMA
notes that “Ireland’s debt fundamentals”
are now similar to those of the EU ‘core’
countries, Germany, the Netherlands and
Austria. Debt-to-GNI is projected to fall
further in the coming years because of
nominal growth and budget surpluses.
However, the Department of Finance
cautions that “at just over €42,000 per
person, Ireland has one of the highest
gross public debt levels in the world.”
The IFAC highlights the “significant risk
that fiscal policy becomes excessively
expansionary in the coming years, while
the economy is already performing
strongly.” Once again it emphasises
Ireland’s dependence on “extraordinary
corporation tax receipts”, without which
“the government would be running a
deficit of €6.3 billion in 2024.” It notes that
the two new funds the Government has
established will save roughly one-third
of the “windfall” element of corporation
tax, the excess relative to what can be
explained by growth in the domestic
economy, most of which is accounted for
by just three companies. It recommends
saving more of these windfall receipts.
While acknowledging IFAC’s concerns
and highlighting that “gross voted current
spending in 2024 was €29bn, or 48.3%,
higher than in 2019, indicating a very
rapid annual increase of 8.2% a year”,
Davy suggests Ireland’s “favourable debt
dynamics” are set to continue “mainly
as a result of the impact of Pillar II of the
OECD’s Base Erosion and Profit Shifting
reforms.”
Employment
Observing that “Ireland’s jobs market
has never been tighter”, IFAC comments
that with 85% of the population aged
25-54 in employment, “there has
never been a greater share of people
working in Ireland’s history.” It notes that
“employment has grown by 18% since
2019.” The CSO reports that 2.8m people
were employed in Q4-24, up 3.7% from
the previous year while the unemployment
rate was 4.5% and the job vacancy rate
was 1.2%. The NTMA notes that the
unemployment rate has been below 5%
for the past two years, the longest such
period ever recorded.
The CSO also reports that average weekly
earnings were up 5.3% in Q3-24. IFAC
highlights that average real wages are
“11.7% above 2019 levels” while Davy
emphasises the difference between
sectors of the economy: “As of Q3 2024,
the figures indicate that the average
wage for an employee of a foreign-
owned company in Ireland was c.€77,500,
whereas the equivalent for an employee
of a domestic-owned company was
€59,900.”
Banking
The Irish banking system remains
characterised by an excess of deposits.
The Central Bank reports that household
deposits increased by €6.9bn or 4.5% in
2024. It notes “this movement was driven
by deposits with an agreed maturity of up
to 2 years, which recorded a €7.3 billion
increase in the period, while overnight
deposits remained in negative territory,
decreasing by €962 million.” It comments
that overnight deposits represent “87%
of the total stock of household deposits”
down from 93.8% in April 2023. The
European average is 54%. It further notes
that net lending to households increased
by €3.2bn or 3.1% in 2024 comprising
€2.5bn of loans for house purchase and
€952m of loans for consumption.
The Central Bank assesses that “domestic
bank profitability has likely peaked.”
Tracker mortgages and Central Bank
deposits, two of the largest asset
categories on Irish bank balance sheets,
will see lower returns in 2025. The Central
Bank concludes: “Net interest income, the
main source of profitability for Irish banks
is likely to decline as ECB policy rates
continue to fall.” It notes that “domestic
banks rely more on net interest income
and customer deposits than European
peers.”
The Central Bank notes that the
“aggregate debt service burden of the
household sector has remained stable
since 2022, with higher loan repayment
amounts being offset by rising incomes.”
It calculates “the debt service ratio for
the household sector – the ratio of debt
repayments to total disposable income
– has remained stable at approximately
9%. This follows a period of household
deleveraging and a substantial decline in
mortgage interest expenses between the
GFC and 2022.”
The Central Bank concludes: “The
banking sector is well placed to weather a
softening in profits, with non-performing
loan ratios continuing to decline,
and capital buffers above regulatory
requirements.” It is “maintaining an
unchanged policy stance with respect
to active macroprudential capital buffers
(i.e. CCyB, O-SII) which continue to
provide resilience to adverse shocks.” It is
retaining the CCyB rate of 1.5%, the rate
it adopts “when cyclical risks are neither
elevated nor subdued.” It further notes
that despite excess demand, there are no
signs of significant increases in mortgage
credit growth, which “remains moderate.”
BPFI reports that 43,000 mortgages
valued at €12.6bn were drawn down in
2024. Drawdown volumes fell by 1.3%
compared to 2023 while values rose
by 4.0%. Davy comments: “After almost
a decade and a half of deleveraging,
mortgages have returned to growth in
the past two years, albeit at lower than
desired levels. The mortgage market
has been subdued in recent years, with
lower-than-expected activity due to
1) lower new completions and 2) low
levels of liquidity in the existing homes
market.” It forecasts “an increase in new
mortgage lending from €12.6bn in 2024
to €13.8bn and €14.8bn in 2025 and 2026
respectively”, reaching €22.1bn by 2031.
Davy projects that as housing output
increases, the proportion available for
sale to homeowners will likely decrease
“mindful that large increases are coming
from social housing and apartments.”
It projects “the percentage of new
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
44
completions mortgages declines from
36% in 2024 to 25% by 2031” while
50% of existing home purchases will
continue to be financed with a mortgage.
It estimates the stock of mortgages
will grow €2.5bn to €88.5bn in 2025 as
€14bn of new mortgages are issued while
€11.5bn of existing mortgages are repaid.
Housing
New dwelling completions disappointed in
2024, falling 6.7% to 30,330 from 32,695
in 2023. While the number of scheme
dwellings increased by 4.6%, the number
of apartments declined 24.1% to 8,763
according to the CSO. Completions in
Q4-24 were 14.5% lower than the same
quarter in 2023. However, new housing
commencements jumped 84% in 2024
to over 60,000 units, the highest levels
since the mid-2000s, which, Davy notes,
were driven by policy incentives on
development.
BPFI points to the resource challenge. It
notes that there were “237,000 people
employed in the construction sector in
the third quarter of 2007” compared
with 176,000 people Q3-24. It further
highlights that “in addition to addressing
the housing deficit, the construction
sector is likely to face significant capacity
constraints with pressure from other
sectors of the economy needing similar
resources particularly for the requirements
arising from the climate action plan.” The
Central Bank highlights some of the other
challenges including delays in the planning
system, a shortage of zoned and serviced
land, as well as the poor productivity of
the construction sector compared to other
European markets.
Various studies report a much greater
need for housing than the 50,000 units
per year which was often cited previously.
Davy estimates a pent-up demand for
230,000 homes, more than 10% of the
housing stock. It forecasts Ireland’s
population “will reach 6m by 2031 and that
it will take close to 93,000 new units each
year for the housing stock per adult to
return to its previous ratio of 0.55 by then”
commenting that this would still be at
the bottom of the range for high-income
European countries.
The new government has extended of the
Help to Buy and First Home schemes to
2030 and proposed to expand the First
Home Scheme to include existing homes.
Davy comments that the Government’s
plan to deliver 300,000 homes over the
next five years “would be a material
increase over the last five years of
c.135,000.”
House Prices
The national Residential Property Price
Index (RPPI) increased by 9.4% in the 12
months to November 2024 compared to
3% for the same 12 months a year earlier
according to the CSO. The national index
is now “16% above its highest level at the
peak of the property boom in April 2007”
and 158.7% above its trough in early 2013.
However, the ESRI notes that in real terms,
house prices in December 2023 “are
actually 13% below the peak value.”
The Central Bank comments: “An ongoing
deficit in housing continues to drive
residential property price growth … The
acceleration in house price growth occurs
against the backdrop of an ongoing
imbalance in the supply and demand
of housing.” An ESRI report questions
“the capability of certain cohorts of the
population to engage in homeownership,
as both the debt service ratio (DSR) and
house price-to-income ratio are increasing
significantly.” It suggests “Irish house
prices are over-valued by somewhere in
the region of 8 to 10%.”
However, Davy finds “that Ireland’s price-
to-income ratios are not misaligned either
in historical or international terms” and
forecasts continued growth in residential
property prices in 2025 (7%) and 2026
(5.5%).” BPFI notes that “notwithstanding
the fact that the main ECB rates are
close to their highest levels since 2008,
average price inflation in the housing
sector gained momentum mainly due to
low housing stock and continuing housing
and mortgage demand amid growing
employment and income levels.”
Overall Position
The outlook for next year is clouded. As
Davy notes, the muted outlook for growth
in the Euro area economy, geopolitical
tensions, “greater protectionism and the
prospect of a trade war between the EU
and the US are now clear risks.” Ireland
as a small, open economy is especially
exposed.
And Ireland’s infrastructure deficit is
likely to continue to impede progress.
As IFAC notes: “One of the major
challenges facing Ireland’s governments
over the past decade has been efforts
to improve Ireland’s infrastructure”
which is 20–25% behind its peers.
While the biggest shortfall is in housing,
significant investment in water and
energy infrastructure will also be needed.
As the Department of Finance notes,
“structural economic changes (the ‘4Ds’:
shifting demographics, decarbonisation,
digitalisation and de-globalisation) pose
significant challenges for the public
finances.”
Despite the many uncertainties, the
outlook for the economy remains positive.
Lower inflation and interest rates will
help the consumer. As the NTMA notes:
“Household balance sheets are not heavily
indebted. Mortgage debt is mostly fixed
at low rates for the next few years.”
Consumer spending and investment are
both expected to grow as the labour
market is expected to remain strong. They
may prove sufficient to keep the economy
on a steady growth path.
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
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
45
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, 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.
Climate-Related & Environmental
Risk
PTSB is committed to the management of
Climate-Related & Environmental (CR&E)
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.
Managing CR&E Risks and opportunities 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.
Through this Strategy, the Bank is working
to manage and mitigate against CR&E
Risk, while also finding new and innovative
ways to help our stakeholders to navigate
the transition to a low carbon economy.
This is complemented by “Sustainable
Business Growth” as one of the refreshed
Strategic Priorities outlining the Bank’s
commitment to building a sustainable
organisation that is fit for the future.
PTSB has formally defined CR&E Risk,
categorising into two Sub-Risk Categories
as follows:
1. Physical Risks - The risk of economic
cost and financial losses resulting from
the increasing severity and frequency of:
• Acute Physical Risk – arises from
extreme weather events such as floods,
storms, droughts and heatwaves.
• Chronic Physical Risk – arises from
longer-term gradual shifts in the
climate patterns, such as increasing
temperatures, sea-level rises, water
stress, biodiversity loss, land use
change, habitat destruction and
resource scarcity.
2. Transition Risk - The risk of economic
cost, financial loss or an adverse outcome
related to the process of adjustment
towards a low-carbon economy and more
environmentally sustainable economy.
Transitioning to a low-carbon economy
may require substantial policy, legal,
technology and market changes. These
changes may result in financial loss and
reputational risk to organisations, with the
severity of this depending on the scope
and speed of change required. Transition
Risk may include:
• Policy Risks that come with the
evolution of policies and regulations
that promote the adaptation to a less
carbon intensive and more sustainable
economy, and those that constrain
actions that lead to climate change and
harm the environment.
• Legal Risk that relates to litigation
claims against institutions and their
representatives who fail to mitigate
and adapt to climate change, and who
fail to disclose material climate and
environmental information.
• Market Risks that arise through
changing demand and supply for
commodities, products and services.
• Reputation Risk that relates to the
changing stakeholder perception of
institutions’ contribution to or detraction
from the transition to a lower-carbon
economy.
The management of CR&E risk is aligned
to key processes and components
set out in the Bank’s Enterprise Risk
Management Framework (ERMF), which
identifies core risk management stages
which collectively ensure that the Bank
appropriately identifies and manages
current and emerging risk the Bank is
exposed to. Consideration of the impact
of CR&E risk on each of the risk categories
has been considered as part of the Banks
2023 CR&E Risk Materiality Assessment.
Through this assessment, the Bank
recognises that CR&E risk is a cross-
cutting risk, which may impact or enhance
other identified risk.
The Bank has established strong
governance structures surrounding
CR&E Risk. During the first half of 2024,
the Bank evolved its Sustainability
Programme to include eight underlying
workstreams, one of which is focused
on CR&E Risk Management. The
Sustainability Programme is led by the
Sustainability Committee (SusCo). The
SusCo acts on delegated authority from
the ExCo, to provide oversight in line with
supervisory expectations on the execution
of the Bank’s Sustainability Strategy by
ensuring that there is sufficient oversight,
alignment, governance and challenge
of activity across key areas of focus
for the Bank. Supporting the SusCo, a
Sustainability Programme Direction Group
(PDG) is in place, consisting of members
from the Bank’s Senior Leadership Team
with enterprise-wide representation to
ensure a holistic and integrated approach
to support execution.
The management of CR&E Risk is aligned
to key processes and components
set out in the Bank’s Enterprise Risk
Management Framework (ERMF),
which identifies core risk management
stages which collectively ensure that
the Bank appropriately identifies and
manages current and emerging risk the
Bank is exposed to. Consideration of
the impact of CR&E Risk on each of the
risk categories has been considered as
part of the Bank’s CR&E Risk Materiality
Assessment. This assessment served as
a foundational exercise to understand
and assess CR&E Risk as an impact and
driver of traditional Risk Categories and
the Bank’s exposure to same. As such, the
Bank recognises that CR&E risk is a cross-
cutting risk, which may impact or enhance
other identified risk.
Over the last number of years, the Bank
has made progress integrating CR&E Risk
considerations into operational processes
and strategic decision-making. PTSB
deployed resources to ensure the delivery
of the CR&E Risk Implementation Plan,
that has been closed and is proactive
in and committed to maturing this
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
46
integration into 2024 and beyond. This
work established the Bank’s baseline
position and enabled the organisation to
make progress across a number of areas.
A summary of progress includes:
• Establishing effective governance for
the management of CR&E Risk across
the Bank;
• Introducing the first enterprise-wide
CR&E Risk Management Framework
(CR&E RMF);
• Preparing a CR&E Risk Qualitative
Materiality Assessment to assess and
understand CR&E Risk as an impact and
drive of traditional Risk Categories;
• Developing CR&E Key Risk Indicators;
• Sourcing and integrating CR&E Risk
data for Bank use to inform CR&E Risk
analysis;
• Implementing a CR&E Risk Stress Test
aligned closely with the ECB Stress Test
Methodology;
• Integrating CR&E Risk into the Bank’s
ICAAP and ILAAP processes;
• Ensuring CR&E Risk is considered in the
Bank’s product development through
the establishment of Green Product and
Proposition Design Principles; and,
• Establishing a Science Based Targets
for emissions reductions Programme.
The Bank has mobilised investment
toward positive CR&E Risk activity by
supporting customers and counterparties
in navigating their transition to a low
carbon economy. CR&E Risk is considered
in the Bank’s product development
process through establishment of Green
Product and Proposition Design Principles.
The Bank has made progress, including:
• c.€875m in Green Mortgage Lending
in 2024 accounting for 43% of New
Mortgage Lending;
• Participation in the SBCI Growth and
Sustainability Loan Scheme, offering
€70 million in low-cost loans to SMEs;
• €100 million in funding as part of SBCI
Home Energy Upgrade Loan Scheme
– first lender to launch the Scheme; and,
• €500m Green Senior HoldCo, the first
Green Bond issuance under the Bank’s
Green Bond Framework. The Bond
issued on 10 April with maturity date 10
July 2030 (first call 10 July 2029).
These developments make up the first
steps towards an envisioned suite of
Sustainable Finance Product offerings,
with proposition development continuing
on future products.
As CR&E risk continues to evolve, the
potential effect of Physical (Acute &
Chronic) and Transition Risk on the
Bank will be continually reviewed. The
assessment of effects as set out in the
CR&E Risk Materiality Assessment will
develop over time as the Bank sources
critical data to incorporate quantitative
analysis. This is supported by the Bank’s
Data Remediation Programme, which has
dedicated resources in place to support
and further develop CR&E Risk data
availability and granularity.
While the Bank is focused on short-term
action delivery and stepping up the pace
in embedding CR&E risk, it is mindful of
creating capacity and building a robust
long-term strategic approach to CR&E
risk, which aligns to best practice. This
will ensure there is a comprehensive
integration within Strategy, Data, Risk
Management and Product Strategy,
supported by enabling activities such as
training and disclosures.
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 risk exposures 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
• The sales 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 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 regulatory and Supervisory
Review and Evaluation Process (capital
requirements). The ICAAP is subject to
review and evaluation by the CBI as part
of its Supervisory Review and Evaluation
Process.
The management of capital within
the Group is monitored by the BRCC,
ExCo and ALCo in accordance with the
Board-approved capital adequacy risk
management framework.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
47
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 completion
of the first phase the Ulster Bank
transaction, combined with the recent
disposal of an additional 5% tranche in
2023, has further reduced the Minister for
Finance’s stake to c.57%.
The risk is that the Irish Government,
through its direct majority 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 and changes in credit
ratings or market dislocation. The level
of Liquidity Risk further depends on the
size and quality of the Group’s liquid asset
buffer, the maturity profile of funding,
as well as broader market factors such
as depositor and investor sentiment/
behaviour.
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 deposits into longer term loans.
The Group’s Risk Appetite Statement
and the associated Liquidity & Funding
Risk Management Framework set out the
Group’s approach to the management of
Liquidity & Funding Risk, including the
Group’s approach to risk identification,
assessment, measurement, monitoring,
mitigation and reporting. The Liquidity &
Funding Risk Framework is approved by
the BRCC on the recommendation of the
ALCo.
The management of the Group’s liquidity
and funding risks 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
liquidity and funding risk. Group Risk
and GIA provide further oversight and
challenge and ensure compliance to
the Group’s Liquidity and Funding Risk
Management Framework.
For further details on Funding and
Liquidity Risk, see section 3.2.
Market Risk
Market Risk is 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
Foreign Exchange Risk. These risks are
covered in detail in section 3.3.
The Group’s Risk Appetite Statement 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 and BRCC on a regular basis.
Group Treasury is responsible for the
management of market risk exposures on
the balance sheet. Group Risk and Group
Internal Audit provide further oversight
and challenge of Group Treasury’s
compliance with the Market Risk
Framework and associated Policies.
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 Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
48
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 ERMF. This
provides the basis for the Group Model
Risk 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
(Group Risk Committee), is the primary
body for overseeing model risk. The
Group RAS (Risk Appetite Statement)
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 monthly to Group
and Board Risk Committees with more
detailed papers as necessary to focus on
key issues.
Operational Risk and ICT 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: operational resilience & business
continuity; third party and outsourcing;
business process; fraud; legal; people;
property; change and data management
risk.
ICT 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 Communication Technology
(‘ICT’) within a reasonable time and with
reasonable costs when the environment
or business requirements change (i.e.
agility). ICT Risk includes risks associated
with poor ICT governance, oversight and
risk management as well as security risks
resulting from inadequate or failed internal
processes or external events including
cyber-attacks or inadequate physical
security.
Risks from both these risk categories are
inherently present in the Group’s business.
Any significant disruption to the Group’s
ICT 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’s Operational Risk and ICT
Risk Management Framework outlines
the Group’s approach to managing
Operational and ICT risks and associated
risk exposures and is applicable Group-
wide. The Framework outlines the specific
governance structures and processes
that enable the management of the Bank’s
Operational & ICT Risks, it defines the
roles and responsibilities for the oversight
of Operational and ICT risks, along with
the ownership and processes in place for
the identification, assessment, mitigation,
monitoring, testing and reporting of
Operational and ICT risks in the Group.
In support of the above, the Group utilises
a Risk and Control Self-Assessment
methodology to:
• Identify, measure and control
Operational Risk, Information
Communication Technology (ICT)
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.
• Support the ability to track any control
design or operational effectiveness
deficiencies that are identified through
the process. This ensures that
comprehensive remediation plans are
created, monitored and tracked through
to closure.
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.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
49
External Fraud remains at a high threat
level with many customers targeted/
responding to fraudulent SMS and
phone calls in circulation, divulging their
credentials to fake websites. There
has been a significant increase in this
activity since 2020 and PTSB have been
recognised as being to the fore in seeking
ways to protect our customers and the
bank. We continue to work on our own
initiative but also collectively with many
external stakeholders i.e. other FI’s,
BPFI, CBI, UCD Cyber Centre, Gardaí,
ComReg, Telco’s and Fintech to reduce
impact. The creation and launch of “PTSB
Protect” to our customer base and added
to our app as an opt-in solution in October
2023 will inform customers using the
service of known fake SMS being received
to their Smart phone. PTSB Protect is the
first of such technology to be deployed
by any bank. We have also enhanced
our fraud monitoring capabilities in the
card transactions space in November
2023 with the ‘Foresight’ fraud scoring
tool added to our strategies, this is
currently proving beneficial from both a
fraud prevention and customer impacting
perspective. By continuing to innovate and
react to the ever changing environment,
we can continue to maintain best in class
status, whilst maintaining a balance
between providing a frictionless customer
journey but also managing the risk.
The external cyber threat environment
continues to evolve, and remains a
challenge to the Banking industry globally.
Continuous improvement in our cyber
defences is a strategic priority with
investment accordingly to enhance the
control environment.
The Bank’s Cyber and Information Security
Strategy (2022-2024) was approved
by the Board Risk and Compliance
Committee (BRCC) in February 2022.
This is driving further improvements in
the Bank’s cyber defence, along with
associated governance. Promoting
information security awareness at all
levels of the Bank is also a key feature
of our approach. The Bank’s Chief
Information Security Officer (CISO) will
present a refreshed Cyber and Digital
Resilience Strategy (2025-2027) to BRCC
in December 2024.
Scenario testing is performed on an
annual basis, as outlined in the Enterprise
Risk Management Framework (ERMF), for
critical processes including but not limited
to: Payments Systems Failure, Information
Security, Cyber Security, Internal Fraud,
Business Disruption and ICT 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 ICT 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 ICT systems or applications
are governed by a change management
process.
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.
Risk culture is a component of the Bank’s
culture. A sound risk culture drives
and supports risk awareness, desired
behaviours and judgements about
risk-taking. It bolsters effective risk
management, promotes prudent risk-
taking, and ensures that any emerging
risks or risk-taking activities beyond
the Bank’s risk appetite are identified,
assessed, escalated and managed in
a timely manner. 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.
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 ‘Third Party
and Outsourcing Risk’ and is defined as
the 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 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 identification
management and mitigation of Third
Party and Outsourcing risks across the
Group, as defined in the Group’s ERMF,
and Operational and IT Risk Management
Framework. The policy outlines the
processes and controls required for
identifying, assessing, mitigating and
managing these 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;
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
50
• 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.
The Group recognises that the
management and mitigation of Conduct
Risk is fundamental and intrinsically
linked to the achievement of our purpose
‘Working together to build trust with our
customers and communities’. 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 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. 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 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 economic 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 moved
from a Less Significant Institution (LSI) to
an Other Systemically Important Institution
(OSII) in November 2023 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
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 Central Bank (Individual
Accountability Framework) Act 2023 (IAF)
introduced the Individual Accountability
Regime for Banks and other regulated
entities. The Group has focused on
implementation measures to ensure
compliance with the new Conduct
Standards and enhancements to the
Fitness and Probity and Administrative
Sanctions regimes which came into
operation on 29 Dec 2023 and the Senior
Executive Accountability Regime (SEAR)
which has been in effect from 1 July 2024.
First Line Assurance teams are in
place with the Regulatory Compliance
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.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
51
The Group is exposed to many forms of
risk in connection with compliance with
such laws and regulations, including, but
not limited to:
• 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
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.
Regulatory Developments
The level of regulatory change remains
high and continues to be an area of focus.
Sustainability and climate change
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 is expected
to be finalised in late 2024 or early 2025,
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 in their own operations and
through their value chains with member
states having 2 years to transpose into
law.
Legislative progress continues on the
implementation of the Basel III reforms,
the Capital Requirements Regulation
3 (CRR3) and Capital Requirements
Directive 6 (CRD6) were adopted by
the European Council (EC) in May 2024
and became effective on 9th July 2024.
CRR3 will apply from January 2025
and member states have 18 months to
transpose CRD6 into national legislation.
Both are aimed at enhancing prudential
regulatory standards, supervision, and risk
management of banks. The EU payments
package, which includes the introduction
of a Digital Euro and other legislative
proposals and policy initiatives aimed
at improving the payment experience
of consumers and businesses, is also
progressing through the EU legislative
process. Further progress is expected on
these proposals in early 2025. The EC has
introduced legislation aimed at increasing
the availability and use of Instant Credit
Transfers in Euro from January 2025. In
line with the objectives of the EU Digital
Finance Strategy, the Digital Operational
Resilience Act (DORA) will apply in
full from January 2025. The revised
Consumer Credit Directive and the revised
Distance Marketing Directive have both
been published and they come into effect
in 2026. The new EU Artificial Intelligence
Act, which was published in June 2024,
comes into effect on various dates from
late 2024 to mid-2027.
The EC’s new legislative package
designed to strengthen the EU’s anti-
money laundering and countering
the financing of terrorism (AML/CFT)
rules entered into force in July 2024.
Key components of the new package
include (a) the establishment of a new
AML Authority (AMLA) which will have
direct supervision of a certain number
of selected obliged entities in the
financial sector along with co-ordination/
oversight powers in relation to member
state AML/CFT supervisors and (b) the
new AML Regulations which will from
July 2027. From a sanctions perspective,
with the continued conflict in Ukraine,
Middle East, amongst other geo-political
developments, it is anticipated that the
EU sanctions regime will be kept under
regular review.
Following the completion of the Irish
Governments Retail Banking Review, the
Access to Cash bill has been published
and legislation is expected to be enacted
in November for commencement in
January 2025.
The Central Bank is progressing its review
of the Consumer Protection Code (CPC).
A consultation paper, containing draft
requirements, was published in March
2024, with the revised CPC expected
to be published in early 2025 with a
12-month implementation timeline.
Regulators continue to emphasise the
importance of culture, conduct risk,
consumer protection risk, data protection,
diversity practices, financial literacy,
operational and IT resilience, cyber
security, financial crime, digitalisation and
climate related and environmental risk.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
52
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. A Credit Risk can be one
of the following types including default
risk, concentration risk, migration risk,
collateral risk, country/sovereign risk and
climate related and environmental 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 of 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 security value
or enforceability due to errors in nature,
quantity or pricing of the collateral.
Country/Sovereign Risk
The risk of having exposure to a foreign
country, arising from possible changes
in the business environment that may
adversely affect operating profits or the
value of assets related to the country.
Climate Related and Environmental Risk
Credit related Climate and Environmental
Risk manifests through both physical
and transition channels. This risk can
lead to declines in the value of the Bank’s
collateral on customer loans, or elevated
risk of customer default. This risk may
be elevated if the Bank’s borrowers do
not adapt to the evolving Stakeholder,
Regulatory and Legislative expectations
to contribute to the transition to a low
carbon economy.
Climate related risk modelling capability
is still evolving and the bank is heavily
focused on improving its data to support
future development. However, the Bank’s
portfolio is heavily weighted towards
retail mortgages meaning the risks are
well understood. The bank currently has
low exposure to SME lending where the
direct manifestation of climate risk may
be more diverse. Management deem the
Bank’s ECL stock at 31 December 2024
appropriately captures the current level of
climate risk within the portfolio.
Lending officers consider Climate and
Sustainability Risks for 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. Retail mortgage
lending should not proceed unless the
customer has obtained home insurance
which covers the impacts of climate
related physical risks.
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
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
53
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 Credit function operate.
Credit Risk Management
The Group’s credit risk management
approach is focused on detailed credit
assessment at initial underwriting stage
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 defaulting.
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 Risk Appetite
Statement, applicable sectoral 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 Transactional Credit
Committee (TCC), a subcommittee of
the GCC or the GCC. Below the TCC
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 several 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;
• collateral financed under Asset Finance
agreements;
• financial collateral (lien over deposits,
shares, etc.); and
• other collateral (guarantees etc.).
Valuation Methodologies
The valuation methodologies for the
Group’s key mortgage 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.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
54
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
Home loans
Buy-to-let
Total
31 December 2024
€m
€m
€m
Less than 70%
16,978
357
17,335
71% to 90%
2,446
50
2,496
91% to 100%
77
20
97
Subtotal
19,501
427
19,928
Greater than 100%
38
37
75
Total residential mortgages
19,539
464
20,003
Commercial
493
Consumer finance
553
Finance leases and hire purchase receivables
466
Total loans and advances to customers
21,515
Deferred fees, discounts and business combination related fair value adjustments
300
Gross loans and advances to customers and deferred fees
21,815
Home loans
Buy-to-let
Total
31 December 2023
€m
€m
€m
Less than 70%
16,261
422
16,683
71% to 90%
3,105
136
3,241
91% to 100%
86
59
145
Subtotal
19,452
617
20,069
Greater than 100%
105
132
237
Total residential mortgages
19,557
749
20,306
Commercial
437
Consumer finance
499
Finance leases and hire purchase receivables
446
Total loans and advances to customers
21,688
Deferred fees, discounts and business combination related fair value adjustments
309
Gross loans and advances to customers and deferred fees
21,997
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 and business
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 and 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 of mitigation
plans proposed where a particular metric
is close or at its limit.
Credit Risk Appetite is considered an
integral part of the Integrated Strategic
Planning 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. Forbearance is offered
on secured and unsecured portfolios.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
55
The following information has not been subject to audit by the Group’s independent auditor.
The table below illustrates the relationship between the credit risk rating grades and PD percentages.
Credit Risk Rating Grade
PD %
Excellent
0% ≤ PD <1.44%
Satisfactory
1.44% ≤ PD < 4.62%
Fair
4.62% ≤ PD < 100%
Non-performing
100%
IFRS 9 Stage 1 and Stage 2 classification is not dependent solely on the absolute probability of default. The IFRS 9 Stage 1 and
Stage 2 classification is also dependant on the perceived significant increase in credit risk (SICR) which is the relative movement
in the IFRS 9 probability of default since initial recognition. Therefore, there is no direct relationship between the credit risk rating
grades and the IFRS 9 stage classification. However, the following relationship between the credit risk rating grades and the IFRS
9 stage classification can primarily be expected to exist:
• Satisfactory and Excellent risk profiles can primarily be expected to be classified as IFRS 9 Stage 1;
• Fair risk profile can primarily be expected to be classified as IFRS 9 Stage 2; and
• Non-performing will align to IFRS 9 Stage 3 or defaulted accounts.
Risk Management
(continued)
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.
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 to secure some level of repayment
on the loan.
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 Buy-to-let non-standard mortgage,
Commercial, Corporate and SME
portfolios. The standardised approach has
been applied to the acquired Ulster Bank
residential mortgage portfolios.
PTSB Group Holdings plc - Annual Report 2024
56
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
Note
31 December
2024
31 December
2023
€m
€m
Cash at bank
12
72
71
Items in course of collection
12
23
40
Loans and advances to banks
13
2,202
2,051
Derivative financial instruments
14
59
36
Other assets
15
7
60
Debt securities
17
4,327
3,256
Loans and advances to customers
20
21,423
21,427
Credit commitments
41
1,618
1,380
29,731
28,321
Further detail on loans and advances to customers is provided in note 36, Financial Risk Management.
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 2024 or at 31 December 2023, with the exception of the corporate bond.
Debt securities neither past due nor impaired
31 December
2024
31 December
2023
€m
€m
Rating
Aaa
726
309
Aa1
292
30
Aa2
-
356
Aa3
2,116
1,578
A3
439
448
Baa1
599
432
Baa3
155
103
Total
4,327
3,256
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
57
The following table discloses, by country, the Group’s exposure to sovereign and corporate debt as at:
31 December
2024
31 December
2023
€m
€m
Country
Ireland
1,524
1,559
EU
658
309
Spain
599
432
France
578
356
Portugal
439
448
Austria
292
30
Italy
155
103
Belgium
82
19
Total
4,327
3,256
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 & Poor’s for the CBI.
31 December
2024
31 December
2023
€m
€m
Rating
Aaa
1,887
1,687
Aa1
23
-
Aa2
6
75
Aa3
125
231
A1
90
2
A2
71
56
Total
2,202
2,051
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
58
Asset Quality
The following tables provide detail of asset quality by Product and IFRS 9 stage. The asset quality risk profiles are linked to IFRS 9
PDs which have improved in the year due to positive customer experience and improved macro-economic factors. IFRS 9 PD is one of
several measures used to assess SICR in the portfolio.
31 December 2024
Home loans
Buy-to-let
Total residential
mortgages
Commercial
Consumer
finance
Finance
leases and
hire purchase
receivables
Total
Asset quality*
€m
€m
€m
€m
€m
€m
€m
Stage 1
Excellent
17,604
185
17,789
62
146
-
17,997
Satisfactory
332
10
342
64
271
414
1,091
Fair
-
-
-
-
12
-
12
17,936
195
18,131
126
429
414
19,100
Stage 2
Excellent
504
68
572
4
1
4
581
Satisfactory
609
110
719
333
26
13
1,091
Fair
231
20
251
6
77
27
361
1,344
198
1,542
343
104
44
2,033
Stage 3
Defaulted
259
71
330
24
20
8
382
Total measured at
amortised cost
19,539
464
20,003
493
553
466
21,515
* The information in the shaded box has not been subject to audit by the Group’s Independent Auditor.
31 December 2023
Home loans
Buy-to-let
Total residential
mortgages
Commercial
Consumer
finance
Finance
leases and
hire purchase
receivables
Total
Asset quality*
€m
€m
€m
€m
€m
€m
€m
Stage 1
Excellent
12,283
54
12,337
32
198
9
12,576
Satisfactory
5,578
151
5,729
40
235
409
6,413
Fair
-
3
3
45
5
15
68
17,861
208
18,069
117
438
433
19,057
Stage 2
Excellent
187
19
206
-
2
-
208
Satisfactory
793
60
853
73
16
-
942
Fair
313
195
508
227
27
1
763
1,293
274
1,567
300
45
1
1,913
Stage 3
Defaulted
403
267
670
20
16
12
718
Total measured at
amortised cost
19,557
749
20,306
437
499
446
21,688
* The information in the shaded box has not been subject to audit by the Group’s Independent Auditor.
The tables on the following page set out the asset quality of loans for which the Group has entered formal temporary and permanent
forbearance arrangements with customers for the years ended 31 December 2024 and 2023.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
59
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 2024
Home loans
Buy-to-let
Total residential
mortgages
Commercial
Total
€m
€m
€m
€m
€m
*Stage 2
Excellent
33
1
34
-
34
Satisfactory
34
4
38
-
38
Fair
30
3
33
-
33
97
8
105
-
105
Stage 3
Defaulted
145
26
171
4
175
Total measured at amortised costs
242
34
276
4
280
*The information in the shaded box has not been subject to audit by the Group’s Independent Auditor.
31 December 2023
Home loans
Buy-to-let
Total residential
mortgages
Commercial
Total
€m
€m
€m
€m
€m
*Stage2
Excellent
38
-
38
-
38
Satisfactory
66
1
67
-
67
Fair
53
17
70
1
71
157
18
175
1
176
Stage 3
Defaulted
236
61
297
6
303
Total measured at amortised costs
393
79
472
7
479
*The information in the shaded box has not been subject to audit by the Group’s Independent Auditor.
Risk Management
(continued)
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.
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 among the Stage 1 population
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 default events among the Stage 2
population over the expected life of the
financial instrument.
IFRS 9 does not define SICR but
incorporates a rebuttable presumption
that SICR has occurred when an exposure
is greater than 30 days past due. The
Group did not rebut this presumption for
any portfolio.
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
is based on an instrument’s lifetime PD,
not the losses expected to be incurred;
• Absolute level of 12-month PD –
accounts that have a 12 month PD that
is in excess of 20% at the reporting
date;
PTSB Group Holdings plc - Annual Report 2024
60
• PD at maturity - non-standard
mortgage exposures (i.e., interest only
or part capital and interest accounts)
have been identified as presenting an
increased risk of default at maturity and
are consequently classified as Stage 2;
and
• Other Risk indicators identified by
management as giving rise to a
significant increase in credit risk at the
balance sheet date.
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
Exposures that are no longer 30
days past due do not transition
automatically to Stage 1 (i.e. without
probation) and, other criteria needs to
be met.
Forborne exposures where certain
criteria are met transition from Stage 2
to Stage 1 (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, the definition of
default approved for use under the
Targeted Review of Internal Models (TRIM)
from 31 December 2018 is also applied
under IFRS 9. 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
incorporates 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
or 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
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.
Low credit risk exemption
A low risk exemption can be availed of
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.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
61
ECL Framework
The Group’s IFRS 9 models leverage
the systems and data that calculate
risk weighted assets for IRB 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 IRB
frameworks. IFRS 9 models, however,
differ from IRB models in a number of
conceptual ways (e.g. the use of ‘through
the cycle’ (TTC) for IRB versus ‘point in
time’ for IFRS 9 inputs, 12 month ECL time
horizon for IRB versus lifetime for IFRS 9
Stage 2 & 3) and, as a result, the Group
did not leverage the outputs of its IRB
models, but instead developed statistical
models, which are based on the IRB
scorecards but otherwise tailored to the
requirements of IFRS 9.
Measurement
For all material portfolios, the Group
has adopted an ECL framework that
is cognisant 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 loss, the Group also
modelled early redemptions as a separate
component in the ECL calculation.
IFRS 9 PD
For estimating 12 month and lifetime
default, the Group applies a statistical
model methodology that allows the Group
to estimate the risk that a loan will default
at a given point in time by 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 applies an
economic response model to reflect future
expected macroeconomic conditions.
Behavioural scorecards with 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 (referred to as risk grades)
which drives the PD for the ECL process.
All components of PD, risk grade, ODR
and economic response model are
independently monitored by the Group’s
Model Risk Team 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 fail to return to performing.
The Group has the same approach for
LGD estimation for both 12 month and
lifetime.
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-
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 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 developments and
notes 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
management judgement in impairment
model parameters and Overlay
adjustments to modelled ECL 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 IRRF 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
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
62
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 IFRS 9
credit losses.
The Group incorporates 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 strategic planning
process, the views of policy makers on
longer term economic prospects and key
macroeconomic risks. The Group has
referenced publicly available information
for key macroeconomic indicators
including the Residential Property Price
Index (RPPI), unemployment, interest
rates, GDP and publicly available external
macroeconomic forecasts including
from the Department of Finance
(DoF), the Central Bank of Ireland,
the ESRI, the European Commission
and the IMF. 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 2024. There are two main
changes from forward looking indicators
utilised in December 2023: Unemployment
forecasts for 2025 to 2028 has been
revised upwards and GDP forecasts
for 2025 and 2026 has been revised
downwards due to the threats to the
global macroeconomic outlook posed by
geopolitical pressures.
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 reviews the
scenario probabilities and recommends to
the BRCC for approval. Applying 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
In line with the requirements of the
standard, the Group’s ECL accounting
framework methodology requires
the Group to apply its experienced
credit judgement in impairment model
parameters and to incorporate the
estimated effect of factors that are not
captured in the modelled ECL results at all
reporting period dates. At 31 December
2024, the impairment provision includes
management judgement in respect
of impairment model parameters and
adjustments to modelled outcomes (see
note 2, Critical accounting estimates and
judgements for further detail).
3.2 Funding and Liquidity Risk -
audited
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.
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.
These risks are inherent in banking
operations and can be heightened by a
number of factors, including over reliance
on a particular funding source or product
type, changes in credit ratings or market
dislocation.
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 deposits into longer term
loans. With 92% of the balance sheet
being deposit funded at the year end,
exposure to a 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 CRR2, CRD V
and associated Delegated Acts such
as the Liquidity Coverage Ratio (LCR)
Delegated Act.
The primary ratios calculated and
reported are the LCR and the Net Stable
Funding Ratio (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 a
binding Minimum Requirement for
Own Funds and Eligible Liabilities
(MREL) as determined by the CBI,
which represents a quantification of
the eligible liabilities required to act
as a buffer in the event of a resolution
scenario. The Group has a senior
unsecured issuance strategy to ensure
ongoing compliance with the MREL
requirement.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
63
(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 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 impact under
idiosyncratic, systemic and combined
stresses.
The full suite of liquidity and funding
metrics and stress test results are
regularly reported to the ALCo, the BRCC
and the Board.
In addition, the Group Internal Liquidity
Adequacy Assessment Process (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,
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:
• 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)
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
64
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 and
covered 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.
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 losses arising from a downgrade,
which may include a loss of customer
deposits; limited 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.
In September 2024, Moody’s issued a
one notch upgrade to both PTSB Group
Holding (HoldCo) to ‘Baa1’, and PTSB
plc (OpCo) to ‘A1’. The decision reflects
improved balance sheet fundamentals,
solid capital levels and improved
profitability. In February 2024, the
HoldCo was upgraded to ‘BBB-’; and
OpCo was upgraded to ‘BBB’ by Fitch.
The upgrade reflects Fitch’s view on the
operating environment, the Group’s risk
profile, asset quality, capitalisation, and
improved profitability. The actions from
both agencies has benefitted the Bank
in widening the potential investor base
and supporting the Bank in reducing the
relative cost of future issuances. PTSB
Group Holdings plc and PTSB plc are
rated at investment grade with Moody’s
and Fitch. As part of a wider review of
PTSB’s rating agency requirements, PTSB
is no longer soliciting a rating from S&P
and the rating was withdrawn on the 19th
December 2024. Prior to the withdrawal,
on the 7th of May 2024, S&P revised
the outlook of both Permanent TSB Plc
and Permanent TSB Group Holdings Plc
to positive from stable, and affirmed
'BBB+/A-2' long- and short-term issuer
credit ratings on Permanent TSB PLC and
the 'BB+/B' long- and short-term issuer
credit ratings on Permanent TSB Group
Holdings plc.
The ratings for PTSB plc are as follows:
• Moody’s: Long-Term Rating “A1” with
Outlook “Stable”;
• Fitch: Long-Term Rating “BBB” with
Outlook “Stable”.
The ratings for PTSB Group Holdings plc
are as follows:
• Moody’s: Long-Term Rating “Baa1” with
Outlook “Stable”;
• Fitch: Long-Term Rating “BBB-” with
Outlook “Stable”.
For further details on liquidity and funding
risk see note 36.
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.
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 the Group’s market
risk exposures. 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 of equity perspective (EVE).
The Group separately calculates the
contractual Basis Risk exposure which is
factored into the Pillar II ICAAP process.
The Basis Risk position is added to the
most severe of EVE or EaR risk levels in
order to ensure all material sources of
Interest Rate Risk are capitalised for.
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB Group Holdings plc - Annual Report 2024
65
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 EVE 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 2024 interest rate risk
level, based on the EBA’s Supervisory
Outlier Test (SOT) EVE calculation in
the Short Up scenario (short term rates
increase while long term rates stay flat),
was calculated as €51m (31 December
2023: €118m in the Parallel Down
scenario).
The Bank executed €0.95bn of fair value
interest rate swaps in 2024, hedging
certain issued senior and subordinated
debt. These swaps reduced the Bank’s
exposure to downward shocks from an
NII sensitivity perspective.
The risk position under the EVE
metric has decreased over the year
as the Bank has purchased €1.1bn
of government and covered bonds,
executed €0.95bn of fair value interest
rate swaps hedging certain issued
senior and subordinated debt, while
also growing the term deposits portfolio
which has the effect of reducing the
overall liability tenor.
The following interest rate floors are
applied in calculating EAR: 0% for the
ECB Refinance Rate and Retail Deposits;
-50bps for the ECB Deposit Rate.
(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 2024 FX position was €3.0m
(31 December 2023 €0.7m).
(iii) Credit Spread Risk
Credit Spread Risk in the Banking Book
(CSRBB) is the risk from market-wide
changes to credit and liquidity spreads
for a given credit quality on an institution’s
banking book. It excludes idiosyncratic
credit spread risks.
In line with revised regulatory standards,
the CSRBB methodology the Group’s
credit spread risk exposure is derived on
both an earnings (Earnings at Risk (EaR))
and economic value of equity perspective
(EVE). This risk is measured on the
Group’s bond portfolio and own debt
issuances.
The Group’s CS01 (impact of 0.01%
movement in credit spreads) as at 31
December 2024 was €1.2m.
For further details on market risk see note
36.
Risk Management
(continued)
PTSB Group Holdings plc - Annual Report 2024
66
Corporate
Governance
Directors’ Report
68
Corporate Governance Statement
74
Directors’ Report on Remuneration
125
Statement of Directors Responsibilities
130
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The Directors present their
Annual Report and audited
Group and Company Financial
Statements to the shareholders
for the year ended 31 December
2024.
Results
The Group’s profit for the year was €162m
(2023 profit: €68m) and was arrived at
as presented in the consolidated income
statement.
Dividends
No dividends were paid in 2024.
Review of the Business and Likely
Future Developments
A detailed review of the Group’s
business activities, assets, liabilities,
financial position, performance for
the year and an indication of likely
future developments are set out in the
Strategic Report. Information on the key
performance indicators and principal risks
and uncertainties of the business are
provided as required by the Companies
Act 2014. This includes both financial
and non-financial key performance
indicators which are set out in the
Strategic Report, Financial Review and
Sustainability Sections. 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 material 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 43 of the Annual
Report.
Financial Instruments
The financial instruments and use thereof
are outlined in the Risk Management
section, financial risk management note
36 and Derivative financial instruments
note 14.
Directors’ Report
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 106
under the Board Audit Committee’s 2024
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 2025-2027. 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 107 under the Board Audit
Committee’s 2024 significant financial
reporting judgements and disclosures.
Directors’ Compliance Statement
As required by section 225(2) of the
Companies Act 2014, the Directors
acknowledge 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 2024
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.
Corporate Sustainability Reporting
Regulations
In accordance with Part 28 of the
Companies Act 2014, the Group has
prepared a Sustainability Statement
for the year ended 31 December 2024.
The Sustainability Statement is set out
on pages 140 to 237 and represents a
dedicated section of the Directors’ Report.
Permanent TSB plc, a subsidiary of the
Group, has availed of an exemption from
preparing a Sustainability Statement
pursuant to Section 1598 of the
Companies Act 2014
Board Diversity Report
The Board Diversity Report, as set out
in the Corporate Governance Statement
(see page 99) forms part of the Directors’
Report.
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 79 to 84 of the
Annual Report. On the 29 August 2024,
Nicola O’Brien ceased as an Executive
Director following her resignation as
Chief Financial Officer. On the 1 October
2024, Mr Donal Courtney ceased as an
Independent Non-Executive Director
following completion of his six year term
of office. On the 25 February 2025, Mr
Barry D’Arcy was appointed as Chief
Financial Officer and Executive Director
(Mr D’Arcy previously held the role of Chief
Risk Officer at PTSB). The Board is at an
advanced stage (within the regulatory
approval process) in the appointment of
two Independent Non-Executive Directors
to fill the directorships held by Donal
Courtney and Ronan O’Neill respectively.
Mr O’Neill will step down from the Board
on the 30 July 2025 at the conclusion of
his third term of office (9 years). Further
details on the selection and suitability
process for Board positions is set out in
the report of the Nomination, Culture and
Ethics Committee on page 109.
All of the directors stood and were re-
appointed by election at the 2024 Annual
General Meeting (AGM). All of the current
directors will stand for re-appointment
by election at the Group’s 2025 AGM.
As the Board is at an advanced stage in
the appointment process for two new
PTSB Group Holdings plc - Annual Report 2024
68
directors, these directors will stand for
re-appointment by election at the AGM
if co-opted to the Board in time for issue
of the 2025 AGM Notice and, if co-opted
thereafter, will stand for re-election at the
2026 AGM.
Information on Directors’ remuneration
is detailed in the Directors’ Report on
Remuneration on pages 125 to 129 of
the Annual Report and Directors’ and
Secretary interests in shares are outlined
in note 42 to the financial statements.
Other than the Directors’ and Secretary’s
interests as set out in note 42, 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 3 March
2025.
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 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 57.4% (2023: 57.4%) of
PTSBGH’s issued ordinary share capital.
Under the terms of the Relationship
Framework entered into between the
Minister for Finance and PTSBGH, 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-making 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 their capacity as a shareholder
of the PTSBGH, 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 with respect to the manner
in which the Minister’s voting rights
are exercised in accordance with best
institutional practice and in a manner
proportionate to the shareholding
interest of the State in the Group. The
views of the Minister for Finance and
the Department of Finance 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 Group 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.
PTSBGH 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.
On 7 November 2022, PTSBGH 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
Natwest Group plc 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 2024, the Company had
544,996,176 ordinary shares of €0.50 each
in issue (2023: 545,589,119). Ordinary
shares represent 100% of the Company’s
issued share capital value. On the 14
October 2024, the Group re-purchased
592,943 ordinary shares as part of an Odd-
lot Offer to eligible shareholders. These
shares were cancelled on 14 October 2024.
Par Value
€
Number of Shares
At 1 January 2024
272,794,560
545,589,119
Shares re-purchased*
296,471
592,943
At 31 December 2024
272,497,088
544,996,176
* All re-purchased shares were cancelled
PTSB Group Holdings plc - Annual Report 2024
69
Strategic Report
Governance
Sustainability
Financial Statements
General Information
At 31 December 2024, the Company
holds, through an employee benefit trust,
4,580 (2023: 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. No new AT1 securities
were issued in 2024.
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
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 Relevant US Holders calling for a
disposal of their shares within 21 days or
such longer period as the Board considers
reasonable. Relevant US shareholders
are those shareholders who hold less
than 25,000 shares of any class in the
capital of the Company (including, without
limitation, shares at any time in the future
represented by American depositary
shares) in any manner described in Rule
12g-3-2(a)(1) of the Exchange Act or in
any amendment to such rule or equivalent
rule promulgated by the SEC under
the Exchange Act (including directly or
through or as a nominee). 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. As previously stated, the
intention of the Board in any exercise of
this power is, subject to legal, fiduciary
and regulatory requirements and costs,
to take account of the relative size of the
holdings of the US resident persons and
apply the power first to those smallest
holdings of shares.
Refusal to Transfer
The Directors in their absolute discretion
and without assigning any reason therefor
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.
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, a minimum
of 21 clear days’ notice, and in any other
cases a minimum of 14 clear days’ notice
(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
Directors’ Report
(continued)
PTSB Group Holdings plc - Annual Report 2024
70
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
Chairperson 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 Chairperson 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 Chairperson
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 Chairperson 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
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, Chairperson or proposed
appointments to the Board. 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.
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
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
57.4%
313,382,197 shares
6 June 2023
RBS AA Holdings (UK)
Limited
11.7%
63,614,171 shares
5 June 2023
Sretaw Private Equity
Unlimited Company
7.02%
38,294,197 shares
18 Oct 2023
Goldman Sachs
International
3.03%
16,490,523 shares
10 Feb 2025
There were no other changes to substantial interests in the voting rights of ordinary
shares reported to the Directors as at 3 March 2025.
PTSB Group Holdings plc - Annual Report 2024
71
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Directors’ Report
(continued)
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. Ordinary remuneration
represents the total of basic fees paid to
Non-Executive Directors of the Company.
Allotment of Shares
At the 2024 AGM held on 15 May
2024, 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 shares up to an
aggregate nominal value of €181,844,853
(representing approximately 66.66% of
the issued ordinary share capital of the
Company (excluding treasury shares))
as at 6.00pm on 3 April 2024 of which
any allotment in excess of €90,922,426
(representing 33.33% of the issued
ordinary share capital of the Company
(excluding treasury shares) as at 6.00pm
on 3 April 2024 may be applied to allot
shares pursuant to a pre-emptive offer.
This authority will expire at the conclusion
of the next annual general meeting of
the Company or at midnight on the date
which is 15 months after the passing of
the resolution (whichever is earlier) unless
previously varied, revoked or renewed.
Disapplication of Pre-emption
Rights
The Companies Act 2014 sets out pre-
emption rights for members where new
equity securities (essentially ordinary
shares in the case of the Company) are to
be allotted for cash. The Companies Act
2014 also provides for these pre-emption
rights to be modified or disapplied.
The London based Pre-Emption Group
has also issued guidelines for such
modifications or disapplications (Pre-
Emption Principles) against which the
Group complies.
At the 2024 AGM held on 15 May 2024
shareholders renewed the Directors’
authority to disapply the strict statutory
pre-emption provisions in certain
circumstances being: (a) rights issues,
open offers or other pre-emptive offers
and subject thereto by way of placing
or otherwise of any shares not taken
up in such issue or offer; and/or (b) for
allotments (other than by way of pre-
emptive offers) up to an aggregate
nominal value of €13,639,727 which
represents approximately 5% of the total
nominal value of the Company’s issued
ordinary share capital (excluding treasury
shares) as at 6.00pm on 3 April 2024.
Furthermore, shareholders authorised the
Directors to dis-apply the strict statutory
pre-emption provisions in additional
circumstances, being for allotments
(other than by way of pre-emptive offers)
up to an additional aggregate nominal
value of €13,639,727 which represents
approximately a further 5% of the total
nominal value of the Company’s issued
ordinary share capital (excluding treasury
shares) as at 6.00pm on 3 April 2024.
The Board has confirmed that any use
of the authority in excess of 5% of the
Company’s issued ordinary share capital
would be only in connection with an
acquisition or specified capital investment
within the meaning of the Pre-Emption
Principles. For this purpose and reflecting
the Pre-Emption Principles, an acquisition
or specified capital investment means one
that is announced contemporaneously
with the issue of share capital, or that
has taken place in the preceding six-
month period and is disclosed in the
announcement of the issue.
The above authorities will expire at the
conclusion of the next annual general
meeting of the Company or at midnight
on the date which is 15 months after the
passing of the resolution (whichever is
earlier) unless previously varied, revoked
or renewed.
Market purchases of own Shares
At the 2024 AGM held on 15 May 2024
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 would not exceed:
• 5% above the higher of the average of
the closing prices of the Company’s
ordinary shares taken from the main
market Euronext Dublin and the average
of the closing prices of the Company’s
ordinary shares taken from the main
market of the London Stock Exchange
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,
• 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).
This authority will expire at the conclusion
of the next annual general meeting of
the Company or at midnight on the date
which is 15 months after the passing of
the resolution (whichever is earlier) unless
previously varied, revoked or renewed.
Re-Allot Treasury Shares
At the 2024 AGM held on 15 May 2024,
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 19 August 2025
(whichever is earlier), unless previously
varied, revoked or renewed.
PTSB Group Holdings plc - Annual Report 2024
72
Post Balance Sheet Events
Events after the reporting period are
described in note 46 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 2024.
Key Intangible Resources
Information on key intangible resources
as required under section 1589 of the
Companies Act 2014 is set out Note 24
Intangible Assets on page 356.
On behalf of the Board:
Julie O’Neill
Chair
Eamonn Crowley
Chief Executive
Barry D’Arcy
Chief Financial Officer
Conor Ryan
Company Secretary
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)
The Trustees of the
Employee Benefit Trust
have elected to waive
dividend entitlements.
LR 6.1.77
(14)
As stated on page
48 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 disclosable in respect of
Listing Rules 6.1.77(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 44 to the financial statements.
Independent Auditor
KPMG Chartered Accountants and
Statutory Audit Firm was appointed as
external auditor at the Group’s AGM on
19 May 2023. In accordance with section
383 (2) of the Companies Act 2014, the
Auditor, KPMG Chartered Accountants
and Statutory Audit Firm, will continue in
office.
Non-Financial Statement
In compliance with the European Union
(Disclosure of Non-Financial and Diversity
Information by Certain Large Undertakings
and Groups) Regulations 2017 (S.I. No.
360/2017), the company fulfils its non-
financial reporting obligations through the
Sustainability Statement included in this
Annual Report.
PTSB Group Holdings plc - Annual Report 2024
73
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 was a year where the Board
focussed on leveraging the opportunity
created through the successful acquisition
of elements of the Ulster Bank business
in Ireland. I mentioned in my statement
last year how the Board recognised
the growing importance of PTSB within
the Irish retail banking landscape and
the associated increase in shareholder,
regulatory, economic and societal
expectations on it. In response to this, the
Board undertook a thorough review of
the Bank’s governance arrangements to
ensure it was positioned for sustainable
growth and that it had both the capability
and capacity to do so safely. Through
2024 the Board implemented and
executed a plan to deliver:
1. Improvements in the effectiveness
of governance arrangements at
the Board and the Executive level.
Implementation of the Individual
Accountability Framework (IAF)
was leveraged to improve clarity of
accountabilities and responsibilities,
ensuring no responsibility gaps and that
risk ownership and responsibilities for
meeting regulatory obligations were
clear across the business and the three
lines of defence.
2. Improvements in strategic planning,
the Board undertook a complete
strategy refresh, building greater
strategic capability (setting and
monitoring) and process enhancements
(e.g., related to capital and liquidity
planning).
3. Enhancements were made to embed
risk management processes and
capabilities across the Bank, including
strengthening, capability and capacity
across the first and second lines of
defence.
Corporate Governance Statement
Chair’s Introduction
Dear Reader,
2024 marked the successful integration of the businesses
acquired from Ulster Bank enabling the Board to develop
and approve a new integrated strategic plan to deliver
sustainable returns for our shareholders.
4. Data and technology strategies were
evolved and used to underpin the
overall business strategy, including
anticipation of future needs and
ensuring the Bank had a resilient
operational base, including through
an updated approach to operational
resilience and third party risk
management which was substantially
reviewed by the Board during the year.
5. Sustainability was further embedded
within the Bank’s strategic planning
processes.
While substantial progress has been
made across each of these programmes
of work, there is more to be done to
ensure the Bank is embedding a culture of
continuous change and a right first time
mindset.
In 2024, the Board prioritised focus on the
Bank’s commercial objectives to ensure
it was allocating resources to maximise
sustainable returns for shareholders.
A material part of this focus has been
overseeing a strategic transformation
of the business with a particular focus
on cost management. In 2024, the
Board oversaw an organisation wide
assessment to provide transparency on
the Bank’s cost categories, benchmarking
of PTSB in terms of spend efficiency and
identification of areas/processes that
could be targeted for savings. Following
the identification of major cost categories,
cost saving initiatives were identified
across key domains and value levers. The
Bank has now moved into the execution
phase to deliver these cost saving
initiatives through 2025 and 2026. The
initiatives focus on simplification of the
operating model, efficiency transformation
through automation and customer self
service offerings that will reduce manual
effort, minimise risk while reviewing
investment and sourcing options utilised
across the Bank. The Directors have
established a new Committee of the
Board (business transformation oversight
committee) to oversee and provide
additional support to the Board on
delivery of this programme of work.
Of course the Board recognises it would
have no business without the support of
our customers and the directors continue
to strive to embed a customer focused
culture at PTSB. At the end of 2024 and
into 2025 the Board and its committees
adopted a new approach to inform
decision making utilising an approach
to ensure that all material decisions
were informed by consideration of our
customers, colleagues, sustainability,
risk while delivering value for our
shareholders.
I look forward to working with my Board
colleagues over the coming months to
ensure we deliver on the commitments
we have set for ourselves and to hold
ourselves to the standards of corporate
governance expected of a systemically
important pillar bank. While there were
no appointments to the Board in 2024, as
part of the planned Board refreshment, I
expect to see a number of appointments
to the Board in 2025 which I believe
will supplement the knowledge and
experience needed to execute and evolve
the Bank’s strategy over the next 5 years.
The following report sets out the detail
to 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 104, 113, 109 and
116 respectively highlight the key activities
and areas of focus for each Committee.
Julie O’Neill
Chairperson
PTSB Group Holdings plc - Annual Report 2024
74
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 a ‘significant institution’ 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.
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. In November 2024,
the Board considered a full governance
focussed analysis against the provisions
of the 2024 UK Corporate Governance
Code which comes into effect on the
1 January 2025 and against which
the Directors will report upon in next
year’s annual report. The Board has not
identified any new gaps (not previously
disclosed in the annual report) in its
governance practices when considered in
the context of the 2024 UK Code.
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 2024, save as set out in the
following paragraphs which at this time
are classified as indefinite in nature.
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. Paul Doddrell and Marian
Corcoran are members of the Board
Risk and Compliance committee which
is chaired by an Independent Non-
Executive director 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. The
Board Audit Committee consists entirely
of Independent Non-Executive Directors
Remuneration
Provision 33 of the UK Code requires that
the Remuneration Committee should have
delegated responsibility for setting the
remuneration for all executive directors
and the Chairperson. 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.
Pension Arrangements
Provision 38 of the UK Code states that
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,
in 2022, the Board approved increases
in 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 was also agreed
to exempt the Executive Directors,
including the CEO, from the age-related
eligibility criteria.
PTSB Group Holdings plc - Annual Report 2024
75
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Stakeholder Engagement
In line with our Purpose of working
together to build trust with our customers
and communities, effective and proactive
engagement with key stakeholders is an
integral part of the Bank’s corporate affairs
strategy, The Bank’s policy with respect to
stakeholder engagement, overseen by the
Sustainability & Corporate affairs function,
encompasses our overarching approach
to stakeholder engagement.
Stakeholder relationship owners across
the Group interact with a variety
of stakeholders at regular intervals
throughout the year and provide regular
updates to the Board on same. Key
stakeholders for the group include
shareholders, customers, colleagues,
suppliers, society and the Bank’s
regulators.
Shareholder Engagement
Transparent and frequent communication
with the Group’s shareholders is a key
priority. The Chairperson is available to
meet with major shareholders on matters
concerning the performance or operations
of the Bank. During 2024, the Chairperson
met with a number of major shareholders
and communicated feedback from these
meetings directly to the Board. The
Group has a dedicated Investor Relations
team, led by the Head of Investor
Relations and headed by the CFO. There
is a comprehensive schedule of investor
engagement which the CEO and CFO
participate in, on behalf of the Board,
along with the Head of Investor Relations
and selected Senior Executives. All
engagements are structured in such a way
as to ensure market sensitive information
is not disclosed. The Group also has an
active market engagement programme in
place, where it reports financial results live
through a webcast twice a year, (typically
in March and July) and updates the
market on trading twice a year, (typically
in May and October). The Group publishes
all results, including the webcasts, to
a dedicated Investor Relations section
on its website. The Group also reports
other relevant information to the market
on a timely basis. Following the release
of results, the CEO and CFO facilitate a
roadshow which provides an opportunity
for institutional shareholders to provide
feedback directly. Investor conferences
are also a valuable tool, and during 2024
executives attended equity conferences
in Dublin, London, New York and Boca
Raton.
The Head of Investor Relations together
with the CEO and the CFO, 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
are aware of the views of the investment
community and are considered in their
decision making. The CEO, CFO and
Chairperson seek regular engagement
with major shareholders and report on
these engagements to the Board. The
Group’s shareholder engagement strategy
will continue to evolve as the level of free
float increases, and will always apply best
practice in this regard.
Customer Engagement
We believe delivering fair customer
outcomes is a central tenet to what we do.
We are committed to understanding our
customers and delivering what matters
most to them through every stage of
their financial journey. We listen to our
customers through our Voice of the
Customer programme, focus groups and
surveys, and we engage with them on a
daily basis in-person through our network
of 98 branches nationwide, in addition
to our and digital channels (customer
contact centres, webchat, social media,
mobile app and website).
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.
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 is outlined in the below
table:
Corporate Governance Statement
Stakeholder Engagement
“How the Board ensures effective engagement with, and
encourages participation from the Company’s Stakeholders”
Mechanism
Detail
Board and Committee Meetings
During 2024 the Board met in total on 15 occasions and this facilitated regular Board
engagement with subject matter experts from across the Bank.
Nomination, Culture and Ethics
Committee
Dedicated Board Committee with accountability for culture, behaviour, ethics and
reputation management oversight in the Bank.
Bi-annual 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.
Examples include the Employee Resource Group initiatives Intercultural Competence
Event, DiCE 2024, Non-Executive Director branch and call centre visits (Board
Meeting and walk-about held in Blackrock Call Centre in October 2024), ‘Values in
Practice’ Awards and Sustainability events.
PTSB Group Holdings plc - Annual Report 2024
76
Mechanism
Detail
Employee Representative Bodies
CFO, CEO and Chief Customer and People Officer 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.
Other Executive and Senior Leadership Team members meet the Employee
Representative Bodies on an, as needed basis, depending on the agenda and
business requirements.
Employee Surveys
The Employee collective voice is shared with the Board Nomination, Culture and
Ethics Committee through a variety of employee surveys that are run throughout
the year.
Examples include the ‘Every Voice Counts’ annual survey and ‘Every Voice Counts’
Micro-pulse surveys
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.
The Nomination Culture and Ethics Committee met with the Bank’s People
Experience Council in November 2024.
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 (PTSB Every
Voice Counts survey, IBCB Éist survey),
they also gain diverse perspectives on
what actions will address the areas for
development and any emerging areas of
discontent from employees. It is intended
that attendance by Non-Executive
Directors will continue indefinitely.
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
the financial and strategic position of
the Bank over its five-year planning
period and where appropriate, aligned to
engagement protocols, provide member
representations. During 2024, 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 2024, the Nomination,
Culture and Ethics Committee was
satisfied that this engagement was
effective and in compliance with the UK
Code.
Supplier Engagement
The Bank is supported by a network of
suppliers that enable the smooth delivery
of services to our customers. In 2024, we
established a new, centralised Third-Party
Management team with responsibility for
managing and overseeing the Third-Party
Management process. The team works
closely with colleagues across the Bank,
including Supplier Relationship Owners,
to ensure compliance with standards,
processes, procedures and governance
requirements, as well as ensuring that
new or renewal of critical Outsourcing
arrangements are brought to Board for
approval.
Societal Engagement
We are committed to being a responsible,
sustainable business, supporting our
communities by having a positive and
meaningful impact. To support us in
doing so, we engage with a number
of stakeholders across Irish society,
including Community Partners and
Sponsorship Rights Holders, Media and
Government Officials. We also engage
at an industry level across a number
of forums, including the Banking and
Payments Federation of Ireland and Irish
Banking Culture Board.
The Nomination Culture and Ethics
Committee is updated by the
Sustainability & Corporate Affairs function
on a quarterly basis on key matters
relating to the Bank’s corporate and public
affairs strategies, including media, political
and community engagement.
PTSB Group Holdings plc - Annual Report 2024
77
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Regulatory Engagement
Led by the Chief Risk Officer, the Board
and Management maintain regular
engagements with regulatory authorities,
including with the Central Bank of Ireland
(‘CBI’). These engagements are in the
form of; one to one meetings with Board
members and Management, onsite
inspections and thematic reviews, and
regular engagements with the Bank’s
Regulatory Affairs Team. Meetings
between the CBI, the Board, the
Chairperson and Management involve
open discussion on a wide range of
topics including, business strategy and
performance, consumer protection,
risk management, capital and liquidity,
upstream regulation and challenges
facing the banking industry. The Board
are also kept up to date on regulatory
engagements and correspondence,
ensuring the Board are aware of feedback
from the CBI along with key areas of
focus. The wide-ranging constructive
engagement with the CBI is recognised
by the Board as an enabler for the Bank
in understanding regulatory expectations
and meeting regulatory obligations.
Sustainability Double Materiality
Assessment
The Bank takes several 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.
During 2024, the Bank engaged a sample
of stakeholders to complete an exercise
in double materiality, in line with the
requirements to comply with Part 28 of
the Companies Act 2014, which came into
effect for reporting dates on or after the
1 January 2024. The exercise assessed
both the stakeholder impact, and the
financial materiality, of identified Impacts,
Risks and Opportunities (‘IROs’), to
determine those that were most material
to our business, and important to our
stakeholders.
The findings from the Double Materiality
Assessment played an integral role in
guiding the Company’s first disclosure
under CSR Regulations and will inform the
next evolution of the Bank’s Sustainability
Strategy in 2025.
Members of the Board took part in the
Double Materiality Assessment process
and progress made in relation to the
disclosure was reported to both the Board
and Board Audit Committee.
To read the Company’s disclosure under
CSR Regulations, which includes a
detailed overview of the Bank’s Double
Materiality Assessment process, please
refer to our Sustainability Statements
beginning on page 140.
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
Corporate Governance Statement
Stakeholder Engagement (continued)
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.
Focus for 2025
The Bank is committed to building on
the progress achieved and to continue
its established proactive engagements
with key stakeholders in 2025. This will
enable the Bank to make continued
progress in cultivating and strengthening
relationships, building trust and further
enhancing the reputation of the Bank.
Overseen by the Chief Sustainability &
Corporate Affairs Officer, the Bank will
continue to ensure that feedback from
all key stakeholders is monitored and
measured effectively in line with the
Bank’s Purpose and that key insights are
brought to the Nomination, Culture and
Ethics Committee, or relevant Committee,
on a regular basis.
PTSB Group Holdings plc - Annual Report 2024
78
A key focus for the Board 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 to 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 is set
out in the Biographies below.
JULIE O’NEILL (69)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
CHAIR
Appointed to Board:
17 January 2023
Nationality:
Irish
Committee Membership:
Remuneration Committee
Nomination, Culture and Ethics
Committee (Chair)
Principal External
Appointments:
Director at XL Insurance
Company SE and Architas Multi-
Manager Europe.
Key Strengths, Skills and Experience
Julie is an accomplished business leader with extensive
executive and board experience, having held a number of
public service positions, including Secretary General of
both the Department of Transport and the Department of
Marine and Natural Resources and previously held a number
of other prominent Non-Executive Director roles, including
Chairperson of the Convention Centre Dublin and Non-
Executive Director, AXA Life Europe and Ryanair Group plc.
Julie previously served a six-year term on this 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 has extensive business and leadership experience
and brings an in-depth knowledge of the Bank and wider
banking/insurance industry to the Board.
• Certified Bank Director
• Bachelor of Commerce
• MSc Policy Analysis
EAMONN CROWLEY
(55)
CHIEF EXECUTIVE
OFFICER
Appointed to Board:
10 May 2017
Nationality:
Irish
Committee Membership:
None
Principal External
Appointments:
PTSB nominee director of
Banking & Payments Federation
Ireland CLG and Irish Banking
Culture Board CLG
Key Strengths, Skills and Experience
Eamonn brings to the Board extensive international banking,
accounting, corporate treasury and leadership experience
with a significant customer focus reflected in the Bank’s
Purpose, Ambition and Strategy.
Eamonn has 30 years+ banking experience. In addition
to his tenure at PTSB since 2017, Eamonn’s experience
encompasses the management of a significant retail banking
growth agenda during his tenure as CFO in Santander Bank
in Poland and as a member of the management board there
for more than 10 years. Eamonn has extensive relevant
stakeholder management experience with particular focus of
building effective relationships with colleagues, regulators,
government and markets (shareholders, investors, analysts).
In addition to his financial management credentials, Eamonn
is an accomplished business leader manager who takes
a broad perspective and has a deep commitment to both
organisational culture and operational transformation for
the benefit of key stakeholders such as shareholders,
customers, colleagues and the long-term sustainable
interests of the Bank.
• MBA Smurfit Business School
• Certified Accountant (FCCA) and Member of Association
of Corporate Treasurers
• Certified Bank Director
• Harvard Business School – Advanced Management
Programme
Corporate Governance Statement
Board of Directors
PTSB Group Holdings plc - Annual Report 2024
79
Strategic Report
Governance
Sustainability
Financial Statements
General Information
BARRY D’ARCY (51)
CHIEF FINANCIAL
OFFICER
Appointed to Board:
25 February 2025
Nationality:
Irish
Committee Membership:
None
Principal External
Appointments:
None
Key Strengths, Skills and Experience
Barry is a CIMA Fellow and Chartered Global Management
Accountant (FCMA, CGMA), a finance and risk professional
with significant banking and leadership experience having
worked in the Commercial and Retail Banking sector in
Ireland for more than 15 years. Barry brings a wealth of
financial, risk, commercial, strategic, operational and
regulatory knowledge to the Bank together with experience
in delivering large complex programmes successfully.
Barry was appointed CFO in February 2025, having joined
the Bank as CRO in October 2023. Prior to joining PTSB,
Barry was Chief Risk Officer and an Executive Director at
KBC Bank (Ireland).
• FCMA, CGMA
• Bachelor of Business Studies
• Certified Bank Director
RONAN O’NEILL (71)
SENIOR INDEPENDENT
NON-EXECUTIVE
DIRECTOR
Appointed to Board:
26 July 2016
Nationality:
Irish
Committee Membership:
Board Audit Committee (Chair)
Nomination, Culture and Ethics
Committee
Principal External
Appointments:
None
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
RUTH WANDHÖFER
(49)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30 October 2018
Nationality:
German/British
Committee Membership:
Board Audit Committee
Remuneration Committee
Principal External
Appointments:
Director at: RTGS Global Ltd;
Aquis Exchange Plc and Leximar
Ltd (personal consultancy
company).
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
and payments transformation programmes.
Ruth was MD and Global 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
Corporate Governance Statement
Board of Directors (continued)
PTSB Group Holdings plc - Annual Report 2024
80
MARIAN CORCORAN
(60)
NON-EXECUTIVE
DIRECTOR
Appointed to Board:
24 September 2019
Nationality:
Irish
Committee Membership:
Board Risk and Compliance
Committee
Nomination, Culture and Ethics
Committee
Principal External
Appointments:
Director HP International Bank
DAC, Director of IDA Ireland,
Chair DCU Educational Support
Services DAC, and Director of
MC2 Change Limited (personal
consultancy company)
Key Strengths, Skills and Experience
Marian has broad executive and non-executive leadership
and advisory experience having led strategy development
in technology and business transformations. Marian has
also played a key role in executive leadership. Marian
brings to the Board wide-ranging experience in advising on
and leading transformational programmes across multiple
industries including banking. Marian’s experience in 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 benefit
the Board as the Group’s strategy and change programmes
evolve at an ever-increasing pace. Marian has a strong track
record in championing inclusion and diversity.
Marian is 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.
Marian is a member of the Governing Authority in DCU
and was also a member of the Irish Public Service Pay
Commission.
• Business Sustainability Management, University of
Cambridge
• Chartered Director
• Certified Bank Director
• Professional Certificate in Leadership Coaching
• BSc Biotechnology
PAUL DODDRELL (57)
NON-EXECUTIVE
DIRECTOR
Appointed to Board:
26 November 2020
Nationality:
British
Committee Membership:
Nomination, Culture and Ethics
Committee
Board Risk and Compliance
Committee
Principal External
Appointments:
Director at Cabot Financial
(Ireland) Ltd, Coastline Housing
Limited. Coastline Services
Limited and 3 to 48 Ltd (personal
consultancy company)
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
PTSB Group Holdings plc - Annual Report 2024
81
Strategic Report
Governance
Sustainability
Financial Statements
General Information
CELINE FITZGERALD
(62)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30th March 2021
Nationality:
Irish
Committee Membership:
Nomination, Culture and Ethics
Committee
Remuneration Committee (Chair)
Principal External
Appointments:
Chair, Pieta House CLG and
CEO (interim) Research Ireland
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 including Chair of the charity
Pieta House. Celine is the current interim CEO of Research
Ireland (an agency under the Department of Education).
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
is 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
• Certified Bank Director
ANNE BRADLEY (65)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
30th March 2021
Nationality:
Irish
Committee Membership:
Board Audit Committee
Board Risk and Compliance
Committee
Principal External
Appointments:
Director at Northern Trust
International Fund Administration
Services Ireland Ltd and
Pieta House CLG.
Key Strengths, Skills and Experience
Anne’s experience is centred on transformation and
business change and her cross industry knowledge and
experience supports the Board as the Bank evolves its
digital transformation strategy while maintaining resilient
and reliable technology systems. Anne 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 in 2020 joined and is a current
member of the Board of Northern Trust International Fund
Administration Services Ireland Ltd.
• Fellow of the BCS, The Chartered Institute for IT
• Chartered Director, Institute of Directors
• Certified Bank Director
Corporate Governance Statement
Board of Directors (continued)
PTSB Group Holdings plc - Annual Report 2024
82
CATHERINE MORONEY
(62)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
12th December 2023
Nationality:
Irish
Committee Membership:
Board Audit Committee
Board Risk and Compliance
Committee
Principal External
Appointments:
Director at Cynergy Bank (UK)
Limited, and Saburai Consulting
Limited (personal consultancy
company)
Key Strengths, Skills and Experience
Catherine brings extensive experience in retail, corporate
and business banking to the Board as the Bank further
develops its business banking proposition. Catherine
has deep experience at senior executive level in leading
customer-facing businesses with a focus on strategic
planning, business growth, innovation, transformation
and sustainability. Catherine has also held a number of
non-executive board positions across Ireland and the
UK, including Chair of the Board and of audit, risk and
remuneration committees in the Banking, Insurance,
Corporate Finance and Not-For-Profit Sectors.
Catherine is an accomplished business leader who has
spent a large portion of her career at senior executive level
in the Irish financial services sector (AIB Bank) with a deep
involvement in the business community, including in her
role as former President and Chair of Dublin Chamber of
Commerce
• Bachelor of Commerce, Banking & Finance, UCD
• Chartered Director, Institute of Directors
• Fellow, Institute of Bankers in Ireland
• Certified Bank Director
RICK GILDEA (72)
INDEPENDENT NON-
EXECUTIVE DIRECTOR
Appointed to Board:
12th December 2023
Nationality:
American/British
Committee Membership:
Board Risk and Compliance
Committee (Chair)
Board Audit Committee
Remuneration Committee
Principal External
Appointments:
Trustee at The Shakespeare
Globe Trust
Chair of the Finance Committee
and member of the Board of
Advisors, The Johns Hopkins
University School of Advanced
International Studies.
Key Strengths, Skills and Experience
Rick Gildea’s background in corporate banking (JP Morgan
Chase) brings deep experience of client coverage and risk
management together with capital markets expertise to the
Board.
Rick spent a large portion of his career at senior executive
level in investment and corporate banking roles in London
and New York, prior to pursuing a non-executive career.
Rick was an independent Non-Executive director at Alpha
Bank (a domestic and international bank listed on the Stock
Exchange in Athens) between 2016 and 2023 where he
chaired the remuneration committee and was a member of
the risk committee with a particular focus on non-performing
loan risk management.
• Certified Bank Director
CONOR RYAN (53)
COMPANY SECRETARY
Conor was appointed Company Secretary in 2017. As Company Secretary and Head of Corporate
Governance, Conor is responsible for advising the Board, through the Chairperson, 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 and past president the Chartered Governance
Institute in Ireland (ICSA) and a Certified Bank Director.
PTSB Group Holdings plc - Annual Report 2024
83
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 Board Meeting Attendance and Directorships
Member
Appointed
Ceased
Number of Years on
Board
2024 meetings
Number of Directorships
held
Current Directors
Julie O’Neill
17 Jan 2023
-
2.0
15/15
4/3
Ronan O’Neill
26 Jul 2016
-
8.5
14/15
2/1
Ruth Wandhöfer
30 Oct 2018
-
6.3
15/15
7/3
Marian Corcoran
24 Sep 2019
-
5.4
15/15
6/3
Paul Doddrell
26 Nov 2020
-
4.1
15/15
7/2
Anne Bradley
30 Mar 2021
-
3.8
14/15
4/2
Celine Fitzgerald
30 Mar 2021
-
3.8
15/15
5/2
Rick Gildea
12 Dec 2023
-
1.0
12/15
4/1
Catherine Moroney
12 Dec 2023
-
1.0
14/15
4/2
Eamonn Crowley
10 May 2017
-
7.7
15/15
9/1
Former Directors
Donal Courtney
3 October 2018
1 October 2024
6.0
10/10
5/2
Nicola O’Brien
04 August 2022
29 August 2024
2.0
9/9
2/1
Notes:
PTSB is the sole direct subsidiary of PTSBGH. During 2024, 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 2024 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/2024.
Eamonn Crowley’s directorships consist of seven group entity directorships and two companies on which he is a representative for PTSBGH.
Corporate Governance Statement
Board of Directors (continued)
PTSB Group Holdings plc - Annual Report 2024
84
Division of Responsibilities
The roles and responsibilities of the Board collectively, the Executive and Non-Executive Directors, the Chairperson, 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 Chairperson
Julie O’Neill’s responsibility as Board Chairperson is to ensure the efficient and effective working of the Board. Her role is to lead
and manage the business of the Board, promoting the highest standards of corporate governance, 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 Chair fosters 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 Chair
has a strong working relationship with the CEO, Eamonn Crowley, and acts as a confidential sounding board for the Directors.
Julie O’Neill is also Chair of the Nomination Culture and Ethics Committee.
The Senior Independent Director
Ronan O’Neill is the Board’s Senior Independent Director whose primary role is to support the Chairperson on all governance
related matters. In addition, he specifically leads the annual appraisal of the Chairperson’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 86 to 87. 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 and insight 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 Chairperson in promoting the highest standards
of corporate governance. The Company Secretary supports the Chairperson in ensuring Directors receive timely and clear
information so they are appropriately equipped for constructive debate and informed decision making. The Company Secretary is
a central source of guidance and advice on Board policy, procedure and governance. All Directors have access to the advice and
services of the Company Secretary and Head of Corporate Governance.
Corporate Governance Statement
Leadership and Effectiveness
PTSB Group Holdings plc - Annual Report 2024
85
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Executive Committee1
EAMONN CROWLEY
CHIEF EXECUTIVE
BARRY D’ARCY
CHIEF FINANCIAL OFFICER
GER MITCHELL
CHIEF CUSTOMER &
PEOPLE OFFICER
Ger has been a member of the Executive Committee since 2012. Ger is a commercial leader
who has held a number of roles at Executive level including HR, Products, Corporate Affairs,
Sustainability, and Marketing. In 2024, Ger’s role was expanded to include ‘Products & Pricing
Strategy’ which brings the Colleague and Customer Experience together alongside the
Marketing and Products Strategy.
Ger is a purposeful commercial executive, with extensive experience in Acquisitions, Sustainable
& Responsible Business, Brand Positioning, Retail Banking, Product Marketing & Management,
Consumer Marketing, Business Transformation, Customer Remediation and Human Resources.
A culture champion and leader in Diversity, Equity, and Inclusion, who nurtures and develops top
talent.
ANDREW WALSH
CHIEF 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 contributing to 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 practices.
CLAIRE HEELEY
HEAD OF INTERNAL
AUDIT
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 practices, has no voting rights. Claire has a direct reporting
line to the Chairperson of the Board Audit Committee.
1
Following the appointment of Barry D’Arcy (previously the Bank’s Chief Risk Officer) as Chief Financial Officer, a recruitment and selection process is underway
to fill the vacancy for Chief Risk Officer. Pending that appointment, the Bank has put in place arrangements to maintain the effective oversight and management
of the Bank’s Risk function.
Corporate Governance Statement
Leadership and Effectiveness (continued)
PTSB Group Holdings plc - Annual Report 2024
86
TOM HAYES
CHIEF TECHNOLOGY
OFFICER
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 implement 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
CHIEF RETAIL BANKING
OFFICER
Patrick has over 25 years’ experience across the banking industry. Patrick joined the Bank in
December 2018 as Retail Banking Director, moving to his new role as Chief Retail Banking Officer
in August 2024. Patrick has previously held senior management roles in Strategy, Product and
Proposition Development, Marketing, Private Banking and, Retail Sales and Service Distribution.
The Retail Banking Division is responsible for all sales and service channels and delivery of the
Bank’s commercial performance. 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 Customer and
People Team on customer propositions and experience.
PETER VANCE
CHIEF OPERATING
OFFICER
Peter joined the Bank as Chief Operating Officer (COO) in 2021 with 25 years’ of experience in
financial services. As COO, Peter is responsible for Group Change & Transformation, Enterprise
Service Delivery including Payments, Financial Crime, Collections & Recoveries as well as other
key functions.
Prior to joining PTSB, Peter held senior positions as Head of Group Operations and Executive
Head of Direct Sales & Service Channels in AIB. 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.
LEONTIA FANNIN
CHIEF SUSTAINABILITY
& CORPORATE AFFAIRS
OFFICER
Leontia joined the Bank’s Executive Committee in August 2024 and is responsible for leading
the Bank’s Sustainability and Corporate Affairs Strategies. The role of Chief Sustainability &
Corporate Affairs Officer was created to reflect the Bank’s commitment to sustainability as a
key driver of its corporate strategy and the value it places on corporate affairs as an enabler of
internal and external stakeholder engagement.
Leontia joined the Bank in 2018 as Head of Corporate Affairs and Communications and has led
out on a number of the Bank’s key strategic initiatives, including PTSB’s Reputation Management,
Sponsorship and Sustainability Programmes. Leontia has over twenty years’ experience
in Corporate Affairs, Reputation Management, Colleague Communications, Sponsorships,
Corporate Social Responsibility and Sustainability.
PTSB Group Holdings plc - Annual Report 2024
87
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Corporate Governance Statement
Governance Structure, Roles and Responsibilities
Board
CEO
Risk
Committee
Executive Committee
Customer
Committee
Resilience
Committee
Sustainability
Committee
Assets and Liabilities
Committee
OP Risk
Committee
Credit
Committee
Nomination, Culture & Ethics Committee
Audit Committee
Risk & Compliance Committee
Remuneration 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 determines the business
strategies and plans that underpin corporate strategy, whilst ensuring the Group’s organisational structure and capability are
appropriate for implementing the chosen strategies. The Board deals with challenges and issues relating to corporate governance,
sustainability and corporate ethics.
Board
• Sets and oversees performance against strategy.
• Sets and oversees delivery of the Group’s Sustainability
strategy (and drives integration with business strategy).
• Ensures business activity aligns with the Company’s stated
Purpose, Ambition, Values, and Culture.
• Sets 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
Julie O’Neill (C)
Marian Corcoran
Celine Fitzgerald
Ronan O’Neill
Paul Doddrell
Audit
Committee
Ronan O’Neill (C)
Anne Bradley
Ruth Wandhöfer
Catherine Moroney
Rick Gildea
Risk and Compliance
Committee
Rick Gildea (C)
Marian Corcoran
Paul Doddrell
Anne Bradley
Catherine Moroney
Remuneration
Committee
Celine Fitzgerald (C)
Julie O’Neill
Ruth Wandhöfer
Rick Gildea
• 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.
• Review/monitors the design,
implementation and effectiveness of
the Company’s Purpose, Ambition,
and Values.
• Oversees the Company’s Culture,
Ethics, Diversity, Workforce
Engagement and Reputation.
• Oversees internal financial controls.
• Reviews and recommends approval
of the Annual Report and Financial
Statements to the Board.
• Oversees all relevant matters
pertaining to the external auditors.
• Monitors the output of internal audit
findings.
• 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.
• Oversees financial and non-financial
risks.
• Monitors and makes
recommendations to the Board on
the Company’s appetite for risk.
• Oversees credit, funding and liquidity
policies.
• Reviews the Company’s regulatory
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.
• Assesses the impact of Climate and
Environmental Risk on the Group’s
overall Risk Profile.
• Oversees remuneration and reward
strategies.
• Ensures remuneration strategy is
aligned with the Company’s appetite
for risk.
• Oversees senior management
reward.
• Monitoring relevant external
benchmarks for posts within the
scope of Committee.
Upon Donal Courtney’s retirement from the Board on 1 October 2024, Rick Gildea was appointed Chair of Board Risk and Compliance Committee and joined the
Board Audit Committee. Rick Gildea will step down from Remuneration Committee when two planned Board appointments are completed in early 2025.
PTSB Group Holdings plc - Annual Report 2024
88
Executive Committee
The Executive Committee reports through the CEO to the Board. The Executive Committee advises 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 are 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 functions 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 relevant Executive Committee member ensures the Executive Committee is updated
on all material matters considered by the sub-committees. The Group Risk Committee has responsibility for oversight of bank-wide
risk management and internal control issues and all members of the Executive Committee are members of the Group Risk Committee.
Executive Committee
• Developing and implementing (as approved by the Board) the Group’s Integrated Strategic Plan (ISP).
• Allocating the Group’s resources (financial and people) to ensure that ISP 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.
• Oversight and leadership of the implementation of the Bank’s Sustainability Strategy.
Risk
Committee
Assets and
Liabilities
Committee
Credit
Committee
Operational
Risk
Management
Committee
Customer
Committee
Sustainability
Committee
Resilience
Committee
• Oversight of
Group wide Risk
Management and
internal control
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 the top risks
facing the Group,
along with an
assessment of
the probability
and severity of
those risks
• 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 of
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
• Recommends
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 the agreed
protocol
• Monitors the
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
• Prioritise
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
• Oversight of the
development and
implementation
of the Group’s
Sustainability
Strategy and
related KPIs.
• Oversee
Sustainability-
related
programming and
provide guidance
and support to
sustainability
activities across
the Group.
• Engage
stakeholders as
needed to ensure
organisational
alignment on key
risks and issues,
while maintaining
awareness
and linkages to
other strategic
programmes.
• Monitor and
report progress
to the Board
and Executive
Committee at
regular intervals
throughout the
year.
• Monitor and
report on
Operational
Resilience, Digital
Operational
Resilience and
Third Party
resilience
activities and risk
profile
• Oversees the
development and
implementation
of the Bank’s
Resilience
strategy
and Digital
Operational
Resilience
Strategy and
related activities
• Oversight of
Group third party
and outsourcing
relationships,
including
performance,
issues
management and
risks
PTSB Group Holdings plc - Annual Report 2024
89
Strategic Report
Governance
Sustainability
Financial Statements
General Information
“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 Group. The Board exercises leadership, integrity and judgement in directing the
Group, based on transparency, accountability and responsibility. The Board is also the focal point for the implementation of best
practice corporate governance within the Group. All Directors must take decisions objectively in the interests of the Company. The
key responsibilities of the Board as a whole are to:
Key Responsibilities of the Board
Customers
Ensure 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
Bank’s purpose and values.
Embedding the Bank’s Organisational Culture and Diversity, Equity and Inclusion Programmes.
Strategy
Question, challenge, assist in the development of, and approve the strategic, financial 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.
Oversight of the ESG factors considered material to the business and ensuring they are
monitored and managed as part of the Bank’s strategic formulation.
Stakeholders
Ensuring regular engagement and effective communication with stakeholders in order to
understand their views on governance and performance against strategy.
Shareholders
Ensuring directors develop a clear understanding on the views of shareholders.
Sustainability
Ensuring the Bank enables support for customers, colleagues and communities while it
conducts and manages all areas of its business in a responsible way through integrating
sustainability within strategic planning.
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 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 there is a remuneration framework that is in line with the risk strategies of the Bank.
Ensure 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 is 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.
Corporate Governance Statement
Board Leadership and Effectiveness
PTSB Group Holdings plc - Annual Report 2024
90
Directors must act in a way they
consider, in good faith, would promote
the success of the Company 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.
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
business 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
(Integrated Strategic Plan). 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 the Integrated Strategic Plan
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 has
adopted a set of objectives closely
aligned with the Bank’s purpose, ambition,
and strategic objectives. Following
a transformative period in 2023, the
Board focused on leveraging the Bank’s
strengthened position in the Irish retail
banking market, driving sustainable
growth, and delivering long-term value.
This involved providing enhanced
oversight of the Bank’s continued
business growth and diversification
strategy. Particular attention was given
to enhancing the Bank’s position in the
personal and business banking market,
and growing the SME and Asset Finance
portfolios, while also strengthening
customer retention and acquisition in the
mortgage market through competitive
fixed-rate and green mortgage products.
Furthermore, the Board ensured the
effective use of the Bank’s strengthened
capital position, supported by the sale
of the “Glas III” Non-Performing Loan
portfolio.
Aligned with the Bank’s “Altogether
More Human” brand promise, the Board
prioritised delivering exceptional customer
experiences by overseeing the next
phase of the Bank’s digital transformation
programme. This included enhancing
customer-facing and back-end banking
systems and monitoring the development
of innovative digital features such as
the “PTSB Protect” fraud prevention
tool. Investments in customer service
capabilities aimed to enhance accessibility
and inclusivity, complemented by
initiatives to expand sustainability-
focused offerings, including green lending
products and participation in government-
backed schemes like the SBCI Growth
& Sustainability Loan Scheme. The
Board also focused on building stronger
connections with the community through
programmes that support inclusivity,
such as the autism-friendly accreditation
achieved in partnership with AsIAm.
The Board remained committed to
advancing the Bank’s sustainability
agenda, which continued to be a core
strategic priority. Significant attention was
given to monitoring the Bank’s progress
in setting Science-Based Targets and
preparing its first disclosure under CSR
regulations. Expanding the Bank’s green
loan offerings and climate-focused
initiatives will be central to helping
customers transition to a low-carbon. At
the same time, the Board continues to
oversee initiatives to embed sustainability
into the Bank’s operations, ensuring
alignment with the expectations of
regulators, shareholders, and the broader
community.
Maintaining financial and operational
resilience was a key focus for the Board
in 2024. The Board provided oversight on
delivering cost management initiatives
designed to achieve operational
efficiencies and offset rising costs
associated with inflation and strategic
investments. The Board monitored the
Bank’s capital and liquidity position
to ensure compliance with regulatory
requirements while maintaining flexibility
for growth. A strong focus was placed
on asset quality and risk management,
supported by the reduction of the Non-
Performing Loan ratio to 1.8% following
the completion of the “Glas III” transaction.
Following the significant transformation
of the Bank in recent years, the Board
focused on executing the forward-looking
improvement plan developed in 2023
which is described in further detail as
part of the Chairperson’s introduction
to governance on page 74 of the annual
report. This plan aimed to enhance
governance, operational resilience,
and core capabilities across the Bank.
Regular reviews of strategic assumptions
and risk frameworks ensured alignment
with regulatory, economic, and societal
expectations. The Board has also
supported the Bank in anticipating and
adapting to long-term changes, including
technological advancements, evolving
market conditions, and climate-related
risks.
The Board remains committed to
maintaining the momentum of the Bank’s
brand repositioning and increasing
PTSB Group Holdings plc - Annual Report 2024
91
Strategic Report
Governance
Sustainability
Financial Statements
General Information
engagement with stakeholders. The
Board will ensure alignment between the
Bank’s strategic goals and stakeholder
expectations, including transparent
communication of its shareholder
distribution policy and long-term
investment plans. Through these actions,
the Board aims to deliver a sustainable
and resilient business model, strongly
underpinned by its financial, technological,
and human resource capabilities, ensuring
the Bank is well-positioned to meet future
opportunities and challenges.
In 2025, the Board will focus on several
critical areas to ensure the continued
success and sustainability of the Bank.
A key priority will be managing the
induction and onboarding of new directors
while overseeing a smooth transition
following the planned retirements of two
Independent Non-Executive Directors.
This process will be carefully managed to
maintain the continuity and effectiveness
of the Board. The Board will also provide
oversight of the implementation of a
Voluntary Severance Scheme (‘VSS’),
which has been announced as part of
efforts to right size the Bank’s workforce,
ensuring the scheme is executed in
alignment with strategic, operational and
financial goals. In addition, the Board
will continue to explore inorganic growth
opportunities, building on the success of
the Ulster Bank transaction, to enhance
the Bank’s scale and competitive position.
The diversification of income streams
will remain a strategic priority, with a
particular focus on expanding the Asset
Finance and SME business lines to
strengthen the Bank’s revenue base and
market position. The Board will also focus
on embedding sustainability across the
Bank and will continue to prioritize its role
in managing the Bank for the benefit of all
stakeholders, ensuring strategic decisions
balance the needs of customers,
colleagues, shareholders, and the wider
community.
Building resilience in the Bank’s
operations, systems, processes, and
technology will remain a cornerstone
of the Board’s focus. This will include
ensuring that investments in technology
and operational improvements enhance
the Bank’s ability to adapt to future
challenges and opportunities. Through
these actions, the Board aims to deliver
sustainable value, ensuring that the Bank
is well-positioned to meet the evolving
needs of its stakeholders and the wider
market in the years ahead.
Strategy Development
The Board is responsible for setting the
strategic direction of the Bank. In the
first half of 2024, the Board approved
a refreshed business strategy for the
Bank following significant engagement
with the Executive Team that included
all-day strategy review sessions. Following
approval of a refreshed business strategy
the Board approved an Integrated
Strategic Plan, which was developed
and agreed in the second half of 2024.
The plan sets out the specific initiatives
that will be undertaken and the human,
financial and technical resources that will
be allocated to each. The annual strategic
planning process integrates strategic,
financial, workforce, sustainability and
change delivery plans and aligns with
the Bank’s Risk Appetite, ICAAP, ILAAP,
Recovery Plan and Resolution Plan.
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, 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.
The Board is responsible for overseeing
the implementation of the Integrated
Strategic Plan and has agreed a set of
Key Performance Indicators to monitor
achievement of the plan and to enable
corrective action to be taken where
required. On an ongoing basis throughout
the year, the Board receives management
updates on key strategic programmes
of work and on progress against Key
Performance Indicators.
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 Chairperson meets the
UK Code requirement to be independent
on appointment.
Each of the Chairperson 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 there
is an appropriate mix of knowledge,
experience and skills. This detailed
assessment considers tenure, succession
planning, Board diversity and assessment
of the continued collective suitability of
Corporate Governance Statement
Board Leadership and Effectiveness (continued)
PTSB Group Holdings plc - Annual Report 2024
92
the Board. The Board has a target size
of 12 Directors with 2 appointments
expected in 2025 to achieve this level.
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 five 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 there is
an appropriate combination of Executive
and Non-Executive Directors such there
is sufficient independent challenge and
oversight of management and that no
individual or small group of individuals can
dominate Board decision making.
At 31 December 2024, the Board
comprised ten Directors: the
Chairperson, who was independent on
appointment, the CEO and eight Non-
Executive Directors, six of whom have
been determined by the Board to be
independent Non-Executive Directors.
On 25 February 2025, Barry D’Arcy was
appointed as an Executive Director and
Chief Financial Officer bringing the Board
size to eleven. Changes to the Board
during 2024 are set out in the Directors’
Report on page 68 of the annual report.
Biographies of each of the Directors
are set out in the Board of Directors
section on pages 79 to 83. The wide
range of knowledge, experience and
skills encapsulated in the biographies are
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,
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 in situ at the time of
publication of the AGM notice 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 further 3 year
period and any term beyond this will only
be exercised in exceptional circumstances.
The Chair is proposed for re-appointment
by the Directors on an annual basis. The
term of office of the Chair is six years.
Julie O’Neill joined the Board on 17
January 2023.
Executive Directors’ service contracts are
reviewed by the Remuneration Committee
and approved by the Board. Executive
Directors’ contracts provide for a 6 month
notice-period for all appointments made
after 2020. Holders of Executive office
in the Company will vacate the office of
Director on notice (given or received) of
ceasing to hold Executive office, though
it is at the discretion of the Board to
extend Board membership until such
time as the Executive office has ceased.
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.
2024 Board Performance Evaluation
The Board is committed to enhancing its
performance and the effectiveness of its
activities on an ongoing basis. Regular
Board and Committee assessments
play a vital role in fostering continuous
improvement and ensuring effective
governance. These assessments provide
valuable insights into how the Board
operates, how directors collaborate, and
areas for development.
In compliance with the UK Corporate
Governance Code the Bank conducts
annual evaluations of Board performance,
with an externally facilitated evaluation
required every three years. The last
externally facilitated evaluation was
conducted in 2021 by the Promontory
Group, and accordingly, the 2024
evaluation was externally facilitated
by Korn Ferry. Korn Ferry provides no
additional services to the Bank, aside from
leadership coaching for the Executive
team in 2024, and maintains no other
connections with the Bank or individual
directors.
The 2024 evaluation assessed
the balance of skills, experience,
independence, and knowledge within the
Board, as well as its diversity, including
gender balance, and how effectively the
Board functions as a cohesive unit. It also
evaluated whether Board committees
possess the expertise necessary to
discharge their responsibilities effectively.
These evaluations are a cornerstone of
the Bank’s commitment to maintaining
high standards of governance and
accountability.
Year 1 –
Internal
Internally led Board
Effectiveness
review undertaken
by the Chairperson
and supported by
Company
Year 2 –
Internal
Internal led Board
Effectiveness
review undertaken
by the Chairperson
and supported
by the Company
Secretary
Year 3 –
External
Externally
facilitated Board
Effectiveness
review
PTSB Group Holdings plc - Annual Report 2024
93
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 Board Performance Process
The Board evaluation, externally facilitated by Korn Ferry, commenced in September 2024 and concluded in February 2025 comprised
a number of activities supported by internal actions set out in the table below:
Stage 1.
Approach agreed with the Chairperson
and endorsed by the Nomination, Culture
and Ethics Committee.
• A review of the existing board evaluation process (qualitative and quantitative)
was carried out by the Company Secretary and amendments proposed to the
Chairperson.
• Korn Ferry were selected as the external facilitator for the Board Evaluation. A key
determinant in the selection of Korn Ferry was their knowledge of the Bank’s key
issues and governance arrangements following a series of leadership coaching
sessions for the Executive team in 2024.
• Korn Ferry met with the Chairperson and Company Secretary to discuss and
agree the scope and objectives of the review.
Stage 2.
Korn Ferry undertake a review of the
Board.
• Korn Ferry observed the 1 October 2024 Board meeting.
• Korn Ferry facilitated a full day Board performance reflection session on 15
October 2024.
Stage 3.
Gather information and insights from
internal questionnaires and interviews.
• A self-assessment governance questionnaire was issued by the Company
Secretary to the Board/Board Committees and a more focussed questionnaire to
ExCo (on ExCo perception of Board Governance).
• 1 to 1 performance meetings were held between the Chairperson and Non-
Executive Directors. These meetings also assessed the training requirements for
individual directors and collectively for the Board.
• The Senior Independent Director (‘SID’) engaged with Directors to seek feedback
on the Chairperson’s Performance.
• The Chairperson completed the annual performance evaluation of the CEO and
reported on same to Nomination, Culture and Ethics Committee.
• An internal review of governance obligations was undertaken incorporating a
review of Director Independence; Board and Committee tenure; attendance
schedule for 2024 Board and Board Committee meetings; assessment of
external directorships and time commitments; review of conflicts of interest and,
certification of director fitness and probity requirements.
Stage 4.
Individual Board Committees reviewed
the results of their Committee
questionnaire.
• During December 2024, each Board Committee held a meeting and discussed
the results of the individual committee assessments. Feedback and actions from
these meetings informed the overall Board Evaluation and actions to improve
Board and Board Committee effectiveness.
Stage 5.
At the February 2025 Nomination,
Culture and Ethics Committee and
Board meetings, outputs from Korn Ferry
and all the internal assessments were
considered.
• Korn Ferry report prepared based on their observations and having been provided
with all feedback and data from Stage 3.
• All feedback from Stage 3 and 4 together with the Korn Ferry Report analysed
and assessed.
• A series of insights reviewed based on Korn Ferry Report and Stage 3 and 4
findings.
Corporate Governance Statement
Board Leadership and Effectiveness (continued)
Outcomes and Actions of 2024
Board Performance Evaluation
During a meeting held on 4 February
2025, the Nomination Culture and Ethics
Committee considered reports from
Korn Ferry and the Company Secretary
which provided both internal and external
perspectives on Board performance.
The Korn Ferry report focussed on the
following areas:
1. Definition of Board Mandate:
demonstrating there was clear,
common understanding of purpose and
accountabilities with a focus on Board
Culture.
2. Delivery of Mandate: Ensuring there
was focus on delivery of Board
objectives with tracked realisation of
expected outcomes.
3. Board Composition: Ensuring the right
mix of knowledge experience and skills
on the Board to support management in
delivery of the Bank’s strategy.
4. Director Contribution: Ensuring
Directors show and speak up
appropriately and demonstrate a clear
understanding of their responsibilities.
5. Team Dynamics: Exploring how
Directors worked together, and with
management. How the Chairperson led
and created the right balance between
support and constructive challenge of
the Executive team.
PTSB Group Holdings plc - Annual Report 2024
94
2024 Board Performance Themes and 2025 Focus Areas
Theme
Focus Area
Stakeholder Engagement
In recognising the Bank has multiple stakeholders who will often have differing views on the
Bank, ensure careful consideration is given to managing the expectations of stakeholders and
providing clear and constructive messaging for Board actions.
Efficiency of Governance
Ensure the Bank’s governance architecture and management committee structure is appropriate
to the size and business model of the Bank. Ensure the governance process is thorough but
efficient and customer focussed.
Decision Making
Greater consideration of stakeholders in the decision making of the Board through embedding
of the Bank’s 'Decision Yes Checks’ (an approach to ensure that all material decisions are
informed by consideration of our customers, colleagues, sustainability, risk while delivering
value for our shareholders).
Strategy
Ensuring execution of the Bank’s Integrated Strategic plan drives the Board agenda with simple
and clear KPIs (business performance and capability) to support Board oversight and challenge.
Ensure the Bank’s Strategic Planning process continues to evolve to the challenges of the
external environment.
Sustainability
Ensuring that the Bank’s Sustainability agenda is getting the right level of management and
Board oversight and the Bank continues to integrate sustainability within strategic decision
making.
Risk
Continue to prioritise oversight on the effectiveness of the Bank’s risk management framework
with focus on ensuring the effective utilisation of the three lines of defence model.
Board Knowledge and
Experience
Continue to ensure the knowledge, experience and skills for Board and the Executive
Committee are understood, are aligned to the Bank’s risk profile and designed to the ensure
delivery of the Bank’s Integrated Strategic Plan.
Overall, the report acknowledged
the Board had been effective in its
mandate and had played its role in
successfully steering the bank through
the unpredictable and turbulent events
of recent years and now faced into a
future that was certain to be equally
challenging. It was noted the Chairperson
was overseeing an evolution of Board
composition to ensure the right
knowledge, experience and skills existed
to fully understand and appraise the
multiple opportunities and challenges the
Bank would face over the coming years. It
was noted Board meetings operated with
efficiency; agenda items were clear, board
members were prepared, proceedings for
the most part ran to time, and scheduled
business got done.
Arising from the evaluation process, a
number of focus areas were accepted by
the Board with actions to be agreed and
implemented throughout 2025.
Director Induction and On-Going
Business Awareness
On appointment to the Board, all Directors
receive a comprehensive induction
training schedule tailored to their
individual requirements. The induction,
which is designed and arranged by the
Company Secretary in consultation with
the Chairperson (and approved by the
Board Nomination, Culture and Ethics
Committee), 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 Group’s operations
first hand. Where appropriate, additional
business awareness briefing sessions and
updates on particular issues identified
in consultation with the Chairperson 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.
PTSB Group Holdings plc - Annual Report 2024
95
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 Board Training and On-Going Business Awareness
Board Training Sessions
A number of Board training sessions were facilitated during 2024 to support on-
going business awareness and Director development. 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 2024 included: Cyber Security; Capital Models;
Operational Resilience; Individual Accountability Framework including SEAR; AML/
CTF training; and Sustainability, incorporating Science Based Targets and briefings
on CSRD.
Board Briefings
In addition to formal Board training sessions, a number of Board briefings were
presented to the Board during 2024. 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 2024 included: macro-economic outlook; capital and liquidity
planning; recovery planning simulation exercise; market abuse update; legal
and regulatory developments; geopolitical developments; Investor/Shareholder
perspectives, customer behaviour analysis; and, technology developments and
innovation.
Individual Director Development
An individual training plan is developed for each Director on appointment. The
purpose of individual training plans is to support individual Director development.
Each Director is required to undertake the Institute of Banking in Ireland 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.
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
During 2024, the Board Audit and
Remuneration committees were
composed of Independent Non-Executive
Directors. The Board Risk and Compliance
and Nomination Culture and Ethics
committees were composed of a majority
of Independent Non-Executive Directors.
The Membership and the Chairpersonship
of each committee are reviewed annually.
On the 6 February 2025, the Board
established the Business Transformation
Oversight Committee to support the Board
in monitoring and providing feedback
on strategic business transformation
initiatives and to ensure the Bank meets
its value realisation targets therein. It
is expected this committee will remain
constituted for a period of two years at
which point its purpose and remit will be
reviewed.
Each of the Board Committees has
a Terms of Reference, under which
authority is delegated by the Board,
and which are reviewed annually. The
Terms of Reference of each Committee
are available on the Bank’s website
https://www.permanenttsbgroup.ie/
document-centre. The Board Committee
Chairpersons are expected to attend the
AGM and be available to answer questions
from shareholders.
Corporate Governance Statement
Board Leadership and Effectiveness (continued)
Board Meetings
The table on page 84 shows Board
membership and directors’ meeting
attendance during 2024. There were
15 scheduled meetings in 2024 (which
included 3 all day strategy sessions). All
scheduled Board meetings were held in-
person. 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. There were 2 such
additional Board meetings held in 2024.
Agendas and papers are circulated to
Directors electronically via a secure online
Board portal in sufficient time to facilitate
review by the Directors.
At each of the scheduled Board meetings,
the directors received reports from
the Chairperson, Board Committee
Chairpersons, 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. The Board is particularly focussed
on strategy, customer outcomes,
sustainability, commercial/financial
performance and risk/compliance matters
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
Chairperson, CEO and Company Secretary
to ensure the Board and Executive
Management are aligned on Board
agendas.
PTSB Group Holdings plc - Annual Report 2024
96
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 annually review 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 it has conducted
a robust assessment of the Group’s
emerging and principal risks. This
assessment is integrated into the
Group’s systems of risk management and
internal control ensuring that risks are
continuously identified, monitored, and
mitigated effectively.
The Group has a well-established internal
control framework underpinned by an
enterprise risk management framework,
divisional operational frameworks and
has risk frameworks and policies in place
for each of the Group’s material risk
categories. The Group has a well-defined
approach to setting and monitoring its
appetite for risk, operates a ‘Three Lines
of Defence’ model and has the required
resources and governance structures in
place to support this model.
Monitoring of risk management and
internal control is an ongoing part of the
governance process at Board Audit and
Board Risk and Compliance Committee
meetings. The Board Audit Committee
reviews a control environment report on
a regular basis which provides a holistic
perspective of the control environment
within the Group. The Board Audit
Committee also receives reporting at each
meeting from the Head of Group Internal
Audit (‘GIA’), on the effectiveness of the
control environment through reporting
on findings that arise from internal audit
activity. On a bi-annual basis, the Board
Audit Committee reviews the interim
and final Audit Opinion prepared by the
Head of GIA. The Audit Opinion considers
the adequacy and effectiveness of the
governance, risk and control environment
within the Group and specifically, how
they relate to individual business areas,
it also takes into account the strategies,
objectives and risks of the organisation.
The Board Audit Committee reviews the
internal controls in place over financial
reporting in order to provide reasonable
assurance the half-year and full-year
accounts materially present a true and
fair view of the Group’s financial position
and performance. The Board Risk and
Compliance Committee receive updates
at each meeting from the Bank’s Chief
Risk Officer and Head of Compliance
concerning the Bank’s operational and
compliance controls.
The Chairs of the Board Audit Committee
and Board Risk and Compliance
Committee report on all material risk and
control related matters to the Board at
each scheduled meeting, as does the
Chief Risk Officer who attends a material
portion of each Board meeting.
The Board has a particular focus on
ensuring that appropriate governance
structures are in place to address issues
raised through internal review and through
feedback from stakeholders, including
regulators. There was no significant failure
of the Group’s system of risk management
and internal control during 2024 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 to sets
set out its key areas of responsibility;
• The preparation and issue of financial
reports, including the consolidated
Annual Report, is managed by Group
Finance with oversight from the Board
Audit Committee. The Group’s financial
reporting process is controlled using
documented accounting policies and
reporting formats issued by Group
Finance to all reporting entities,
(including subsidiaries), within the
Group, in advance of each reporting
period end. Group Finance 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 medium term financial
plan, prepared and considered by the
Board. Actual results are monitored and
there is monthly consideration by the
Board of progress against budgets and
forecasts;
• Clearly defined capital investment
control guidelines and procedures set
by the Board;
• Responsibilities for the management
of credit, investment and treasury
activities which 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 Chairperson
of the BAC;
Corporate Governance Statement
Risk Management and Internal Control
PTSB Group Holdings plc - Annual Report 2024
97
Strategic Report
Governance
Sustainability
Financial Statements
General Information
• The reviews completed by the Board
Audit Committee on the scope, nature
and independence of the work of
undertaken by GIA;
• The reviews completed by the Board
Audit Committee of progress with the
internal audit programme of work.
The Head of GIA reports regularly
to the BAC in private session. 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;
• 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 Chairperson 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 Board 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. The Board
Nomination, Culture and Ethics Committee
receives regulator reporting on key
themes and issues reported through the
‘Speak Freely’ process.
Internal Control over Financial
Reporting
The Group operates a Group Finance
Divisional Control Framework (a divisional
framework of the Group’s Internal Control
Corporate Governance Statement
Risk Management and Internal Control (continued)
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 is 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.
PTSB Group Holdings plc - Annual Report 2024
98
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.
Target:
A majority of Non-Executive Directors, the Board Chairperson
together with the Chairpersons 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:
• Retail Personal and/or Business
Banking
• Culture and Ethics
• ESG/Sustainability/Climate
• Customer Advocacy/Experience
• Accounting/Auditing and Model
Governance
• Risk Management
• Governance and Oversight
• Technology (including Cyber/
Resilience/Artificial Intelligence/
Digital Evolution/Fintech)
• Organisational Change
• Strategy Development/Execution
• Legal and Regulatory (Ireland and
EU)
• Capital Markets/Treasury/Investor
Relations
• Data and Analytics
• Workforce capability and strategy
• ALM/CTF
Skills:
• Authenticity
• Decisiveness
• Communication
• Judgement
• Customer and Quality
Orientated
• Leadership
• Loyalty
• External Awareness
• Persuasive
• Teamwork
• Sense of Responsibility
• Integrity
• Independence of Mind
• Innovative
• Neurodiversity
Corporate Governance Statement
Board Diversity Report
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 Board
Diversity policy is published on the Group’s
website: https://www.permanenttsbgroup.
ie/document-centre.
The Group recognises the benefits of
having a diverse and inclusive Board
whose members reflect a wide range of
relevant knowledge, skills and experience
with differences in educational and
professional background, ethnicity,
gender, age, cognitive and personal
strengths, and other qualities, in order
for the Board to be able to discharge its
duties and responsibilities effectively,
in addition to having a diverse senior
leadership and executive management
succession pipeline. The Group sees
diversity at Board level as an important
element in delivering on the Bank’s
strategic objectives.
The Board also recognises how diversity
of thought serves as a catalyst for richer
discussions, enhanced collective decision-
making, fostering talent and building
trust among colleagues, customers and
shareholders. 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
(desired mix of knowledge, experience
and skills), including regional and industry
experience, education and professional
experience, together with other diversity
aspects of Directors. These differences
are considered in determining the
optimum composition of the Board, and
where possible, balanced appropriately.
In November 2024, the Board Diversity
Policy was reviewed and updated to
reflect a broader range of relevant skills,
knowledge and experience required for
the Board in line with the Board Suitability
Matrix and reflects the following target
and guidance principles for 2025:
PTSB recognises the importance of having a diverse and inclusive
Board that fosters innovation, engagement and collaboration to
deliver on the Bank’s strategic objectives.
Diversity
A diverse and inclusive culture is essential
to the long-term success of PTSB and
enables the Group to respond to diverse
customer and wider stakeholder needs
and to deliver long-term sustainable
growth. The Group embraces diversity
at all levels of the organisation and
appreciates the different perspectives
and unique value each Board member and
employee brings to the role and the value
that creates for the business, colleagues,
community and wider stakeholders.
Further details on the Group’s
Organisational Culture, Diversity, Inclusion
and Equal Opportunity Programmes are
set out on page 206.
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
PTSB Group Holdings plc - Annual Report 2024
99
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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.
Cognisant of its role model
ambitions for the rest of the Bank,
the Board ensures that gender
diversity is extended to Senior
Board positions within the Bank.
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 Chairperson, Chief Executive Officer, Senior
Independent Director or Chief Financial Officer positions will be
held by a female (including those self-identifying as a female).
Geographic
Location
The Board should be comprised
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.
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 or worked outside of Ireland.
Age and Ethnicity
The Board 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 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 and
colleague base.
Guidance:
For each Director appointment, the Board will consider age,
ethnicity and other demographics of the Group’s customer
and colleague base together with relevant Board composition
benchmarking data to inform the design of any role profiles. In
doing so, the Board will have regard to the requirements under the
UK Listing Rules and the Parker Review in respect of non-white
ethnic minority representation on the Board. Consideration will also
include latest Irish census data on non-white ethnic minorities.
Corporate Governance Statement
Board Diversity Report (continued)
Objective of Board Diversity Policy
The Board is mindful of its commitment
to having a diverse and inclusive Board
and recognises the importance of age,
ethnicity and other demographics of
the Group’s customer and colleague
base which inform the design of the role
profile for each Director appointment, in
addition to gender, relevant knowledge,
experience and skills. 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 considers
relevant Board diversity benchmarking
data published by competent authorities
including the Central Bank of Ireland
and the European Banking Authority,
national census data and other relevant
international bodies and organisations.
At any given time, the Board may seek
to improve one or more aspects of
its diversity and measure progress
accordingly.
PTSB Group Holdings plc - Annual Report 2024
100
How the Board Diversity Policy was
implemented during 2024
All Board appointments are made on merit
and objective criteria, in the context of
the relevant knowledge, experience and
skills that the Board as a whole requires
to be effective and having regard to the
Diversity Policy. The balance and mix
of appropriate and relevant knowledge,
experience and skills of Non-Executive
Directors are taken into account when
considering a proposed appointment and
is reviewed at least annually by the Board.
The Board Nomination Culture and
Ethics Committee carries out a review
of Board performance annually. A part
of that review considers the succession
planning, composition and diversity needs
of the Board. In 2024, the Committee
carried out a detailed analysis of Board
and Committee composition, Board
Independence levels, Board diversity
analysis, review of the Board Suitability
Matrix and potential retirements over
the following two-year period in light
of planned departures from the Board
in 2024 and 2025. This comprehensive
assessment allows the Board to recognise
strengths and address weaknesses,
plan for relevant knowledge, experience,
skills and other diversity needs of the
enlarged Group for the future in line with
its strategic priorities and evolving risk
profile, in addition to developing a diverse
pipeline and effective succession planning
for departures from the Board.
The behaviours likely to be demonstrated
by potential Non-Executive Directors
are also considered when interviewing
for new appointments to ensure an
environment in which a range of
perspective, insight and challenge which
enhances collective decision-making
and reflects positive conduct and culture
of the Board is expected, achieved
and maintained in the Boardroom and
beyond. In reviewing Board composition,
the Nomination, Culture and Ethics
Committee considers the benefits of
diversity, including gender and other
characteristics, and looks to ensure
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 technology, change and
risk management, customer advocacy,
aviation, healthcare, ESG/sustainability
and climate risk, capital markets,
workforce planning and remuneration,
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.
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 a proportion of the Board
has a deep understanding of financial
products and has established guidelines
to ensure Board candidates are selected
on merit and objective criteria, based
on their relevant skills, competencies,
qualifications and ability to commit
sufficient time to the role, and in line with
the Board Diversity Policy.
2024 Board Diversity Progress
At 31 December 2024 the Board female/
male stood at 60:40 (67:33 for Non-
Executive Directors) against a gender
diversity target of 50:50. This exceeds the
UK Listing Rules target to have at least
40% female representation on the Board.
The Board has also met its diversity
target of having at least one senior Board
position held by a female, being the
Chairperson position, throughout the full
year which is also in line with the role
model ambitions of the Board in increasing
diversity and inclusion across the rest
of the Group. The Board continues to
review and monitor progress on diversity
of the Executive Committee, the Senior
Leadership team and throughout the
wider Group as part of its commitment to
improve gender diversity and other wider
diversity aspects of the workforce.
The Board broadly achieved gender
balance with regard to its Committee
composition and has regard to wider
diversity aspects among the members of
the Board Committees.
The Board has not set a target for having
at least one member of the Board from a
non-white ethnic minority background in
its Diversity Policy as required under the
UK Listing Rules as the Board recognises
the challenges in setting diversity targets
that it may not be in a position to achieve
in the medium term. The Board will keep
this position under review having regard
to ensuring the Board has the appropriate
balance of relevant knowledge,
experience and skills to deliver the
Group’s strategic objectives, and having
regard to the latest benchmarking data
on non-white ethnic minorities in Ireland
being the geographical provenance of
the Group’s customer and colleague
base. Furthermore, when considering
Board appointments, the Board will have
regard to the requirements under the
UK Listing Rules, and the Parker Review
in respect of non-white ethnic minority
representation on the Board. The Group
is committed to having a diverse Board,
to achieving the targets and guidance set
out in its Diversity Policy and to ensuring
an open and fair recruitment and selection
process that reflects relevant metrics of
diversity for each Director appointment
in the best interests of the Group and its
stakeholders.
The Board exceeded its objective of
requiring a majority of Non-Executive
Directors, the Board Chairperson together
with the Chairpersons of the Audit and
Risk and Compliance Committees to
have relevant banking and/or financial
experience and is satisfied that all
Directors have attained the required
financial literacy threshold. The Board
diversity ratio of Non-Executive Directors
with experience gained from living or
working outside of Ireland to bring an
external perspective and insights from
other jurisdictions and cultures stood
at 25% in line with its target range of
between 20-30%. The other diversity
aspects including age, nationality and
independence are displayed in line with
the guidance for Board appointments as
set out in the Board Diversity Policy.
PTSB Group Holdings plc - Annual Report 2024
101
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 Board Diversity Measures
This section outlines the key diversity and inclusion metrics for Board and Executive Management at 31 December 2024, being the
chosen reference date within the accounting period as required by the UK Listing Rules LR14.3.30-14.3.33. This section also includes
detail of tenure, age, skills and experience. All information on the Board and Executive Management^ gender identity and ethnic
background was manually gathered. The Chief Financial Officer and Executive Director (Nicola O’Brien) resigned from the Board on 29
August 2024 and therefore is not included within the diversity metrics at the chosen date.
Gender Identity
Number of
board members
Percentage of
the board
Number of
senior positions
on the board
(CEO, CFO, SID
and Chair)
Number in
executive
management
% of executive
management
Men
4
40%
2
8
80%
Women
6
60%
1
2
20%
Other categories
-
-
-
-
-
Not specified/prefer not to say
-
-
-
-
-
Note: Executive Directors are counted in both Board and Executive Management disclosures. Company Secretary included in Executive Management disclosure.
^ Executive Management refers to the Group Executive Committee.
Ethnic Background
Number of
board members
% of the board
Number of
senior positions
on the board
(CEO, CFO, SID
and Chair)
Number in
executive
management
Percentage
of executive
management
White British/Irish or other White (including minority-
white groups)
10
100%
3
10
100%
Mixed/Multiple Ethnic Groups
-
-
-
-
-
Asian/Asian British/Irish
-
-
-
-
-
Black/African/Caribbean/Black British/Irish
-
-
-
-
-
Other ethnic group, including Arab
-
-
-
-
-
Not specified/ prefer not to say
-
-
-
-
-
Note: Executive Directors are counted in both Board and Executive Management disclosures. Company Secretary included in Executive Management disclosure.
Corporate Governance Statement
Board Diversity Report (continued)
Nationality
Irish
British
German
US
7
1
1
1
Independence
7
1
2
Independent Non-Executive Directors
Non-Executive Directors
Executive Directors
Age Profile
40-49
50-59
60-69
70+
1
2
5
2
PTSB Group Holdings plc - Annual Report 2024
102
2025 Board Diversity Priorities
Area of Diversity
Board Objective
2025 Board Action
Gender
The Board remains
committed to maintaining
gender diversity on the
Board.
• Board Gender Diversity Target maintained at least 50% female; and,
• Encourage initiatives that promote broader inclusive gender diversity across
the Group, in line with the Organisational Culture, Diversity, Inclusion and Equal
Opportunity Programmes.
Alignment to
customer and
colleague base
The Board acknowledges
the Group has a diverse
customer and colleague
base and should take
account of same in
considering the diversity
requirements of the Board.
• The Board Diversity Policy recognises the importance of ensuring 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; and,
• Receive reports on actions taken by the Bank to foster a more inclusive,
equitable and diverse organisation including colleague surveys and customer
experiences.
Board Diversity
Policy
The Board recognises
there are many aspects
of diversity such as
age, social and ethnic
backgrounds, gender,
cognitive and personal
strength, skills and
experience, and the
importance of ensuring
wider diversity is
considered for Board
appointments.
• 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
relevant 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, in addition to ensuring a diverse Senior Leadership and Executive
Management succession pipeline.
Board
Recruitment
and Selection
and Suitability
The Board remains
committed to having a
diverse range of relevant
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.
• Maintain a majority of Non-Executive Directors, including the Board
Chairperson, together with the Chairpersons 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 or worked outside of Ireland given the Bank’s strategic priorities and
evolving risk profile;
• Retain the requirement that all candidates for appointment need to demonstrate
the financial competency 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 and objective criteria, based on their relevant
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.
Board
Succession
Planning
The Board is responsible
for overseeing succession
plans for the Board and
Senior Executives.
• Review Succession Plans of the Board and Senior Executives ensuring they are
sufficiently robust; that talent management and development plans remain in
place with live talent maps to ensure a diverse pipeline of successors at Senior
Leadership team level;
• Ensure the Group pipeline of successors takes account of the Group’s diversity
and inclusion measures and ambitions; and,
• Ensure the results of the Board Performance Review inform the Board
appointment and succession planning process, and that it continues to reflect
the requisite time for the selection, recruitment and appointment process.
• Where the requisite skills and expertise are not available on the Board, ensure
that it has access to such expertise and skills.
PTSB Group Holdings plc - Annual Report 2024
103
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Dear Reader,
I am pleased to present my report
as Chairperson of the Board Audit
Committee (the ‘Committee’ or ‘BAC’).
The Committee, as defined in its Terms
of Reference primarily ensures the proper
implementation of the Group’s financial
and internal control policies, practices
and decisions. It aims to align these
with Group strategies and shareholder
interests, while operating within applicable
regulatory and legal requirements.
As this marks my final report as
Chairperson before I retire from the Board
on the 30 July 2025, I want to express
my gratitude to my fellow Committee
members, the executive team, and all
stakeholders for their collaboration and
support during my tenure. The process
for appointing my successor is at an
advanced stage and I am confident
the transition will ensure continued
effective oversight of the Committee’s
responsibilities.
2024 saw KPMG’s second audit as the
Group’s External Auditors. I am pleased
with the thoroughness and challenge
they brought to the audit process, which
reflects their commitment to providing a
fresh perspective on the Group’s control
environment. Their detailed reviews
continue to enhance the integrity of the
Group’s financial reporting.
During the year, Nicola O’Brien stepped
down as Chief Financial Officer. Nicola
played an important role in supporting
the Bank on its journey to grow and
diversify its business and I would like to
acknowledge the commitment shown
to the Bank throughout her tenure. I am
also delighted to welcome Barry D’Arcy
as her successor. Barry D’Arcy is an
experienced finance leader and Board
Executive Director. Looking ahead,
ensuring that both the Finance Function
and Group Internal Audit (‘GIA’) continue to
have the necessary skills and resources,
remains a key priority for 2025. The
In 2024, the Committee conducted a
comprehensive review of the Group’s
compliance with the provisions of the
UK Corporate Governance Code. This
review reaffirmed the Bank’s commitment
to maintaining the highest standards of
governance and accountability.
As the Committee looks to the future, a
key area of focus will be working closely
with the BRCC on the Group’s capital
model programme. Ensuring these models
are robust, compliant, and aligned with
regulatory expectations will be critical
to supporting the Group’s growth and
resilience.
In closing, I want to reiterate my thanks
to the BAC members, management, and
staff for their hard work and dedication. I
am confident the Committee’s continued
focus on governance, assurance, and
oversight will position the Bank for
ongoing success.
Ronan O’Neill
Chairperson, Board Audit Committee
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.
Committee will continue to work closely
with management to support recruitment,
development, and capacity building within
these critical functions.
The Committee has been actively
engaged in preparing the Group’s first
disclosure under CSR Regulations. This
has included reviewing data readiness and
aligning processes to ensure compliance
with this important new disclosure
requirement.
The design and implementation of
the Internal Audit Plan are critical
to the Committee’s oversight. A
notable development in 2024 was the
introduction of rapid review audits, which
provided timely insights into issues of
material importance to the Committee.
Additionally, there has been a marked
increase in First-Line attendance at
BAC meetings to discuss audit findings,
reflecting a deeper engagement with the
Committee’s work.
The Committee maintained a strong
focus on the effectiveness of the Bank’s
control environment, with significant
progress made on evolving a ‘Three
Lines of Defence’ combined assurance
process. This effort has included close
review of the Bank’s internal audit opinion,
(provided by the Head of Group Internal
Audit), and an ongoing assessment of key
performance measures tracking the status
of the Bank’s control environment. Linked
to this point, the Committee closely
monitored all key controls over financial
reporting to ensure the Bank’s published
accounts provide a true and fair view on
the financial position of the Group.
During 2024, I have also supported
enhanced collaboration with the Board
Risk and Compliance Committee (‘BRCC’)
to align on key priorities and to ensure
each Committee’s time is utilised to
maximum effect while aligned to its own
legal and regulatory obligations.
PTSB Group Holdings plc - Annual Report 2024
104
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 and provides the
necessary information for shareholders to
assess the Group’s position, performance,
business model and strategy.
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 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 2024
During 2024, 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 2024, the Committee also:
• Reviewed GIA activity throughout the
year, including a review of performance
against the 2024 internal audit plan;
• Prepared for and considered
disclosures under CSR Regulations;
Composition and Operation
The Board Audit Committee (‘BAC’) comprises five Independent Non-Executive
Directors, each bringing significant expertise and experience to their role. Detailed
biographical information for each member is provided on pages 79 to 83 of this report.
Neither the Board Chairperson nor the CEO is a member of the BAC, ensuring the
Committee’s independence and objectivity.
To enhance the Committee’s effectiveness, the Board mandates that the Chairperson
of the BAC must possess recent and relevant financial experience, ensuring robust
oversight of the Group’s financial reporting and internal controls. The Chairperson is
responsible for providing strong leadership to the Committee, setting meeting agendas,
facilitating open and productive discussions, and ensuring the Committee operates
efficiently and in alignment with its Terms of Reference. Collectively, the members of
the BAC bring a diverse and complementary range of skills, including financial expertise,
risk management, corporate governance, and industry-specific knowledge, all of which
contribute to the effectiveness of the Committee and the overall governance of the
Group.
The BAC meets at least six times a year with additional meetings convened as
necessary. Each scheduled meeting begins with a private session attended exclusively
by Committee members, fostering candid discussions and an opportunity to review key
matters on the agenda. Following this, the head of GIA is invited to join the meeting,
allowing the Committee to engage directly on the scope, findings, and progress of
internal audit activities while ensuring independence from senior management. Senior
management, External Auditors, and other invitees participate only by invitation.
This structured approach safeguards the independence and integrity of the BAC’s
deliberations and decisions.
To promote cross-committee collaboration and alignment, the Board requires that at
least one member of the BAC also serves on the Board Risk and Compliance Committee.
This ensures a seamless flow of information between the Committees, enhancing the
organization’s overall risk management and governance framework. Richard Gildea,
Catherine Moroney and Anne Bradley are members of both Committees.
2024 Committee Meeting Attendance
Member
Appointed
Ceased
Number of
Years on the
Committee
2024 Meeting
Attendance
Ronan O’Neill*
02 Nov 2021
-
3.2
9/9
Donal Courtney
03 Oct 2018
1 Oct 2024
6.0
5/6
Anne Bradley
30 Mar 2021
-
3.8
9/9
Ruth Wandhöfer
31 Dec 2023
-
1.0
8/9
Catherine Moroney
12 Dec 2023
-
1.1
8/9
Richard Gildea
1 Oct 2024
0.3
2/2
*
Chairperson
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 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
PTSB Group Holdings plc - Annual Report 2024
105
Strategic Report
Governance
Sustainability
Financial Statements
General Information
• Reviewed the Group’s Pillar 3 policy and
associated disclosures;
• Approved the GIA Charter, resourcing
model and considered the effectiveness
of the function;
• Reviewed External Auditor
independence and effectiveness;
• Approved the TCFD Report included in
the 2024 Annual Report;
• Reviewed the continued recognition of a
Deferred Tax Asset (‘DTA’) on tax losses
carried forward;
• Approved changes in accordance
with International Financial Reporting
Standards (‘IFRS’) and International
Accounting Standards (‘IAS’);
• Reviewed impairment provisions;
• Reviewed control environment reports;
• Reviewed Technology updates with
focus on IT incidents impacting
customers;
• Reviewed the effectiveness of internal
control over financial reporting;
• Approved the Internal Audit Plan for
2025;
• Reviewed the governance and
approval arrangements underlying
the fair, balanced and understandable
assessment of the Annual Report;
• Assessed the Longer Term Viability and
Going Concern Statements;
• Reviewed the disclosures on
compliance with the UK Corporate
Governance Code;
• Reviewed and approved changes to the
Committee’s Terms of Reference with
updates to align with the UK Corporate
Governance Code 2024, a new Irish
Corporate Governance Code, (effective
from 1 January 2025 and against which
the Group will comply or explain),
and against the Chartered Institute of
Internal Auditors- Internal Audit Code of
Practice;
• Reviewed non-impairment provisions
including legacy, legal and compliance
liabilities; and
• Reviewed the basis, background and
level of Non-Audit fees paid to KPMG.
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 2024
Financial Statements as set out on the
current and the following page.
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 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 Management judgement.
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 2024, the impairment
provisions included €136m of
Management’s judgement in impairment
model parameters (€44m) and overlay
adjustments to modelled ECL outcomes
(€92m), see note 2 for further information.
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 Committee was satisfied that the
provision and related disclosures in the
financial statements were appropriate.
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 had
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
2024 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
approved an impairment charge for the
year of €263m due to the recoverable
amount based on the Value in Use
calculation being in excess of the carrying
value.
IT Access
Certain matters relating to IT access
controls were communicated to the
Committee through the external audit
process. The Committee reviewed these
matters and was satisfied sufficient
mitigating controls were 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 judgement, 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 judgements and agree
with Management’s view that the Group
continues on a going concern basis and
that there are no material uncertainties.
Corporate Governance Statement
Board Audit Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
106
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 in account Group’s current and
projected financial position taking in
account the principal risks facing the
Group.
The period over which we consider
longer-term viability
The Directors have assessed the viability
of the Group over the three-year term
which falls within the time horizons
considered for the Group’s strategic
planning and the regulatory stress 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
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 (‘MTP’) and 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 and Company’s
principal risks together with the 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 2024
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 or liquidity positions
in the viability period of assessment
to December 2027 after management
intervention.
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.
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 2024, and its liquidity
position remains strong at 31 December
2024 with the Group holding a significant
liquidity buffer. The Group has no reliance
on ECB funding and is 92% deposit
funded with plans to diversify its funding
profile over the horizon of the next three
years.
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 Group continues to undertake a
number of initiatives to improve its
liquidity position in the areas of deposits,
collateral optimisation, and wholesale
markets activity.
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 2024. Directors and
Management have reviewed the MTP
and based on this, the Directors and
Management are satisfied that the Group
is well positioned to continue to deliver
profits in future years.
Directors and Management have
considered the forecast sufficiency of this
capital base, and its ability to withstand
additional stress scenarios such as
the economic environment in Ireland
deteriorating. The Group is confident that
all regulatory requirements will be met
over the period to 2027.
Reasonable Expectation of longer-term
viability
Based upon the above assessment, the
Directors have a reasonable expectation
that the Group and Company will be able
to continue in operation and meet its
liabilities as they fall due over the three-
year period of their assessment to 31
December 2027.
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 2024.
Corporate Sustainability Reporting
(CSRD)
The CSRD was transposed into Irish
law and came into effect on 1 January
2024 for Irish companies with the aim of
improving the existing requirements of
the European Union’s (‘EU’) Non-Financial
Reporting Directive, to better harness the
potential of the EU in the transition to a
fully sustainable and inclusive economic
and financial system, in accordance with
the European Green Deal and the United
Nations’ Sustainable Development Goals.
Following a significant programme of
work, the Bank is pleased to publish its
inaugural CSRD disclosure within this
PTSB Group Holdings plc - Annual Report 2024
107
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Annual Report. It can be found in the
Sustainability Statements beginning on
page 140.
The Bank’s External Auditor was
engaged to provide limited assurance
of the CSRD disclosure in line with the
recommendations set out within the
Directive. Their assurance opinion can be
found on page 137.
Throughout the year, updates on the
progress of the CSRD were brought
to the BAC, with the Committee being
responsible for ensuring an integrated
approach to disclosure preparation and
delivery, providing a link between the
Board and the External Auditors providing
the assurance, and ultimately, signing off
the disclosure.
Relationship with External Auditors
The Group’s External Auditors are KPMG
who were appointed by shareholders
in 2023. 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
Auditor 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 2024
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 ethical
and professional guidance and that, in
their professional judgment, they are
independent of the Group.
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 2024 was €2.0m (excluding
VAT) payable to KPMG Ireland. €0.8m
(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 Frank Gannon who was
appointed in 2023. 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.
Review of Group Internal Audit
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 Group
Internal Audit (‘GIA’) being the Third Line
of Defence. GIA’s purpose is to strengthen
the organisation’s ability to create, protect,
and sustain value by providing the board
and management with independent,
risk-based, and objective reasonable
assurance, advice, insight, and foresight.
The Head of Internal Audit has a direct
reporting line to the Chairperson 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.
GIA’s mandate allows for full and
unrestricted access to all functions,
records, and personnel. The GIA authority,
roles, and responsibilities are set out in
the GIA Charter which is approved by
the BAC annually. The primary role of
GIA is to develop an annual risk-based
audit plan that assesses independently,
the effectiveness and efficiency of
internal controls, risk management and
governance systems and processes and
provides assurance on these systems
and processes, including the reporting of
overall findings and any areas of concern
resulting from such assurance activities.
GIA provide the BAC with an annual
resourcing assessment. The 2024
resourcing assessment included a review
of the current GIA resource model and
skills, with an emphasis on ensuring
adequate resources and skills are in
place to provide assurance in relation to
the current and emerging risk profile of
the Group. The BAC is satisfied that the
quality, experience, and expertise of the
function is appropriate to the needs of the
Group.
In line with the Global Internal Audit
Standards, 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 Global Internal Audit Standards.
The results of the latest internal quality
assessment, completed by the Chartered
Institute of Internal Auditors (‘CIIA’), with
an overall rating of ‘Generally Conforms’
was presented to the BAC in Q1 2024.
The last external quality assessment
was completed by the CIIA in 2021
and was rated as ‘Generally Conforms’
against the CIIA Standards. The Audit
Committee was satisfied that during
2024, GIA demonstrated flexibility and
responsiveness to enable the function
to focus on current and emerging risks,
inclusive of audit requirements driven
by both legislation and regulation,
auditable processes within the Group and
alignment with the Global Internal Audit
Standards. Through these measures
the Audit Committee has assessed the
effectiveness of the internal audit function
and is satisfied that the function is
appropriate to the needs of the Group.
Corporate Governance Statement
Board Audit Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
108
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.
Dear Reader,
As Chairperson of the Board Nomination,
Culture and Ethics Committee (the
“Committee”), I am pleased to present
the report of the Committee for the year
ended 31 December 2024. 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 2024 as set
out below.
A key focus area for the Committee
is effective refreshment of Board
composition to ensure Directors have
the collective knowledge experience
and skills to oversee delivery of the
Group’s strategic objectives. Arising
from the retirement of Donal Courtney in
October 2024 and planned retirement of
Ronan O’Neill on 30 July 2025, in 2024
the Committee carried out a collective
suitability assessment of the Board with a
view to aligning the Board skills with the
strategic direction and risk profile of the
Group. This assessment demonstrated
the need to identify candidates with
deep financial and accounting experience
who could chair the Board Risk and
Compliance Committee following the
departure of Donal Courtney and chair the
Board Audit Committee with the planned
departure of Ronan O’Neill. Following the
appointment of Rick Gildea (an existing
Board member) as Chairperson of the
Board Risk and Compliance Committee
in October 2024, a further need was
identified to appoint an Independent Non-
Executive Director with deep financial and
capital markets experience. The selection
and recruitment process for each of these
board positions is at an advanced stage.
The Committee also oversaw the process
to identify and select a successor for
Nicola O’Brien, the Group’s Chief Financial
Officer (CFO) and Board Executive
Director who resigned from the Bank in
August 2024. I am very pleased that,
following a robust selection process
involving internal and external candidates,
Barry D’Arcy, the Bank’s Chief Risk
Officer has been appointed CFO and
Corporate Governance Statement
Nomination, Culture and Ethics Committee
customers and colleagues through
enhanced governance, performance
and accountability and which reflects
the culture, purpose and values of
the Group. The Committee oversaw
the implementation of the IAF through
an extensive programme of work
to embed new Conduct Standards
requirements from the end of 2023,
enhancements to the Fitness and Probity
regime, extensive mapping of roles
and responsibilities to implement the
Senior Executive Accountability Regime
(SEAR) requirements by 1 July 2024 and
embedding the IAF Target Operating
Model into business-as usual across the
Bank. Further work to prepare for the
implementation of SEAR for the Non-
Executive Directors by 1 July 2025 is
underway.
The Committee oversaw the
enhancements to individual and
collective Board induction, training and
development plans which were refreshed
to reflect a more holistic approach to
the required skills on the Board with
a focus on enhanced effectiveness to
adapt to the evolving nature and pace
of change in the Group’s operating
environment. Enhancements to handover
arrangements in line with the IAF
reflected positively on incoming role
holders and the Committee received
regular updates throughout the year on
the implementation of such plans which
provided assurance as to the robustness
of the arrangements and transition of
roles on the Board, in particular new
Board Committee Chair appointees.
The Committee recognises the
importance of looking after the
Bank’s customers at all stages of their
journey with PTSB and oversaw the
introduction of the Bank’s “Decision
Yes Checks” as a key element of the
Bank’s decision-making and approval
process; these assessments help in
the making of informed decisions,
enabling comprehensive consideration of
potential customer impact and ensuring
fair outcomes for customers and other
Board Executive Director. I was also very
pleased with how the systems put in place
under implementation of the Individual
Accountability Framework worked well
facilitating the timely re-allocation of the
Responsibilities for the CFO at the time
of her departure. Further details on the
selection and recruitment process for
the CFO is set out later in this Committee
report.
During 2024, a key area focus for the
Committee was the refreshment of
succession planning arrangements
for the Executive Committee (ExCo)
and Senior Leadership team. This
included a comprehensive review of the
arrangements for the Chief Executive
Officer (CEO), CFO and other Executive
Committee roles which included live
talent maps, stress testing of potential
internal candidates and aligning training
and development plans accordingly.
The Committee was assured by the
robustness of the process following
the resignation of the CFO in August
2024 when the succession planning
arrangements were invoked which led to
a more efficient recruitment and selection
process to fill the vacancy. Further
detail on these succession planning
arrangements implemented during the
year are set out in this report.
The Committee also undertook a review
of business-critical roles which are
particularly required to maintain resilience
in certain areas of the Bank and to
safeguard delivery of strategic priorities.
The Committee oversaw the development
and implementation of succession plans
for all business-critical roles together with
the integration of succession planning
into Strategic Workforce Planning to
incrementally grow talent within the
organisation and ensure robustness of
mitigation plans in place for unplanned
vacancies.
A key programme for the Bank during
2024 and continuing into 2025 is the
Central Bank (Individual Accountability
Framework) Act 2023 (IAF) which the
Group has seen as a positive development
in supporting the building of trust with
PTSB Group Holdings plc - Annual Report 2024
109
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Composition and Operation
The Committee is composed of a majority of Independent Non-Executive Directors.
The Board requires that the Board Chairperson and the Senior Independent Director
(SID) are members of the Committee. The Committee holds a member only session at
the start of each meeting following which the Committee may invite members of the
executive team to join, this may include the Chief Executive Officer, Chief Customer and
People Officer and Head of Talent.
2024 Committee Meeting Attendance
Member
Appointed
Ceased
Number of
Years on the
Committee
2024 Meeting
Attendance
Julie O’Neill*
17 Jan 2023
-
2.0
9/9
Ronan O’Neill
26 Jul 2016
-
8.4
9/9
Marian Corcoran
30 Mar 2021
-
3.8
9/9
Celine Fitzgerald
30 Mar 2021
-
3.8
9/9
Paul Doddrell
31 Dec 2023
-
1.0
9/9
*
Chairperson from 31 March 2023
stakeholders which is a key priority for the
Bank. Both approaches support diversity
of thought and ultimately enhance
decision-making.
The Committee continues to engage
in meaningful manner to support the
Group’s espoused culture. In this regard
the Committee considered the results of
the 2024 ‘Every Voice Counts’ colleague
engagement survey. This survey explored
the behaviours and activities across the
Bank measuring critical success factors
for delivering a strong customer centric
risk culture with both qualitative and
quantitative results. The Committee
also met with colleagues from the
People Experience Council (employee
representative group on culture evolution
and colleague wellbeing) during the year
and received updates on actions identified
to address feedback from the Every Voice
Counts survey and overall measures to
enhance the colleague and customer
experience. This included enhancements
to learning and development, employee
value proposition, communication and
engagement with colleagues, focus on
further reducing the gender pay gap and
alignment of gender balance aspirations.
The Committee also considered the
output from the 2024 Board Evaluation
approach externally facilitated by Korn
Ferry further details of which are set out
on page 94 of the annual report.
Julie O’Neill
Chairperson, Board Nomination, Culture
and Ethics Committee
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 Chairperson. The
Board Chairperson does not attend
the Committee when it is dealing with
the appointment of a successor to the
Board Chairperson. 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 practical opportunity following
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
and composition of Board Committees.
The Committee also has responsibilities
for supporting the Board on oversight on
culture, ethics, 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
regular and planned refreshment of Board
and Board Committee membership.
Arising from such succession planning
reviews, the Committee agreed the
need to identify replacements for Non-
Executive Directors Donal Courtney and
Ronan O’Neill for which a recruitment
process is at an advanced stage.
The Committee maintained its focus on
the Executive Committee (ExCo) and
Senior Leadership talent pipeline and
succession plans reflecting the Board’s
responsibility to ensure appropriate plans
are in place. The Committee oversaw
development of robust talent management
and succession plans for ExCo members
which included the development of
a diverse pipeline of successors at
senior leadership team level in line with
the talent management, development
and succession planning programmes
within the Group which reflect the
DE&I ambitions. This included talent
mapping individuals to identify strengths,
development needs (both experiential
and formal training programmes) and
future potential of identified successors
internally together with talent maps for
potential external successors identified for
certain ExCo and Senior Leadership roles.
Executive Committee Composition
During 2024, the Committee oversaw
the assessment of existing leadership
capabilities at Executive Committee and
SLT level (ExCo minus 1) which resulted
in ExCo changes to support the CEO
in the delivery of the Group’s strategic
objectives and to further strengthen
the talent management and succession
planning pipeline in line with the DE&I
Corporate Governance Statement
Nomination, Culture and Ethics Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
110
ambitions across this Group. Following
this assessment, the need to strengthen
the strategic focus in the Group’s current
customer proposition, channel strategy
and sustainability and corporate affairs
agenda was identified.
Arising from these assessments, Leontia
Fannin was appointed Chief Sustainability
and Corporate Affairs Officer on 1 August
2024 reflecting the Group’s commitment
to sustainability as a key driver of its
corporate strategy and the value it places
on corporate affairs as a driver of internal
and external stakeholder engagement. Ms
Fannin brings a wealth of experience in
corporate affairs, reputation management,
colleague communications, sponsorships,
corporate social responsibility and
sustainability. Ms Fannin is responsible
for building and proactively managing
the Bank’s Corporate Affairs Strategy
alongside responsibility for PTSB’s
Corporate Social Responsibility and
Sustainability strategies.
Patrick Farrell was appointed Chief
Retail Banking Officer on 1 August 2024
with responsibility for leading the Bank’s
retail distribution channels (Branch,
Digital, Broker, Mobile Mortgages,
Private Banking, Business Banking and
Asset Finance) in recognition of the
importance of the increased nationwide
branch footprint, significant growth and
diversification of the business through
business banking and asset finance.
A member of the Bank’s Executive
Committee since 2018, Mr Farrell brings
over 25 years’ experience in the banking
industry to this role and is responsible
for the commercial performance of the
personal and business banking business
including sales strategy and service
provision to PTSB customers through all
channels.
Ger Mitchell was appointed as Chief
Customer and People Officer on 1
August 2024 with responsibility for
the development and implementation
of all aspects of the Bank’s Customer
and People Strategy, including the
Bank’s Commercial strategy, Customer
Enablement strategy, Product strategy,
Marketing, Brand and Sponsorships
strategy, as well as the Bank’s People
and Culture strategies. A member of
the Bank’s Executive Committee since
2012, Mr Mitchell has successfully led
a number of strategic programmes of
work for the Bank throughout his time
and his experience will be central to the
Bank’s delivery of its customer focused
Altogether More Human brand promise.
Board Composition
A key function of the Committee is
succession planning for the Board. There
were no appointments to the Board in
2024. Following the retirement of Donal
Courtney, the planned retirement of
Ronan O’Neill and the resignation of Nicola
O’Brien, the Board Nomination Culture
and Ethics Committee oversaw the
recruitment and selection processes for a
total of three new Board appointments as
set out below.
Chief Financial Officer
Following the resignation of the CFO in
August 2024, the Committee invoked
succession planning arrangements and,
with the support of recruitment specialists
Odgers Berndtson (Odgers) oversaw
selection and recruitment process which
led to the appointment of Barry D’Arcy
as CFO and Executive Board Director
on the 25 February 2025. Barry D’Arcy
was selected as the preferred candidate
following a competitive selection process
involving both internal and external
candidates. A comprehensive handover,
training and development plan for Barry
was approved by the Committee who will
provide oversight of the implementation
thereof. In his new role, Barry is
responsible for leading, managing and
overseeing all Finance related matters
of the Group and growing the Bank’s
financial planning and analysis function to
enhance the commercial and operational
value, build a culture of transparency
and accountability, and support the CEO
in directing the business of Bank and
delivering upon its strategic objectives.
Independent Non-Executive Directors
A collective suitability assessment of
the Board was undertaken in light of the
planned departure of Donal Courtney
from the board in October 2024 and
Ronan O’Neill in July 2025 leaving vacant
the Chairs of Board Risk & Compliance
Committee and Board Audit Committee
respectively. Assisted by Odgers, the
Committee approved role profiles for
each of these positions with initial focus
on filling the Board Risk and Compliance
Committee Chair position. Following a
competitive selection process involving
both internal and external candidates,
Rick Gildea, an existing Board member,
was selected as the preferred candidate
for the Chair of the Board Risk and
Compliance Committee and appointed
to the role in October 2024. Mr Gildea’s
identification as preferred candidate
required the Committee to approve a
new role profile to fill the Independent-
Non-Executive Director position vacated
by Mr Courtney. Being mindful of the
Bank’s business model and strategic
priorities, it was agreed the Board could
be further strengthened through the
addition of a candidate with deep capital
markets and investor relations experience.
Assisted by Odgers, both internal and
external candidates were identified and
interviewed for the two remaining Board
positions, Audit Committee Chair and
Independent-Non-Executive Director.
Arising from the selection process, two
preferred candidates have been identified
who have fully met the requirements of
the respective role profiles
and, at the date of publication of this
Annual Report are at an advanced stage in
the approval and appointment process.
Note: 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.
Committee Composition
During 2024 the Committee undertook a
review of Committee composition in light
of planned changes to the Board and
the need to refresh the knowledge and
experience of the Board’s Committees
following the planned departures of Donal
Courtney in 2024 and Ronan O’Neill in
2025. The Board will carry out a further
review of committee composition upon
the appointment of two new Non-
Executive Directors.
Induction, Training and Professional
Development
The Board recognises the high calibre and
the varied level of knowledge, skills and
experience of the Board. The Committee
reviewed and enhanced the approach
to induction, training and professional
development of the Board members with
a view to aligning the Board skills with
the strategic direction and risk profile
of the Group thereby enhancing the
collective knowledge of the Board. It aims
to achieve this by prioritising training
topics around the risks and opportunities
from emerging themes, tailoring individual
training and development plans for
PTSB Group Holdings plc - Annual Report 2024
111
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Board members to enhance the core
skills identified following the Collective
Suitability Assessment by building on the
education and professional development
opportunities through externally facilitated
professional programmes. It will also seek
to deepen the Board’s knowledge of the
business through increased exposure to
subject-matter experts both internally and
externally through the Board approved
training programme. The Committee also
oversaw the comprehensive induction,
training and development plans for new
Board members and Executive Committee
appointments, in addition to induction and
handover arrangements for transition of
Committee chair roles to existing Board
members.
Board Performance Evaluations
In 2024, led by the Chairperson,
the Committee oversaw the annual
performance evaluation of the Board,
its Committees and individual Directors.
Enhancements have been made to the
process undertaken for the 2024 annual
Board performance evaluation reflecting
actions identified to enhance Board and
Board Committee effectiveness and the
resulting recommendations are set out
in page 93 of this report. In accordance
with the UK Corporate Governance Code,
the 2024 Board review was externally
facilitated by Korn Ferry.
Other Matters considered by the
Committee in 2024
• Review of the work undertaken
throughout the year to implement
actions identified to strengthen the
foundations, capabilities and build
resilience within the enlarged Group
following the acquisition of certain parts
of the Ulster Bank businesses.
• Review of its own performance and
effectiveness, including a review of its
Terms of Reference;
• Reviewed the Annual Gender Gap and
Gender Pay Gap Research Report;
• Approval of the recruitment process
and appointment of a number of Senior
Management positions;
• Review and oversight of the evolution
of the Group’s culture throughout the
year together with the approval of the
Culture Compendium (Charter);
• Review and approval of Board
Policies (Diversity, Conflict of Interest,
Assessment and Suitability, Induction,
Training and Professional Development,
Succession Planning);
• Review and approval of the Group’s
Fitness and Probity Policy;
• Review of updates to the Group’s
Speak Freely Procedure, and Protected
Disclosure Procedure;
• Review and approval of updates to the
Group Colleague and Conduct Policies
and Procedures including the Code of
Ethics Policy; Colleague Conduct Policy,
Conflict of Interest Policy, Colleague
Disciplinary Procedures, and IAF
Conduct Standards Policy;
• Review of Colleague Conduct related
activity within the Group;
• Review of the Board Training and
Professional Development Plan together
with oversight of the implementation
of individual Directors (including Board
Committee Chairs) handover/induction,
training and professional development
plans;
• Consideration of workforce engagement
mechanisms under the UK Code;
• Review of Diversity, Equity and
Inclusion, Learning and Talent, and
Employee Survey updates;
• Reviewed the enhanced Learning
& Development Programme and
Policy which improved the colleague
experience and learning outcomes with
strong focus on business skills training;
• Reviewed progress on the Group’s
Diversity, Equity and Inclusion and
Organisation Culture programmes of
work including the DEI Strategy for
the period 2023-2025 which focused
on an enduring model for continuous
improvement, aligned to the Irish Centre
for Diversity Gold Accreditation which
the Bank received in 2023;
• Reviewed and approved gender balance
aspirations for the Group;
• Review of Corporate Affairs, Reputation
Management and Communication
(including Stakeholder Engagement)
updates;
• Review of the Corporate Sponsorship
programmes (including reflection and
analysis); and
• Review and oversight of the
implementation of the Bank’s ‘Decision
Yes Checks’ to support decision-making
in the Bank.
Corporate Governance Statement
Nomination, Culture and Ethics Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
112
Dear Reader,
As Chairperson 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 2024.
While I have been a member of the
Committee since December 2023,
I was appointed as Chairperson in
October 2024. I would like to thank my
predecessor, Donal Courtney who retired
from the Board in October 2024 for his
valuable contribution over the past six
years during which time, the Committee
played a key role in supporting the
Board to manage risk during what was a
transformational time for the Bank. I would
also like to report on the appointment of
Catherine Moroney to the Committee in
December 2023 and who, during 2024
brought extensive business banking
and commercial credit experience to
the Committee. Catherine’s knowledge
and experience of different SME sectors
and her understanding of the potential
opportunities and challenges in the market
have greatly benefited the Committee in
what is a key growth area for the Bank.
A key area of focus for BRCC is the role of
the Committee in assisting and providing
assurance to the Board on the Bank’s
appetite for risk (Risk Appetite Statement
or RAS), capital and liquidity management
(ICAAP/ILAAP), Resolution and Recovery
Planning. In particular, the Committee has
ensured that these assessments inform
and underpin strategic decision making.
The Committee has overseen a
redeveloped RAS approach which has
provided greater integration of risk
appetite setting with the Bank’s key
risk assessment, planning and strategy
processes. The redeveloped RAS includes
measures for long-term Risk Appetite
Ambition as well as Risk Appetite and
seeks to articulate both the actual
and current risk position of the Bank.
In addition to this, over the past 12-18
months, the ICAAP and ILAAP have
evolved, with increased emphasis on the
Bank’s own view of risks as calculated by
The Committee supports the Board in ensuring
risks are properly identified, reported, assessed,
and controlled, and that the Bank’s strategy is
consistent with risk appetite.
Corporate Governance Statement
Risk and Compliance Committee
supported oversight on delivery of an
enhanced control environment through a
number of key initiatives. Key outcomes
are the embedding of a revised approach
to the Risk Control Self-Assessment
process including mapping of regulatory
regulations, development of a combined
assurance model with enhanced alignment
and collaboration across the three lines
of defence. Furthermore, there has been
roll out of first-line risk committees in
each functional area with cross functional
collaboration on risk management. While
positive progress has been made in
implementing the Central Bank Guidelines
on Operational Resilience and Outsourcing
and the Digital Operational Resilience Act
(DORA), maintaining the robust approach
to Operational Resilience and Third Party
Management will be a key focus in 2025.
During 2023, the Committee
supported the Board in overseeing
the risks associated with what was a
transformational transaction for the Bank
to acquire certain parts of the Ulster Bank
business from Nat West Bank; throughout
2024, the Committee maintained oversight
of the residual risks that remained to be
addressed post integration of the Ulster
Bank business. One example is how the
Committee oversaw the risks associated
with the newly acquired Asset Finance
business reviewing RWA calculation
approach, AML/CTF compliance and
conduct risk matters such as early
identification of the need to update
the unit’s discretionary commission
arrangements for Irish motor dealers.
I look forward to working with my fellow
committee members and continuing to
support the Board in 2025 with particular
focus on overseeing and managing the
risk associated with execution of the
Bank’s Integrated Strategic Plan.
Rick Gildea
Chairperson, Board Risk & Compliance
Committee
the Bank’s internal models (the Economic
perspective), which enhances how ICAAP
and ILAAP can input into decision making
on strategic planning and on optimising
use of the Bank’s capital resources.
The Committee is also focussed on
developing the appropriate quantitative
and qualitative Risk Appetite metrics for
Climate Related and Environmental Risk
and continues to be proactively involved
in monitoring how the Group delivers
its Climate Risk Strategy, ensuring it is
underpinned by a robust Data Strategy.
The Committee recognises the
importance of looking after the Bank’s
customers at all stages of their journey
with PTSB and welcomed the introduction
of the “Decision Yes Checks” as a key
element of the Committee’s decision-
making and approval process; these
assessments assisted in the making
of informed decisions, enabling
comprehensive consideration of potential
customer impact and ensuring fair
outcomes for customers which is a key
priority for the Bank. The Committee
also monitored the risk and incidence of
fraud both from the customer and Bank
perspective and has oversight on the
initiatives being undertaken to mitigate
these risks while acknowledging the
growth of fraud is a particular challenge
for all banks.
A key programme for the Bank during
2024 and continuing into 2025 was the
Bank’s Capital Models Programme which
seeks to achieve Regulatory approval
to utilise a suite of redeveloped Internal
Ratings Based (IRB) models underpinning
the Risk Weighted Asset calculation for
the Bank’s Capital (CET1). The Committee
provided support and challenge to
Management and is actively involved in
overseeing progress with this programme.
Advising and supporting the Board
in ensuring there is effective risk
management and risk governance
across the Group is a key priority for
the Committee. Following a period of
reflection and engagement with key
stakeholders in 2023, the Committee
PTSB Group Holdings plc - Annual Report 2024
113
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Responsibilities of the Committee
The Committee is responsible for
monitoring adherence to the 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 reviews
the regulatory agenda and receives
updates on activities to implement new
and updated regulation together with
monitoring engagement with the Group’s
Regulators.
The Committee is responsible for
oversight and advice to the Board on
risk governance, current risk exposures,
future risk strategy, including strategy for
capital and liquidity management, setting
of compliance policies and principles and
the embedding of a supportive culture in
relation to the management of risk and
compliance. BRCC supports the Board
in carrying out its responsibilities for
ensuring risks are properly identified,
reported, assessed and controlled, and
that the Group’s strategy is consistent
with the Group’s Risk Appetite. The
Committee 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 which provide assurance
that Management complies with relevant
laws and regulations regarding customers
and business partners. The Committee
remain focused with on its oversight
responsibilities for Anti-Money Laundering
and Counter-Terrorist Finance activities.
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 2024
During 2024, 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 2024 were:
• Operational Resilience and related
matters (Critical Business Services
reviews);
• Review of risk appetite to capture the
evolving impact of climate risk;
• Review of data strategy needed to
support evolution of the Bank’s climate
risk assessment and measurement;
• Review of Third Party Business Case
and Risk Assessments;
Composition and Operation
The BRCC is composed of a majority of Independent Non-Executive Directors. Neither
the Board Chairperson nor the CEO is a member of the BRCC. The Board ensures that
the Chairperson 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 Board Audit (Anne Bradley, Catherine Moroney, Rick Gildea) and the
Board Remuneration Committees (Rick Gildea). The Committee holds a member only
session at the start of each meeting following which the Committee invites the CRO for
a private session with the Committee if required. Thereafter other members of Senior
Management are invited to attend, as required.
2024 Committee Meeting Attendance
Member
Appointed
Ceased
Number of
Years on the
Committee
2024 Meeting
Attendance
Donal Courtney**
3 Oct 2018
1 Oct 2024
6.0
10/10
Catherine Moroney
12 Dec 2023
-
1.1
11/12
Rick Gildea*
12 Dec 2023
-
1.1
9/12
Marian Corcoran
29 Oct 2019
-
5.2
12/12
Paul Doddrell
26 Nov 2020
-
4.1
11/12
Anne Bradley
30 Mar 2021
-
3.8
11/12
*
Chairperson from October 2024
**
Chairperson until October 2024
Corporate Governance Statement
Risk and Compliance Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
114
• Review of Outsourcing Strategy and
Third Party Management Framework;
• Key divisional and business frameworks
under the Internal Control Framework;
• Review of OSII Prudential Compliance
Obligations;
• Review of IRRBB Strategy;
• Monitoring of conduct risk and
vulnerable customers;
• Reviews of the Bank’s Resolution
Planning work programme;
• Oversight for the remediation of SREP
related Risk Mitigation Plans;
• Spotlights on key product portfolios
(e.g. Home Loans, Asset Finance);
• Reporting on Compliance Monitoring
and Assurance;
• MLRO Reports (AML/CFT and Anti
Bribery and Corruption);
• Monitoring of upstream Regulatory
developments;
• Oversight and approval of the Bank’s
Non-Performing Asset Strategy;
• Recovery Planning Preparedness and
Scenario Planning;
• Spotlights on Fraud, Cyber Security and
Digital resilience;
• Climate and Environment Risk
Management;
• Complaints Framework and regular
updates on complaint levels/plans to
address;
• Reviews on Material Risk Events,
Customer Impacting Errors and Fraud;
• ICAAP and ILAAP approach, design
and recommendation of approval to the
Board;
• ICAAP and ILAAP utilisation in strategy
formulation and decision making;
• Reviews of the Bank’s provision models
and expected credit loss outcomes;
• Updates on embedding of the Bank’s
Risk and Control Self-Assessment
process;
• Addressing Risk Appetite breaches and
approving remediation plans;
• Operational and IT Risk Monitoring
Reports;
• Consideration of Data Protection
Officer’s Reporting;
• Reviews of obligations and activity
under the Central Bank of Ireland Code
on Lending to Related Parties;
• Recommending approval of the Bank’s
Internal Control Framework (to Board)
and approval of the Bank’s Enterprise
Risk Management Framework and key
divisional and business risk Frameworks
therein; and,
• Approval of the Bank’s Credit Risk
Framework.
Governance in Action: Payments
Issue November 2024
The importance of Operational Resilience
and Third-Party Management was brought
into sharp focus in November 2024, when
PTSB experienced a significant disruption
to SEPA payment processing due to a
hardware failure at a Citibank Third-
Party provider and a consequential issue
with PTSB’s Open 24 service causing
disruption for our customers during a
high-demand period. As part of its role in
overseeing Third Party Management and
Operational Resilience, throughout 2024
BRCC had assisted with the development
of a new Third-Party Management
Framework (providing guidance on the
Third-Party Management Lifecycle) and
supported key changes to the Bank’s
Third Party Management Policy, to reflect
enhanced internal governance and
oversight arrangements put in place and
to align with DORA requirements. The
Committee has and will continue to be
heavily involved in the process to ensure
that lessons are learned from these
incidents and will track actions taken to
mitigate the risk of re-occurrence.
PTSB Group Holdings plc - Annual Report 2024
115
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Dear Shareholder,
On behalf of the Remuneration
Committee, I am pleased to present the
Directors’ Remuneration Report for the
year ended 31 December 2024, 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
Bank’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 Regulations”,
or the “Regulations”), the UK Corporate
Governance Code (the “UK Code”) and
Irish Annex. For financial year 2025 the
Bank will also be subject to the Irish
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 Bank’s reward offering,
with a focus on the Bank’s Directors
(Executive and Non-Executive).
In 2024, the Committee continued
to oversee the way in which our
Remuneration policy, and its
implementation serve 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 how
we reward the delivery of the long-term
sustainability of our business by aligning
remuneration with the long-term interests
of shareholders, investors and other
interested parties, and with the public
interest, as well ensuring fulfilment of our
regulatory obligations.
Corporate Governance Statement
Remuneration Committee
In line with its responsibilities under
the terms of the Shareholder Rights
Regulations, 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. During 2024, our
Directors’ remuneration was implemented
in accordance with the approved Policy,
and no derogations from the Policy were
availed of during the year.
It remains the policy of the Bank to
reward our colleagues appropriately as
we work together to build a valuable and
sustainable business, operating within the
Bank’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.
Amendments to the restrictions on
variable pay present the opportunity
for PTSB to introduce an all-colleague,
Enterprise-wide Variable Pay Scheme
involving potential awards of up to
€19,999. Subject to consultation with
our Staff Representative Bodies, the
new scheme is intended to enable us to
reward colleagues at all levels, including
Senior Management for their contribution
to the achievement of our long-term
strategic goals, the sustainability of our
business and delivery for our customers.
The scheme design will take account
of the need to comply fully with all
appropriate regulation and legislation and
State Agreements on remuneration. The
structure of the scheme is intended to
ensure that the determination of variable
pay at the group and individual level will
link to the Bank’s financial and strategic
performance, encourage the embedding
of a culture of strong prudential and
conduct risk management and reward
colleagues appropriately for their
contribution.
Beyond the Variable Pay matters, 2024
was a year of considerable change for
PTSB, and one in which we sought to build
on the momentum gained as a result of
the expansion of our customer, product
and colleague base following the Ulster
Bank transaction.
In May 2024, following robust but
productive discussions with Staff
Representative Bodies, supported by
the Workplace Relations Conciliation
Services, the Bank reached agreement
with two of our three Union partners
on our 2024 annual Pay Review. That
review involved an average increase
of 4.7% for eligible colleagues, with
individual award increases of up to 5%
based on performance and relative salary
positioning. The Bank was unable to
secure agreement from our third Union
partner. At the date of writing, issues
relating to pay remain unresolved with the
Bank’s third Union and the Bank continues
to engage on these matters with the
intention of reaching a suitable outcome
as soon as possible.
As part of the Bank-wide review of 2024
pay, Mr Eamonn Crowley’s (CEO) salary
remained unchanged in order to comply
with State Agreements on remuneration,
and specifically the ‘Pay Cap’ which
restricts Executive Pay to €500,000
per annum. In 2024, Ms Nicola O’Brien
(CFO) received a base salary increase
of 4.5%. That increase was below the
average 4.7% payout across the wider
colleague population. The level of increase
was approved by the Committee based
on an assessment informed by the
use of independently sourced market
benchmarks for equivalent roles in
comparable organisations in the Republic
of Ireland. In the context of Executive Pay,
it is of note that the market information
used to inform pay decisions included
data relating to organisations which –
unlike the Bank - operated variable pay
arrangements. In August 2024, Ms O’Brien
announced her intention to resign as CFO.
Full details of Directors remuneration
The Board Remuneration Committee ensures that PTSB’s
remuneration policies, practices and decisions serve to align the
interests of its employees with those of its shareholders; operate within
the applicable regulatory and legal requirements; and, are free from
any form of bias relating to gender, age or social or ethnic background.
PTSB Group Holdings plc - Annual Report 2024
116
arrangements are provided over the
following pages.
The fee structure for Non-Executive
Directors remained unchanged in 2024.
The 2025 review for Non-Executive
Director fees has not yet concluded and
further details will be included within next
year’s report.
The Committee also approved
the implementation of a Voluntary
Redundancy scheme in line with the
terms of the Bank’s Remuneration Policy.
Initially involving members of our Senior
Management community, in December
2024 the scheme was subsequently
expanded to gauge the level of interest
amongst colleagues at all levels. The
scheme is one of a number of important
strategic business transformation change
initiatives designed to support our
strategy and to improve organisational
effectiveness and efficiency, and has
been designed in a manner which
provides optionality to colleagues who
after a period of significant change, may
now wish to seek opportunities outside
of PTSB. The window for receipt of
expressions of interest closed in January
2025 with management making decisions
on VSS recipients in February/March
2025, and colleague exits scheduled to
take place throughout the year.
Finally, throughout 2024, the Committee
was also involved in the overseeing
aspects of PTSB’s response to emerging
legislation that will impact how we
remunerate our colleagues and in
particular changes to Pay Transparency
legislation and the roll-out of Pension Auto
Enrolment, which will be known as “My
Future Fund” upon implementation. More
details will be provided in the 2025 Annual
Report.
On behalf of the Board Remuneration
Committee:
Celine Fitzgerald
Chair of the Remuneration Committee.
Annual Report on Remuneration - 2024
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 eight meetings during 2024.
2024 Committee Meeting Attendance
Member
Appointed
Ceased
Number of Full
Years on the
Committee
2024 Meeting
Attendance (of
which eligible to
attend)
Celine Fitzgerald
30-Mar-21
-
3.8
8/8
Julie O’Neill
01-Feb-23
-
1.0
8/8
Ruth Wandhöfer
01-Feb-19
-
5.9
8/8
Richard Gildea
12-Dec-23
-
1.1
6/8
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 Bank’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 2024.
The main roles and responsibilities of the
Committee include:
• Recommending the Bank’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
Bank’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
arrangements) in respect of the
Chairperson, 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 Bank.
Remuneration Committee Advisers
During 2024, 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 advisory services to the Bank in
the technology area as well as certain risk
related topics.
PTSB Group Holdings plc - Annual Report 2024
117
Strategic Report
Governance
Sustainability
Financial Statements
General Information
opened up to members of our Senior
Management. In December 2024, the
scheme was expanded to colleagues at
all levels and individual expressions of
interest will continue to be accepted up to
mid-January 2025.
During the year, the Committee also
maintained significant oversight to ensure
compliance with the UK Corporate
Governance Code and Irish Annex, CRD
V related regulations and guidelines,
including focusing 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.
The Committee also reviewed the
Bank’s established variable commission
scheme referred to as the ‘Branch Based
Commission Scheme’, as well as principles
and practices to ensure full alignment with
regulatory requirements. In particular, we
considered the requirements of 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 the basis
of this review, it was agreed to extend
the operation of the scheme for a further
year, subject to management maintaining
strong control over customer and conduct
management and robust governance of
scheme-related performance data.
The Committee also reviewed the design
of a new all-colleague, enterprise-wide
Variable Pay Scheme which is subject to
consultation with Staff Representative
Bodies. The scheme is intended to
incorporate appropriate metrics,
weightings and targets to assess the
Bank’s performance (including its ability to
pay variable remuneration) and individual
performance and also, risk adjustment
methodology including the use of
clawbacks.
The Remuneration Committee, supported
by management, continued to monitor
closely ongoing engagements with key
stakeholders including shareholders and
employee representative bodies and
the insights gained were used to inform
decision-making relating to remuneration
throughout 2024.
During 2024, the Committee also
employed the services of Willis
Towers Watson who provided market
benchmarking data and remuneration
trend analysis.
In addition to the use of external advice,
in designing its approach to remuneration
the Committee also takes account of
appropriate input from the Bank’s HR, Risk,
Compliance, Finance and Internal Audit
functions to ensure that the decision-
making process is aligned with the Bank’s
financial performance, risk appetite,
regulatory guidelines and stakeholder
interests.
Matters considered by the
Committee in 2024
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 2024, and within the terms of
State agreements, the Remuneration
Committee kept the impact of the
Bank’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 Bank’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 Bank’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
Chairperson, 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
Bank took place with the Bank’s Staff
Representative Bodies during 2024.
It remains the policy of the Bank to
reward our colleagues appropriately as
we work together to build a valuable and
sustainable business, operating within the
Bank’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 to ensure that the Bank’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 2024, the Committee reviewed the
Bank’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 2024 was the fifth year in which
the Bank published details of its gender
pay gap; and the third year in which the
Bank reported in line with Irish legislation
introduced in 2022. The Bank’s gender
pay gap stood at 16.9% at our chosen
snapshot date of 30th June 2024, which
represented an increase in the gap of
16.3% reported in 2023. The gap persists
primarily as a result of a gender imbalance
at senior levels and we continue to design
and implement strategies designed to
eliminate the gap over time. Further
details of the gap and our commitment
to reducing same are provided in the
separate section of the Bank’s Annual
Report which details the Bank’s Diversity,
Equality and Inclusion strategy.
In May 2024, following robust but
productive discussions with Staff
Representative Bodies, supported by
the Workplace Relations Conciliation
Services, the Bank reached agreement
with two of our three Union partners
on our 2024 annual Pay Review. That
review involved an average increase
of 4.7% for eligible colleagues, with
individual award increases of up to 5%
based on performance and relative salary
positioning. At the date of writing, issues
relating to pay remain unresolved with the
Bank’s third Union and the Bank continues
to keep these matters under review
with the intention of reaching a suitable
outcome as soon as possible.
In 2024, the Bank also launched a
Voluntary Redundancy scheme in line
with the terms of the Bank’s Remuneration
Policy. That scheme was initially
Corporate Governance Statement
Remuneration Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
118
The Bank’s Directors’ Remuneration Policy
was approved by our shareholders on
an advisory basis at our 2024 AGM. The
Committee is satisfied that in 2024 the
Bank 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 Bank, 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, the Committee is satisfied
that the Bank is in compliance with the
provisions of the Companies Act 2014,
the, UK Corporate Governance Code and
Irish Annex and the Shareholder Rights
Regulations. With specific reference to
the UK Code, the table below sets out
how the Remuneration Committee has
addressed the principles set out in the UK
Code. Additional regulatory disclosures
in relation to Remuneration Policy and
strategy are set out in the Bank’s Pillar 3
Report.
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.
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 Bank 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 Bank’s
website www.permanenttsbgroup.ie.
Further details on the engagement model in place with Representative Bodies
is included in the Workforce Engagement Section of the Corporate Governance
Statement that forms part of this report.
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.
Linked to certain agreements and commitments in place with the Irish State,
the Bank 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 was limited.
However, the simplicity of our approach enhances its predictability.
Our future approach to variable remuneration will involve a review of 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 providing the Remuneration Committee with discretion over remuneration
outcomes.
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.
Remuneration arrangements are designed to align pay with the Bank’s risk culture,
attitude to and appetite for risk and our governance and regulatory framework.
The launch of future variable remuneration schemes will factor in robust linkages
between pay and performance with controls to be put in place to ensure variable
pay outcomes are appropriate, including the use of risk adjustments as appropriate.
The Committee will be assigned the discretion to adjust formulaic outcomes for
Executive Directors and members of the Executive Committee to ensure appropriate
consideration of risk factors when determining variable pay outcomes.
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.
While the Bank 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.
In future years, where variable remuneration is likely to form a component of our
reward proposition, the Committee will have the ability to adjust formulaic outcomes
to ensure they remain proportionate in the context of the Bank’s achievement of its
financial or non-financial performance objectives and to promote the achievement
of our long-term strategic ambitions while driving behaviours consistent with
our purpose, values and strategy including our commitment to our Sustainability
agenda.
PTSB Group Holdings plc - Annual Report 2024
119
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Components of Executive Director
Remuneration - 2024
Basic salary
As in previous years, pay increases to
eligible staff in our wider workforce were
based on each individual staff member’s
performance and salary position versus
the relevant market median. The increases
ranged from 0% up to 5% with an average
increase of 4.7% and all increases were
effective from 1 January 2024. As part
of the 2024 review of pay arrangements,
the CEO’s salary remained unchanged in
order to comply with State Agreements
on remuneration, while the CFO received
a 4.5% base pay increase, with the size of
that increase influenced by the results of
a comprehensive market benchmarking
exercise. In the context of Executive Pay,
it is of note that the market information
used to inform pay decisions included
data relating to organisations which
– unlike the Bank - operated variable
pay arrangements The fee structure
for Non-Executive Directors remained
unchanged in 2024. The 2025 review
for Non-Executive Director fees has not
yet concluded and further details of that
review will be included within next year’s
report.
Pensions
The current Executive Directors
are members of the PTSB Defined
Contribution Pension Scheme. During
2024, the Bank contributed up to 20% of
basic salary in the case of the CEO and
16% in the case of the CFO.
For context: 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. While the CFO has
been aligned to this maximum, given the
particular challenges faced in attracting
and recruiting the most senior talent, in
2022, the Board approved an exceptional
maximum pension contribution of 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 was also agreed
to exempt the Executive Directors,
including the CEO, from the age-related
eligibility criteria.
Other than basic salary, there are no other
elements of Director’s remuneration which
are pensionable.
Benefits
During 2024, Executive Directors received
benefits in line with the 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
No bonus schemes were in place for
Executive Directors and no bonus
payments were made to Executive
Directors during 2024 or 2023. Neither
were there any long-term incentive
arrangements in place for Executive
Directors in 2024 or 2023.
In 2024, the Remuneration Committee
and the Board reviewed the design of a
new Variable Pay Scheme. All variable
remuneration arrangements will be
designed in a way that promotes the
interests of our stakeholders and fully
complies with applicable regulatory
requirements and State Agreements on
remuneration. The Variable Pay Scheme
will be based on company and individual
performance. For Executive Directors,
future variable awards will be based on
a performance period of one financial
year. Awards will be assessed with
reference to both financial and non-
financial performance metrics. Awards
will be payable following the end of the
performance period in cash or – where
practical – in shares or a combination
of shares and cash. The Remuneration
Committee will hold the discretion to
review the level of awards and adjust the
formulaic outcomes, including down to
zero, to take account of risk adjustments
where appropriate. Variable Pay awards
will be subject to malus and clawback
(where applicable).
Further information on our future
approach to variable pay will be provided
in the 2025 annual report and accounts.
Share option schemes
No share options were granted in 2024
or 2023. 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.
PTSB is reviewing options to implement an
Approved Profit Sharing Scheme as part
of its plans to implement a new Variable
Pay scheme and more details will be
disclosed in a future annual report.
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.
Ms. O’Brien stepped down from the
Board effective 28th August 2024,
and remained in receipt of her salary,
benefits and pension until 28th February
2025, in line with the six month notice
period as agreed in the 2023 Director’s
Remuneration Policy. The amounts she
received for the period 29th August 2024
to 28th February 2025 are as follows:
Salary:
€209,000
Benefits:
€10,000
Pensions:
€33,440
Total Loss of Office
Payments due:
€252,440
Corporate Governance Statement
Remuneration Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
120
Payments to Former Directors
Other than in respect of the Loss of Office
payments described above, no such
payments were made to former Executive
Directors during 2024.
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.
Directors’ Remuneration Policy
In this section, we set out our Directors’
Remuneration Policy (“Policy”) for
our Executive Directors and Non-
Executive Directors as reviewed by the
Remuneration Committee and approved
by the Board of Directors.
The Directors’ Remuneration Policy
was most recently approved by our
shareholders at the 2024 AGM and
incorporated certain amendments to the
Policy to support the launch of a Variable
Pay scheme at an appropriate future
date, and subject to consultation with our
Staff Representative Bodies. The current
version of policy is intended to apply until
the AGM in 2027. However, we may seek
shareholders’ approval for a new Policy
during the period depending on regulatory
developments, changes to our strategy or
competitive pressures.
The Policy is published in full on the Bank’s
website: www.permanenttsbgroup.ie and
is outlined in full below.
The Policy, in alignment with the
Remuneration Policy applicable across
the Bank, is based on a set of agreed
basic principles which are applied to all
employees:
• Aligning remuneration with the
Bank’s risk appetite, approaches and
governance framework;
• Ensuring our approach is in compliance
with all applicable regulatory
requirements;
• Aligning remuneration with our business
strategy, objectives, purpose and
values, and promoting the achievement
of long-term Bank and stakeholder
objectives and interests;
• Focusing on the attraction, engagement
and retention of key talent of the calibre
required;
• Ensuring that our Policy and each
element of Directors’ remuneration is
as transparent, simple and clear as is
possible.
Remuneration Components
Executive Director Remuneration:
The following are the key components of the Bank’s reward proposition as it relates to the Executive Directors:
Remuneration
Component
Remuneration 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 Bank’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 employment conditions of colleagues elsewhere in the Group;
• overall business performance and affordability; and
• market competitiveness by reference to relevant comparator groups.
Increases to basic salary may not necessarily be provided at each review. Whilst there is no maximum base
salary (other than that specified by the terms of State Agreements), 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 (or cash allowance in lieu) and subsidised
house purchase loans provided on the same terms and conditions as loans to other eligible PTSB
employees.
Taxable or other expenses incurred in performing the role may also be reimbursed, as well as any related
tax cost on such reimbursement.
PTSB Group Holdings plc - Annual Report 2024
121
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Corporate Governance Statement
Remuneration Committee (continued)
Remuneration
Component
Remuneration Policy
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 generally consistent across the Bank.
However, in recognition of the remuneration restrictions remaining 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.
Short Term
Incentive Plans
In 2023, the Remuneration Committee approved changes to the remuneration policy to support the
introduction of variable remuneration at an appropriate future date.
Variable pay subject to the criteria included in the remuneration policy will help support the further
development of PTSB’s high performance culture and will do so in way that promotes sustainable
outcomes for our stakeholders. The scheme criteria will support full compliance with applicable regulatory
requirements and State Agreements on remuneration.
A maximum limit of €20,000 per annum on any award or combination of awards per individual colleague
will apply.
For Executive Directors, awards will be based on a performance period of one financial year. Awards will be
assessed with reference to a suite of financial and non-financial performance metrics and will be paid in
cash, shares (where practical) or a combination of both.
Variable pay awards will be subject to malus and clawback (i.e., repayment or recoupment of paid/
vested awards) for a period of three years from the date of award. Malus and clawback may be applied in
circumstances including:
• Evidence of misconduct or serious error by the individual (e.g., breach of conduct standards and other
internal rules, especially concerning risks);
• Whether PTSB and/or the business unit subsequently suffers a significant downturn in its financial
performance;
• Whether PTSB and/or the business unit in which the identified staff member works suffers a significant
failure of risk management;
• Significant increases in PTSB’s or the business unit’s economic or regulatory capital base; or
• Any regulatory sanctions where the conduct of the individual contributed to the sanction.
Also, if the individual:
• i. Participated in or was responsible for conduct which resulted in significant losses to PTSB; or
• ii. Failed to meet appropriate standards of fitness and propriety;
PTSB intends to implement an APSS to facilitate the delivery of shares under the scheme.
PTSB Group Holdings plc - Annual Report 2024
122
Recruitment approach for new
Executive Directors
In determining the remuneration
arrangements of a new Executive Director
recruited or appointed to the Board, the
Remuneration Committee’s approach is to
pay no more than is necessary to attract
the best candidates to the role, and the
following principles will be applied:
• The Remuneration Committee will
take into account all relevant factors
including the calibre of the individual
and local market practice;
• Remuneration packages must meet
any applicable local regulatory
requirements;
• Remuneration arrangements for
new recruits will be appropriately
competitive and aligned with the
remuneration policy table set out above;
and
• In the case of an internal appointment,
any existing commitments will be
honoured.
• The Policy does not, other than
by exception, allow for buy-out of
remuneration terms forfeited by new
recruits on leaving a previous employer.
Any such award would be structured
in line with applicable regulatory
requirements, be subject to the terms
of agreements in place with the Minister
for Finance and will be structured in
order that the terms and amount of any
replacement award will not be more
generous than the award forfeited on
departure from the former employer.
Any such buy-outs will be minimised
wherever possible.
Non-Executive Director
Remuneration
Non-Executive members of the Board of
Directors receive a base fee. Additional
fees may be paid for those individuals
that perform additional duties; including,
but not limited to, the role of Senior
Independent Director and for chairing
or being a member of specific Board
Committees. The Chairperson receives an
inclusive fee for the role.
Taxable or other expenses incurred
in performing the role may also be
reimbursed, as well as any related tax cost
on such reimbursement.
The Chairperson’s and Non-Executive
Directors’ fees are reviewed regularly to
ensure they are consistent with market
practice and are market competitive,
reflective of the time commitment and
responsibilities of the role (subject to any
limits set by the Bank’s shareholders).
The Remuneration Committee
recommends the Chairperson’s fee to
the Board for approval. In respect of the
review of remuneration decisions relating
to Non-Executive Directors, a forum
consisting of the Chairperson, Company
Secretary and CEO has been authorised
by the Board to review Non-Executive
Director remuneration and to approve any
changes thereto. No individual is involved
in decisions in respect of their own
remuneration.
Newly appointed Non-Executive Directors
are remunerated in line with the principles
above, on a time-apportioned basis in the
first year as necessary.
For the avoidance of doubt, Non-
Executive Board members are not eligible
to participate in variable remuneration
schemes or receive any pension benefits.
Buy-out awards are not offered to Non-
Executive Board members.
Relative proportion of fixed and
variable remuneration
PTSB does not currently operate any
variable remuneration arrangements for its
Executive Directors. Remuneration for this
population is therefore presently entirely
fixed in nature.
In line with the amendments to the State
Agreement, the Committee has decided
to introduce the ability to pay variable
pay to our Executive Directors to enable
us to provide an element of pay for
performance within our overall reward
framework, albeit on a very limited basis.
Any awards paid will be in line with the
framework agreement between the
Minister for Finance and the Bank, which
currently permits annual bonuses in any
12-month period not exceeding €20,000
in the aggregate per individual.
Service contracts and letters of
appointment and payments for loss
of office
Executive Directors
Executive Directors’ service contracts are
reviewed by the Remuneration Committee
and approved by the Board.
Executive Directors’ contracts provide
for a rolling 6 month notice period for all
Executive Director Board appointments
since 2020. The contractual arrangements
in place with Executive Directors do not
typically contain a predetermined contract
end date, other than that date as set with
reference to the Bank’s retirement policy
age criterion (i.e., age 65). The Bank
reserves the right to require an Executive
Director to take any remaining leave
entitlement they may have during notice
period.
Executive Directors may be required to
work during the notice period, take a period
of ‘garden leave’ or may be provided with
pay in lieu of notice if not required to work
the full notice period.
Executive Director contracts will not
normally contain any provisions for
predetermined compensation on
termination which exceeds basic salary,
pension and benefits payable in respect of
the applicable notice period. Accrued but
untaken holiday entitlement may also be
paid. Any statutory requirements will be
observed.
If an Executive Director ceases employment
due to ill-health, retirement or death, the
individual or his/her estate may be eligible
for a payment under the scheme. The
HR Director may approve any payments
pro-rated for the period worked by the
individual, provided it is aligned with
performance during that time and subject
RemCo oversight. Any payment made in
these circumstances will only be paid on
the date on which a payment becomes
due under the rules of the scheme, apart
from the death of the employee when a
payment to the estate of the deceased
employee may be made earlier, subject to
the assessment of performance.
If an Executive Director ceases employment
for any other reason, the default position
is that the individual is not eligible for a
payment under the scheme. However, in
exceptional circumstances, the HR Director
may approve a payment pro-rated for the
period worked by the individual, provided
it is aligned with performance during that
time and subject to RemCo oversight. Any
payment made in these circumstances
will only be paid on the date on which a
payment ordinarily becomes due under the
rules of the scheme.
Any payments in relation to termination of
employment are made in accordance with
the provisions of all applicable regulatory
requirements and Irish legislation and will
reflect performance achieved over time and
will not reward failure or misconduct.
PTSB Group Holdings plc - Annual Report 2024
123
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Non-Executive Directors
The term of appointment of Non-
Executive Directors is three years and
is subject to satisfactory performance
that is reviewed annually. Non-executive
Directors do not have service contracts,
but are bound by letters of appointment.
All Directors are required to seek
reappointment by election at the
Annual General Meeting. 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 further period but this discretion
will only be exercised in exceptional
circumstances.
The Chairperson is proposed for
reappointment by the Directors on an
annual basis. The term of office of the
Chairperson is normally six years.
The Non-Executive Directors’ letter of
appointment specify a one-month notice
period. There are no additional obligations
in the Non-Executive Directors’ letters
of appointment that could give rise to
remuneration payments or payments for
loss of office.
Statement of consideration of
employment conditions elsewhere
in the Bank
The Committee takes account of the pay
and employment conditions of the wider
PTSB employee base when it considers
the remuneration of the Executive
Directors. As stated above, the Policy is
in alignment with the Remuneration Policy
applicable across the Group and which
is made available to all staff members
on the Group’s internal communications
website, and is based on a set of agreed
basic principles which are applied to all
employees.
In determining remuneration arrangements
for the Executive Directors, the Committee
is presented with information in relation to
the remuneration of the wider workforce,
including aggregate pay outcomes in
order to ensure decisions are made in the
context of a detailed understanding of
remuneration for the wider employee base
and to ensure consistency throughout the
Group.
Decision-making process for
Policy determination, review and
implementation
The Board of Directors is responsible for
(i) designing the Directors’ Remuneration
Policy and proposing the Policy for
shareholder approval at the Annual
General Meeting; and (ii) implementing
and evaluating the adopted Policy,
including determining the remuneration
and other terms and conditions of
appointment of the Executive Directors.
The Remuneration Committee is
responsible for annually reviewing
the Policy and submitting a clear and
understandable proposal to the Board
concerning the Policy. In the performance
of this task the Remuneration Committee
receives input and support from the other
Board committees and control functions
as appropriate.
Non-Executive members of the Board act
independently of the Executive Directors,
and therefore no conflicts of interest
should arise. No Director is involved in
deciding their own remuneration outcome.
Derogation
Minor changes
The Board may make minor amendments
to the Directors’ Remuneration Policy
set out above for regulatory, exchange
control, tax or administrative purposes or
to take account of a change in legislation
without obtaining shareholder approval
for that amendment. In the performance
of this task the Committee may receive
input and support from the other Board
committees.
Exceptional circumstances
In exceptional circumstances, and to
facilitate recruitment and termination, the
Committee may, with approval from the
Board, award minor additional benefits
as appropriate. Any such award would
be structured in line with applicable
regulatory requirements, and be subject to
the terms of agreements in place with the
Minister for Finance. Any such awards will
be minimised wherever possible.
Grandfathering
Executive Directors may be eligible
to receive any payments from any
remuneration arrangements in effect
prior to the approval of this Remuneration
Policy. Details of any such payments
will be set out in the applicable annual
remuneration report as they arise.
Corporate Governance Statement
Remuneration Committee (continued)
PTSB Group Holdings plc - Annual Report 2024
124
Executive Directors’ Remuneration and Pension Benefits
Directors’ remuneration for 2024 was implemented in accordance with the Bank’s Directors’ Remuneration Policy, as approved by
shareholders at the 2024 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.
In line with certain agreements and commitments in place with the Irish State, during 2024 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 2023 or 2024.
It is the policy of the Bank that any future bonus schemes and long term incentive 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. However, there were no such payments relating to the 2024 financial year.
Executive Directors’ Remuneration and Pension Benefits
2024 remuneration for Executive Directors who held office for any part of the 2024 financial year was entirely fixed in nature,
consisting of basic salary, certain benefits and defined contribution pension entitlements as follows:
Name of Executive
Director, Position
2024
1.
Fixed Remuneration
2.
Variable
Remuneration
3.
Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
Note
Base
Salary
Fees
Fringe
Benefits
Loss of
Office
Payments
One-
year
variable
Multi-
year
variable
Eamonn Crowley,
CEO
1 €480,000
€0
€20,000
€0
€0
€0
€0
€96,000
€596,000
100% Fixed
Nicola O’Brien,
CFO
2 €275,296
€0
€13,497 €172,365
€0
€0
€0
€44,047
€505,205
100% Fixed
Notes:
1.
Fringe Benefits consist of Car Allowance Benefit.
2.
On the 28th of August 2024, Ms. O’Brien announced her intention to resign her role. She stepped down from the Board effective 29th August 2024 and will
remain in receipt of her salary, benefit and pension until February 2025. The remuneration disclosed above includes Loss of Office Payments related to Ms.
O’Brien’s employment as CFO and relates only to that period as an Executive Director. Fringe Benefits consist of Car Allowance and Benefit in Kind relating to the
payment of professional body subscriptions.
For comparison, 2023 Remuneration for Executive Directors who held office for any part of the 2023 financial year was entirely fixed
in nature, consisting of basic salary, certain benefits and defined contribution pension entitlements as follows:
Name of Executive
Director, Position
2023
1.
Fixed Remuneration
2.
Variable Remuneration
3.
Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
Note
Base Salary
Fees
Fringe
Benefits
One-year
variable
Multi-year
variable
Eamonn Crowley,
CEO
1
€480,000
€0
€20,000
€0
€0
€0
€96,000
€596,000
100% Fixed
Nicola O’Brien,
CFO
2
€400,000
€0
€20,892
€0
€0
€0
€61,667
€482,559
100% Fixed
Notes:
1.
Fringe Benefits consist of Car Allowance Benefit.
2.
Fringe Benefits consist of Car Allowance and Benefit in Kind relating to the payment of professional body subscriptions.
Aggregate Executive Director Compensation stood at €928,840 in 2024 compared to €1,078,559 in 2023.
No Executive Director was in receipt of any remuneration from any undertaking within the Group other than PTSB Group Holdings plc.
Director’s Report on Remuneration
PTSB Group Holdings plc - Annual Report 2024
125
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Non-Executive Director Remuneration
The basic fee structure in place for the Chairperson and Non-Executive Directors in 2024 remained unchanged versus the prior year
and is outlined in the table below.
Aggregate fees paid to Non-Executive Directors decreased from €1,061,840 (2023) to €1,038,445 in 2024.
2024
Name of
Director,
Position
Note
1.
Fixed Remuneration
2.
Variable
Remuneration
3.
Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
Base
Salary
Basic Fees
Fees Paid
Fringe
Benefits
One-
year
variable
Multi-
year
variable
Julie O’Neill
1
€0 €320,000 €320,000
€420
€0
€0
€0
€0
€320,420
100% Fixed
Ronan O’Neill
2
€0
€60,000 €115,000
€375
€0
€0
€0
€0
€115,375
100% Fixed
Donal
Courtney
3
€0
€60,000
€72,070
€590
€0
€0
€0
€0
€72,660
100% Fixed
Ruth
Wandhofer
4
€0
€60,000
€73,750
€110
€0
€0
€0
€0
€73,860
100% Fixed
Marian
Corcoran
5
€0
€60,000
€73,750
€465
€0
€0
€0
€0
€74,215
100% Fixed
Paul Doddrell
6
€0
€60,000
€73,750
€543
€0
€0
€0
€0
€74,293
100% Fixed
Celine
Fitzgerald
7
€0
€60,000
€76,500
€465
€0
€0
€0
€0
€76,965
100% Fixed
Anne Bradley
8
€0
€60,000
€76,500
€110
€0
€0
€0
€0
€76,610
100% Fixed
Catherine
Moroney
9
€0
€60,000
€76,500
€0
€0
€0
€0
€0
€76,500
100% Fixed
Richard
Gildea
10
€0
€60,000
€80,625
€0
€0
€0
€0
€0
€80,625
100% Fixed
Notes:
1.
Ms O’Neill was appointed as a member of the Board on 17 January 2023 and on the 1 February 2023 became a member of the Remuneration Committee and
Board Nomination, Culture and Ethics Committee. She does not receive additional fees in these roles. Ms O’Neill was appointed as Board Chairperson on 31
March 2023. Fringe benefits comprise Benefit in Kind relating to the payment of professional body subscriptions and expenses.
2.
Additional fees paid as Chairperson of the Board Audit Committee, member of the Board Nomination, Culture and Ethics Committee and Senior Independent
Director. Fringe benefits comprise Benefit in Kind relating to the payment of professional body subscriptions.
3.
Ceased as Non-Executive Director on 1 October 2024. Additional fees paid as Chairperson of the Board Risk and Compliance Committee, and member of Board
Audit Committee. Fringe benefits comprise Benefit in Kind relating to the payment of professional body subscriptions.
4.
Additional fees paid as member of the Board Audit Committee and the Remuneration Committee. Fringe benefits comprise Benefit in Kind relating to the
payment of professional body subscriptions.
5.
Additional fees paid as member of the Board Risk and Compliance Committee and the Board Nomination, Culture and Ethics Committee. Fringe benefits
comprise Benefit in Kind relating to the payment of professional body subscriptions.
6.
Additional fees paid as member of the Board Risk and Compliance Committee and the Board Nomination, Culture and Ethics Committee. Fringe benefits
comprise Benefit in Kind relating to the payment of professional body subscriptions and expenses.
7.
Additional fees paid as Chair of the Remuneration Committee and member of the Nomination, Culture and Ethics Committee. Fringe benefits comprise of Benefit
in Kind relating to the payment of professional body subscriptions.
8.
Additional fees paid as member of the Board Audit Committee and Board Risk and Compliance Committee. Fringe benefits comprise of Benefit in Kind relating
to the payment of professional body subscriptions.
9.
Additional Fees paid as member of the Board Risk and Compliance Committee and the Board Audit Committee.
10. Additional Fees paid as Chair of the Board Risk and Compliance Committee and member of the Remuneration and Board Audit Committees.
Director’s Report on Remuneration
(continued)
PTSB Group Holdings plc - Annual Report 2024
126
Non-Executive Director Remuneration
For comparison, the level of fees paid to the Chairperson and Non-Executive Directors in 2023 is outlined in the table below.
2023
Name of
Director,
Position
Note
1.
Fixed Remuneration
2.
Variable
Remuneration
3.
Extraordinary
items
4.
Pension
Expense
5.
Total
Remuneration
6.
Proportion
of Fixed and
Variable
Remuneration
Base
Salary
Basic Fees
Fees Paid
Fringe
Benefits
One-
year
variable
Multi-
year
variable
Robert Elliott
1
€0 €320,000
€80,000
€0
€0
€0
€0
€0
€80,000
100% Fixed
Julie O’Neill
2
€0 €320,000 €256,275
€11
€0
€0
€0
€0
€256,286
100% Fixed
Ken Slattery
3
€0
€60,000
€72,593
€375
€0
€0
€0
€0
€72,968
100% Fixed
Andrew Power
4
€0
€60,000
€28,350
€0
€0
€0
€0
€0
€28,350
100% Fixed
Ronan O’Neill
5
€0
€60,000 €121,187
€375
€0
€0
€0
€0
€121,562
100% Fixed
Donal
Courtney
6
€0
€60,000 €101,938
€90
€0
€0
€0
€0
€102,028
100% Fixed
Ruth
Wandhofer
7
€0
€60,000
€73,750
€445
€0
€0
€0
€0
€74,195
100% Fixed
Marian
Corcoran
8
€0
€60,000
€79,937
€445
€0
€0
€0
€0
€80,382
100% Fixed
Paul Doddrell
9
€0
€60,000
€82,688
€445
€0
€0
€0
€0
€83,133
100% Fixed
Celine
Fitzgerald
10
€0
€60,000
€71,281
€445
€0
€0
€0
€0
€71,726
100% Fixed
Anne Bradley
11
€0
€60,000
€82,688
€445
€0
€0
€0
€0
€83,133
100% Fixed
Catherine
Moroney
12
€0
€60,000
€4,113
€0
€0
€0
€0
€0
€4,113
100% Fixed
Richard Gildea
13
€0
€60,000
€3,965
€0
€0
€0
€0
€0
€3,965
100% Fixed
Notes:
1.
Mr Elliott resigned from the Board on 30 March 2023.
2.
Ms O’Neill was appointed as a member of the Board on 17 January 2023 and on the 1 February 2023 became a member of the Remuneration Committee, Board
Nomination, Culture and Ethics Committee and Project Sun (Ulster Bank transaction) Oversight Committee. Ms O’Neill was appointed as Board Chairperson on
31 March 2023. Fringe benefits relate to the payment of expenses.
3.
Additional fees paid as Chairperson of the Remuneration Committee, and member of the Nomination, Culture and Ethics Committee. Fringe benefits comprise
Benefit in Kind relating to the payment of professional body subscriptions. Mr Slattery resigned from the Board on 12 December 2023.
4.
Additional fees paid as member of the Board Audit Committee and member of the Remuneration Committee. Mr Power resigned from the Board on 19 May
2023.
5.
Additional fees paid as Chairperson of the Board Audit Committee, member of the Board Nomination, Culture and Ethics Committee, Project Sun Oversight
Committee and Senior Independent Director. Fringe benefits comprise Benefit in Kind relating to the payment of professional body subscriptions.
6.
Additional fees paid as Chairperson of the Board Risk and Compliance Committee, and member of Board Audit Committee and the Project Sun Oversight
Committee. Fringe benefits comprise Benefit in Kind 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 the Remuneration Committee. Fringe benefits
comprise Benefit in Kind relating to the payment of professional body subscriptions.
8.
Additional fees paid as member of the Board Risk and Compliance Committee, the Board Nomination, Culture and Ethics Committee and Project Sun Oversight
Committee. Fringe benefits comprise Benefit in Kind relating to the payment of professional body subscriptions.
9.
Additional Fees paid as member of the Board Risk and Compliance Committee, Project Sun Oversight Committee and the Board Audit Committee. Fringe
benefits comprise Benefit in Kind relating to the payment of professional body subscriptions.
10. Additional fees paid as member of the Remuneration Committee and Nomination, Culture and Ethics Committee. Fringe benefits comprise of Benefit in Kind
relating to the payment of professional body subscriptions.
11. Additional fees paid as member of the Board Audit Committee, Project Sun Oversight Committee and Board Risk and Compliance Committees. Fringe benefits
comprise Benefit in Kind relating to the payment of professional body subscriptions.
12. Additional Fees paid as member of the Board Risk and Compliance Committee and the Board Audit Committee. Ms Moroney was appointed to the Board on 12
December 2023.
13. Additional Fees paid as member of the Board Risk and Compliance Committee and the Remuneration Committee. Mr Gildea was appointed to the Board on 12
December 2023.
PTSB Group Holdings plc - Annual Report 2024
127
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The table below outlines the level of fees paid to the Chairperson and Non-Executive Directors, including base fees and further fees
for additional Board duties such as chairpersonship or membership of a committee. The fee structure remained unchanged in 2024.
The 2025 review for Non-Executive Director fees has not yet concluded and further details of the outcome of this review will be
included within next year’s report.
Position:
2023 Fees
2024 Fees
Board Chairperson
€320,000
€320,000
Non-Executive Director (Base Fee)
€60,000
€60,000
Senior Independent Director
€22,000
€22,000
Board Audit Committee and Board Risk & Compliance Committee
Chairperson
€27,500
€27,500
Member
€8,250
€8,250
Remuneration Committee
Chairperson
€11,000
€11,000
Remuneration Committee and Nomination, Culture & Ethics Committee
Member
€5,500
€5,500
Project Sun (Ulster Bank Transaction) Oversight Committee (Committee was dissolved
on 30/09/2023)
Member
€8,250
N/A
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 2019 and 2024.
Changes in Remuneration
Note
Percentage
change
between 2019
and 2020
Percentage
change
between 2020
and 2021
Percentage
change
between 2021
and 2022
Percentage
change
between 2022
and 2023
Percentage
change
between 2023
and 2024
Directors’ Remuneration – Executive
Directors
Eamonn Crowley, CEO
1
6.60%
5.10%
0.00%
4.20%
0.00%
Nicola O’Brien, CFO
2
N/A
N/A
N/A
12.70%
4.7%
Michael Frawley, CRO
3
0.7%
0.00%
0.00%
N/A
N/A
Directors’ Remuneration – Non-
Executive Directors (NEDs)
Robert Elliot, Chairperson
4
0.00%
0.00%
5.20%
0.00%
N/A
Julie O’Neill, Chairperson
5
N/A
N/A
N/A
N/A
23.0%
Ken Slattery, Independent NED
6
4.6%
2.30%
1.70%
4.10%
N/A
Andrew Power, Independent NED
7
0.00%
0.00%
4.90%
4.70%
N/A
Ronan O’Neill, Independent NED
8
6.50%
21.30%
7.60%
2.90%
-5.1%
Donal Courtney, Independent NED
9
0.00%
1.10%
6.60%
2.70%
-5.6%
Ruth Wandhofer, Independent NED
10
0.00%
0.60%
4.20%
4.70%
-0.5%
Marian Corcoran, NED
11
0.00%
7.00%
8.90%
2.00%
-7.7%
Paul Doddrell, NED
12
N/A
1.80%
14.20%
2.10%
-10.6%
Celine Fitzgerald, Independent NED
13
N/A
N/A
4.10%
5.70%
7.3%
Anne Bradley, Independent NED
14
N/A
N/A
6.50%
2.70%
-7.8%
Catherine Moroney, Independent NED
15
N/A
N/A
N/A
N/A
0.0%
Richard Gildea, Independent NED
16
N/A
N/A
N/A
N/A
9.3%
Director’s Report on Remuneration
(continued)
PTSB Group Holdings plc - Annual Report 2024
128
Changes in Remuneration
Note
Percentage
change
between 2019
and 2020
Percentage
change
between 2020
and 2021
Percentage
change
between 2021
and 2022
Percentage
change
between 2022
and 2023
Percentage
change
between 2023
and 2024
Average remuneration on full-time
equivalent basis
Employees of the company
17
2.60%
1.70%
-0.80%
2.80%
3.0%
Underlying profit/loss
18
(€109m)
€17m
€45m
€166m
€180m
Adjusted Cost to Income Ratio
19
75%
82%
83%
64%
74%
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. The
increase in 2023 results from certain changes to pension arrangements.
2.
Ms. O’Brien was appointed to the Board on 4 August 2022 and therefore no pre-2022 data is available for comparative purposes. Ms. O’Brien resigned from the
Board on 29th August 2024. The year on year increase in 2024 reflects an annual performance related salary increase.
3.
Mr. Frawley was appointed to the Board on 29th October 2019. Remuneration for 2019 has been annualised for the purpose of the above. He resigned from the
Board on 30 March 2022.
4.
Mr Elliott resigned from the Board on 31st March 2023. Mr. Elliot’s increase in 2022 is reflective of the increase in board remuneration fees which were approved
in July 2022.
5.
Ms O’Neill was appointed as member of the Board on 17th January 2023, and as Chairperson to the Board on 31st March 2023 and therefore no data is
available for comparative purposes prior to this. The year on year increase in 2024 reflects her appointment as Chairperson during 2023.
6.
Mr. Slattery resigned from the Board on the 14 December 2023. 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 increases in 2022 and 2023
respectively are reflective of the increase in board remuneration fees which were approved in July 2022.
7.
Mr Power resigned from the Board on 19th May 2023. The year on year increases in 2022 and 2023 respectively are reflective of the increase in board
remuneration fees which were approved in July 2022 and which have been annualised for the purposes of the 2023 analysis.
8.
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 increases in 2022 and 2023 respectively are reflective of the increase in board remuneration fees which
were approved in July 2022. The year on year decrease in 2024 is reflective of the windup of the Project Sun Oversight Committee at the end of 2023, of which
Mr O’Neill was a member.
9.
The year on year increases in 2022 and 2023 respectively are reflective of the increase in board remuneration fees which were approved in July 2022. The year
on year decrease in 2024 is reflective of the windup of the Project Sun Oversight Committee at the end of 2023, of which Mr Courtney was a member.
10. Ms Wandhöfer was appointed as a member of the Board on 1st February 2019. Remuneration for 2019 was annualised for the purposes of the above. Her year
on year increase in 2021 reflects payment of fringe benefits during 2021. The year on year increases in 2022 and 2023 respectively are reflective of the increase
in board remuneration fees which were approved in July 2022. The year on year decrease in 2024 is reflective of committee changes.
11. Ms Corcoran was appointed as a member of the Board on 24th September 2019. Remuneration for 2019 was annualised for the purposes of the above. Her
year on year increase in 2021 reflects committee membership changes during 2021. The year on year increases in 2022 and 2023 respectively are reflective
of the increase in board remuneration fees which were approved in July 2022. The year on year decrease in 2024 is reflective of the windup of the Project Sun
Oversight Committee at the end of 2023, of which Ms Corcoran was a member.
12. 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 increases in 2022 and 2023 respectively are reflective of the increase in board remuneration fees which were approved in July 2022. The year
on year decrease in 2024 is reflective of the windup of the Project Sun Oversight Committee at the end of 2023, of which Mr Doddrell was a member.
13. 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 increases in 2022 and 2023 respectively are reflective of the increase in
board remuneration fees which were approved in July 2022. The year on year increases in 2024 is reflective of committee membership changes during the year.
14. 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 increases in 2022 and 2023 respectively are reflective of the increase in board
remuneration fees which were approved in July 2022. The year on year decrease in 2024 is reflective of the windup of the Project Sun Oversight Committee at
the end of 2023, of which Ms Bradley was a member.
15. Ms Moroney was appointed as a member of the Board on 12th December 2023 and therefore no data is available for comparative purposes prior to that.
Remuneration for 2023 was annualised for the purposes of the comparison to 2024.
16. Mr Gildea was appointed as a member of the Board on 12th December 2023 and therefore no data is available for comparative purposes prior to that. The
year on year increases in 2024 is reflective of committee membership changes during the year. Remuneration for 2023 was annualised for the purposes of the
comparison to 2024.
17. 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.
18. Operating profit/loss before exceptional items. See page 410 for a reconciliation of underlying profit to operating profit on an IFRS basis.
19. 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 2024 AGM, held on 15 May 2024, shareholder approval on an advisory basis was sought for the 2024 Directors’ Report on
Remuneration. At the AGM in 2024, 99.7% 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 2024
which was approved by 99.7% 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 resolutions.
PTSB Group Holdings plc - Annual Report 2024
129
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The Directors are responsible for
preparing the Annual Report and the
financial statements in accordance with
applicable law and regulations.
Company law requires the Directors to
prepare Group and Company financial
statements for each financial year. Under
that law, the Directors are required to
prepare the Group financial statements
in accordance with IFRS as adopted by
the European Union and applicable law
including Article 4 of the IAS Regulation.
The Directors have elected to prepare
the Company financial statements in
accordance with IFRS as adopted by the
European Union as applied in accordance
with the provisions of Companies Act
2014.
Under company law the Directors must
not approve the Group and Company
financial statements unless they are
satisfied that they give a true and fair
view of the assets, liabilities and financial
position of the Group and Company and of
the Group’s profit or loss for that 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 applicable Accounting
Standards have been followed,
subject to any material departures
disclosed and explained in the financial
statements;
• assess the Group and Company’s
ability to continue as a going concern,
disclosing, as applicable, matters
related to going concern; and
• use the going concern basis of
accounting unless they either intend to
liquidate the Group or Company or to
cease operations, or have no realistic
alternative but to do so.
The Directors are also required by the
Transparency (Directive 2004/109/EC)
Regulations 2007 and the Transparency
Rules of the Central Bank of Ireland 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 keeping
adequate accounting records which
disclose with reasonable accuracy at
any time the assets, liabilities, financial
position and profit or loss of the Company
and which enable them to ensure that
the financial statements are prepared
in accordance with the applicable
accounting framework and comply with
the provision of the Companies Act 2014.
The Directors are also responsible for
taking all reasonable steps to ensure such
records are kept by its subsidiaries which
enable them to ensure that the financial
statements of the Group comply with the
provisions of the Companies Act 2014
including Article 4 of the IAS Regulation.
They are responsible for such internal
controls as they determine is necessary
to enable the preparation of financial
statements that are free from material
misstatement, whether due to fraud or
error, and have general responsibility
for taking all reasonable steps to ensure
such records are kept by its subsidiaries
which enable them to ensure that the
financial statements of the Group comply
with the provisions of the Companies
Act 2014. They are also responsible for
safeguarding the assets of the Group,
and hence for taking reasonable steps
for the prevention and detection of fraud
and other irregularities. The Directors
are also responsible for preparing a
Directors’ report that complies with the
requirements of the Companies Act 2014.
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.
Each of the Directors, whose names and
functions are listed on pages 79 to 83 of
this Annual Report, confirm that, to the
best of each person’s knowledge and
belief:
• The Group financial statements,
prepared in accordance with IFRS as
adopted by the European Union and the
Company financial statements prepared
in accordance with IFRS as adopted
by the European Union as applied in
accordance with the provisions of
Companies Act 2014, give a true and
fair view of the assets, liabilities, and
financial position of the Group and
Company at 31 December 2024 and of
the profit or loss of the Group for the
year then ended;
• The Directors’ report contained in the
annual report includes a fair review of
the development and performance of
the business and the position of the
Group and Company, together with a
description of the principal risk and
uncertainties that they face;
• The Sustainability Statement contained
in the Directors’ report is prepared in
accordance with ESRS and Article 8(4)
of Regulation (EU) 2020/852 and our
responsibilities for the sustainability
statement are discussed in full in our
statement of directors’ responsibilities
for the sustainability statement in the
annual report on page 136; and
• The Annual Report and financial
statements, taken as a whole, provides
the information necessary to assess
the Group’s performance, business
model and strategy and is fair, balanced
and understandable and provides the
information necessary for shareholders
to assess the Company's position and
performance, business model and
strategy.
On behalf of the Board
Julie O’Neill
Eamonn Crowley
Chairperson
Chief Executive
Barry D’Arcy
Conor Ryan
Chief Financial
Officer
Company Secretary
3 March 2025
Statement of Directors’ Responsibilities
PTSB Group Holdings plc - Annual Report 2024
130
Sustainability
Sustainability
132
Statement of Directors’ Sustainability Responsibilities
136
Independent Practitioner’s Limited Assurance Report
137
Sustainability Statement
140
Annex VI - Template for the KPIs of credit institutions
238
Task Force on Climate related Financial Disclosures
276
PTSB Group Holdings plc - Annual Report 2024
131
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Sustainability
Our Commitment to Building a Sustainable Business
‘We have made notable progress in
integrating sustainability into all areas of our
business, introducing consideration into our
strategic decision-making, risk management
processes, data strategy, external reporting
practices and approach to product and
proposition design.
As we look forward, we are committed to
creating capacity and building a robust long-
term strategic approach to sustainability
that considers both the needs of our
colleagues, customers and wider society, as
well as the opportunity to deliver sustainable
business growth.’
Eamonn Crowley, Chief Executive Officer
Sustainability Strategy Progress & Future Direction
Since the launch of our first Sustainability Strategy in 2021, we
have made considerable progress in enhancing our capability
and putting sustainability at the centre of how we run and grow
our business. Key progress includes:
• Embedding consideration for sustainability into all areas of our
business;
• Meeting sustainability-related regulation and mitigating
against ESG risk;
• Ensuring that our workforce have the right knowledge and
capability to deliver our sustainability objectives;
• Enhancing mortgage and retrofit propositions for personal
customers; and,
• Introducing sustainability propositions for our Business
Banking customers.
Over the coming months, we will be launching our Sustainability
Strategy 2025-2027 to the market. The Strategy has been
informed by the outputs of the Double Materiality Assessment
outlined in our Sustainability Statement. It will provide an
overview of the Bank’s long-term strategic approach to
sustainability, considering both the needs of our stakeholders,
as well as the opportunity to diversify our income and direct
capital towards areas that enhance societal wellbeing.
The following is a summary of progress made under each of the
four pillars of the Bank’s Sustainability Strategy during 2024.
Impact in Action
Addressing Climate Change and Supporting the Transition to a Low Carbon Economy
A Board approved Sustainability Strategy aligned to
the UN SDGs*
Appointment of a Chief Sustainability and Corporate
Affairs Officer to deliver on the Bank’s Sustainability
Strategy
€875 million in green lending during 2024, +28% YoY,
accounting for 43% of new Mortgage Lending
• First lender to participate in the SBCI’s Home Energy Upgrade Loan
Scheme, offering €100 million in loans
• Participation in the SBCI’s Growth and Sustainability Loan Scheme,
offering €70m in loans
• Inaugural €500m Green Senior HoldCo notes issued under the Bank’s
Green Bond Framework
• Disclosing the Bank’s carbon impact across Scope 1, 2 and 3 (including
financed emissions) and developing Science-Based Targets (SBTs)
and a corresponding Carbon Reduction Plan
• Continuing to embed our Sustainable Supplier Charter
• A ‘Low’ ESG Risk Rating through Sustainalytics
• Issuance of the Bank’s inaugural Sustainability Statement aligned to
the Corporate Sustainability Reporting Directive
PTSB Group Holdings plc - Annual Report 2024
132
Elevating Our Social Impact and Connecting with Local Communities
€19.4 million in funding provided to the Social
Finance Foundation since 2009**
€360,000 in charitable giving through the PTSB
Community Fund in 2024, which included matched
funding by the Bank
More than 2,000 volunteering hours provided on the
ground last year, equating to c.€67,000 of in-kind
giving.
• 600 students completing LIFT Ireland’s ‘Minding Our Futures’ Schools
Programme, proudly supported by PTSB
• Title Sponsorship of the Irish Olympic Team and the Irish Paralympic
Team for the 2024 Games in Paris
• Multi-year partnership with AsIAm – Ireland’s Autism Charity
• First Bank in Ireland to receive Autism-Friendly Branch accreditation
• Partnership with Dublin City University (DCU) through its Access
Programme
• 12,000 financial reviews completed last year, supporting customers in
taking control of their financial future
Enhancing Our Culture and Investing in Our People
A Diversity, Equity, and Inclusion Strategy supported
by five Employee Resource Groups – LiveWell,
PRISM, DiCE, Adapt and Better Balance
88% of employees feel comfortable to be themselves
at work regardless of background or life experiences
60% Female Board Gender Composition and 40% of
Senior Leadership positions filled by Women
• A Mean Gender Pay Gap of 16.9% and a Median Gender Pay Gap of
11.6%
• 76% Culture Index Score, +6% above our Culture Index Target of 70%
• Awarded The KeepWell Mark™, the Irish Business and Employer’s
Confederation’s (IBEC) industry accreditation standard that recognises
commitment to employee wellbeing and workplace health
• More than 100,000 hours of training delivered through the Bank’s
eLearning platform COMPASS in 2024
• 145 employees achieved an award by completing an Institute of
Banking (IOB) programme of study, while a further 287 employees
passed an exam on the pathway to completing an IOB programme of
study
• More than 2,400 nominations received to our Values in Practice (VIP)
Awards, the Bank’s Colleague Recognition Programme.
Championing our Customers and Creating a Bank that is Fit for the Future
Relationship Net Promoter Score (RNPS)*** +10%
YoY
19,000 Explore Current Accounts opened in 2024,
with 61% of customer choosing to open them
through digital channels
• A Digital Mortgage Application Journey
• Broadening our Business Banking offering through partnerships with
Bibby Financial Services, the Strategic Banking Corporation of Ireland
and Worldpay
• A focus on cyber security and data protection with training delivered
to all colleagues
• The first Irish Retail Bank to be awarded the Guaranteed Irish Symbol,
recognising our contribution to local communities across the country
*
The United Nation’s Sustainable Development Goals (SDGs) were launched in 2015 to provide a plan of action for people, planet and prosperity. While we
recognise that we may contribute to all 17 SDGs in some way, we have identified 6 as being core to our Strategy.
**
The Social Finance Foundation was established in 2007 by the Irish Government to address the needs of community organisations and social enterprises for
loan funding which was difficult to obtain from mainstream financial institutions. Acting as a ‘wholesaler’, it provides funding to its lending partners Clann Credo
and Community Finance Ireland.
*** Relationship Net Promoter Score (RNPS) measures the willingness of a customers to recommend a company’s products or services to others.
PTSB Group Holdings plc - Annual Report 2024
133
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Awards, Recognition and Pledges
Awards and Recognition in 2024
• Winner – Financial Services Loyalty Programmes/Initiative of the Year for
PTSB’s Explore Current Account, Irish Loyalty Awards, 2024
• Winner – Specialist Lender Award, FS Awards, 2024
• Winner – Brand Campaign of the Year, All Ireland Marketing Awards, 2024
• Winner – Gold for Best Brand Campaign, Digital Media Awards, 2024
• Winner – Silver Bell for Design (Rebranding Schemes) Permanent TSB
becomes PTSB, Institute for Creative Advertising and Design (ICAD), 2024
• Winner – Bronze Bell for Art Direction - Moving with you Campaign
(Mortgages), Institute for Creative Advertising and Design (ICAD), 2024
• Winner – Bronze for Best Use of AV, Media Awards, 2024
• Winner – Best Innovation Award for PTSB Protect, Bonkers Awards, 2024
• Winner – Customer Experience Team of the Year, Customer Experience
Awards, 2024
• Winner – Best Customer Success Story, Customer Experience Awards, 2024
• Winner – Team of the Year for PTSB’s Customer Service Team, Workplace
Excellence Awards, 2024
• Winner – Colleague Engagement and Team Building, Workplace Excellence
Awards, 2024
• Winner – Excellence in Learning and Development for PTSB’s Digital and
Direct Rising Stars Programme, Workplace Excellence Awards, 2024
• Winner – Best Use of Training and Development Strategies for Teams,
Customer Experience Awards, 2024
• Winner – Elevating the Colleague Experience (Large Company), Chartered
Institute of Personnel and Development (CIPD) Awards, 2024
• Winner – Diversity, Equality and Inclusion Initiative, Business and Finance
ESG Awards, 2024
• Winner – Speaking Up and Psychological Safety Award for PTSB’s DiCE
Employee Resource Group, Irish Banking Culture Board (IBCB) Proud to Work
in Banking Awards, 2024
• Winner – Ethical Behaviour Award for PTSB’s People Experience Team, Irish
Banking Culture Board (IBCB) Proud to Work in Banking Awards, 2024
• Winner – Most Innovative use of Technology, National Procurement Awards,
2024
• Winner – Best Community or Charity Engagement for the PTSB Community
Fund, Bonkers Awards, 2024
• Winner – Best Sports Sponsorship for the Olympic Federation of Ireland’s
Dare to Believe Schools Programme, Irish Sport Industry Awards, 2024
• Winner – Who Won Sport Overall in 2024? Award, Who Won Sponsorship
Series, 2024
• Winner – Who Won the Paris Summer Olympics 2024? Award, Who Won
Sponsorship Series, 2024
• Winner – Who Won the Paris Summer Paralympics 2024? Award, Who Won
Sponsorship Series, 2024
• Winner – Bronze for Best Storytelling Direction for ‘Human Behind the
Athlete’ (Motherland Production Company for PTSB), Sharks, 2024
Pledges
Business in the Community Ireland’s
(BITCI) Elevate Inclusive Workplace
Pledge:
PTSB has added our signature to
BITCI’s Elevate Pledge, committing to
building inclusive workplaces that are
representative of all members of our
society. Workplaces have become more
diverse, incorporating a multiplicity of
backgrounds, experiences and identities.
This has brought huge benefits to Irish
business. 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.
Business in the Community Ireland’s
(BITCI) Low Carbon Pledge:
PTSB was pleased to add our signature to
BITCI’s Low Carbon Pledge, deepening our
commitment to long-term sustainability
and committing to new climate action
goals. The Pledge focussed on setting
carbon emission reduction targets based
on science and includes measuring and
reducing our carbon footprint in line
with the Paris Agreement and the latest
Intergovernmental Panel on Climate
Change (IPCC) findings. The Bank was
proud to add our signature to the Pledge,
joining 68 other Irish businesses in
committing to set robust carbon emissions
reduction targets.
Science-based Targets
The Science-Based Target Initiative
(SBTi) provides a pathway for companies
to reduce greenhouse gas emissions,
aiming to mitigate the severe impacts of
climate change while ensuring sustainable
business growth. Targets are deemed
'science-based' when they align with
the latest climate science necessary to
limit global warming to 1.5°C above pre-
industrial levels, as outlined in the Paris
Agreement.
Following a significant programme of
work, during 2024 the Bank worked
to develop our science-based targets
(SBTs) in line with the SBTi’s Version 2
Guidance for Financial institutions. The
work included the development of a
corresponding Carbon Reduction Plan
to support us in achieving our Targets
once set. The Targets and Plan will be
submitted to the SBTi during Q1 2025 for
validation.
Sustainability
(continued)
PTSB Group Holdings plc - Annual Report 2024
134
We will communicate our Targets once the
validation process reaches completion.
For more on the Bank’s SBTs, please refer
to our Sustainability Statement beginning
on page 140.
Disclosures and ESG Risk Ratings
Sustainability Statement and Double
Materiality Assessment
The objective of the Sustainability
Statement is to improve the existing
requirements of the European Union’s
(EU) Non-Financial Reporting Directive,
to better harness the potential of the EU
in the transition to a fully sustainable and
inclusive economic and financial system,
in accordance with the European Green
Deal and the United Nations’ Sustainable
Development Goals.
The Sustainability Statement introduces
new mandatory reporting standards,
the European Sustainability Reporting
Standards (ESRS), which include two
cross cutting and ten topical standards,
plus sector specific/SME standards that
are being developed for later issue.
Materiality determines which of topical
standards, or elements within, are
applicable to a company and must be
disclosed.
During 2024, the Bank completed an
exercise in double materiality in line
with the expectations set out within
the Directive. The exercise assessed
both stakeholder impact and financial
materiality of identified Impacts, Risks and
Opportunities (IROs), to determine those
that were most material to our business,
and important to our stakeholders.
The findings highlighted E1-Climate
Change, S1-Own Workforce, S4-
Consumers and End-Users and G1-
Business Conduct as topical standards
that are material to PTSB.
The Bank has disclosed against these four
material topics within our Sustainability
Statement and have also disclosed
against ESRS 2, which is mandatory for all
in-scope companies.
To read PTSB’s disclosure, which includes
a detailed overview of the Bank’s Double
Materiality Assessment process, please
refer to our Sustainability Statement
beginning on page 140.
The findings from the Double Materiality
Assessment have played an integral role
in guiding an informing the next evolution
of the Bank’s Sustainability Strategy. This
strategy will launch during 2025.
Task Force on Climate Related
Financial Disclosures
In 2021, PTSB became a supporter
of the Task Force on Climate-related
Financial Disclosures (TCFD). The 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.
To read PTSB’s 2024 TCFD Report, please
refer to page 276.
EU Taxonomy
In accordance with Article 8 of the EU
Taxonomy Regulation and the underlying
Disclosures Delegated Act, PTSB is
required to disclose KPIs related to the
proportion of taxonomy-eligible (across
all six environmental objectives) and
taxonomy-aligned activities (for climate
change mitigation, and climate change
adaption) for year-end 2024.
You can view PTSB’s 2024 EU Taxonomy
disclosure on page 238.
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, Equity, and Inclusion (DEI) is
a core pillar of our culture. For the fifth
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 DEI
Strategy.
Our 2024 gender pay gap is as follows:
• Mean Gender Pay Gap 2024 – 16.9%
• Median Gender Pay Gap 2024 – 11.6%
An ESG Risk Rating Through
Sustainalytics
PTSB engaged Sustainalytics, a leading
independent ESG and Corporate Governance
research ratings and analytics firm,
to produce an ESG Risk Rating for the
organisation. ESG Risk Ratings measure a
company’s exposure to industry-specific
material Environmental, Social and
Governance risks, to determine how well a
company is managing those risks.
Following the process, the Bank received a
‘Low’ rating, recognising that enterprise value
is considered to have a low risk of material
financial impacts driven by ESG factors.
Company ratings are categorised across five
levels: negligible, low, medium, high, and
severe.
The Business Working Responsibly
Mark
Following a comprehensive programme of
work, the Bank was proud to be certified
with the Business Working Responsibly Mark
(The Mark) from Business in the Community
Ireland (BITCI) for the second time.
The Mark is an external accreditation
recognising best in class Responsible
Business Programmes in Ireland and as such,
the Bank joins a prestigious group of only
38 other companies who have achieved
this accolade. As part of this accreditation,
our CEO, Eamonn Crowley sits alongside
the CEOs of other member companies as
part of the Leaders Group on Sustainability
– a collaborative group who work with key
stakeholders to drive ESG change across the
country.
The Bank first received the Mark in 2020.
We will continue to work alongside BITCI
as we continue to embed our Sustainability
Programme in the years that lie ahead.
PTSB Group Holdings plc - Annual Report 2024
135
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The Directors of the Entity are responsible
for: preparing the Sustainability Statement
in accordance with the relevant criteria,
contained in the applicable sustainability
reporting framework being Part 28 of
the Companies Act 2014, the ESRS; the
Taxonomy Regulations; and any additional
criteria used by the Entity to supplement
and/or interpret the sustainability
reporting framework criteria. This
responsibility includes:
• understanding the context in which
the Entity’s activities and business
relationships take place and developing
an understanding of its affected
stakeholders;
• the identification of the actual and
potential impacts (both negative and
positive) related to sustainability
matters, as well as risks and
opportunities that affect, or could
reasonably be expected to affect, the
entity’s financial position, financial
performance, cash flows, access to
finance or cost of capital over the short,
medium, or long-term;
• the assessment of the materiality
of the identified impacts, risks and
opportunities related to sustainability
matters by selecting and applying
appropriate thresholds;
• when relevant, using reasonable
assumptions and estimates in preparing
the Sustainability Statement. This
includes the selection of different but
acceptable estimation, approximation or
forecasting techniques about forward-
looking information;
• disclosing and reporting our double
materiality assessment process in the
Sustainability Statement in accordance
with ESRS;
• ensuring the Entity maintains adequate
records in relation to the preparation of
the Sustainability Statement;
• disclosing that the scope of
consolidation for the Sustainability
Statement is the same as for the
financial statements and disclosing
to what extent the Sustainability
Statement covers the Company’s
upstream and downstream value chain
(“the reporting boundary”);
Statement of Directors’ Sustainability Responsibilities
• including material value chain
information that meets the qualitative
characteristics set out in ESRS in the
Sustainability Statement when required
by ESRS;
• appropriately referring to and describing
the applicable criteria used;
• identifying the quantitative metrics
and monetary amounts disclosed in
the Sustainability Statement that are
subject to a high level of measurement
uncertainty;
• disclosing established targets, goals
and other performance measures,
and implementing actions to achieve
such targets, goals and performance
measures;
• describing the implemented due
diligence process in respect of
sustainability matters of the Entity;
• reporting and preparing forward-looking
information, when applicable, on the
basis of disclosed assumptions about
events that may occur in the future and
possible future actions by the Entity;
and
• The Directors are also responsible
for designing, implementing and
maintaining such internal controls that
they determine are relevant to enable
the preparation of the Sustainability
Statement in accordance with Part 28
of the Companies Act 2014 that is free
from material misstatement, whether
due to fraud or error.
On behalf of the Board
Julie O’Neill
Eamonn Crowley
Chairperson
Chief Executive
Barry D’Arcy
Conor Ryan
Chief Financial
Officer
Company Secretary
3 March 2025
PTSB Group Holdings plc - Annual Report 2024
136
Independent Practitioner’s Limited Assurance Report
to the Directors of PTSB Group Holdings Plc Group PLC
Limited Assurance Report on the
Sustainability Statement
Our limited assurance conclusion
We have performed a limited assurance
engagement on the sustainability
reporting included in the consolidated
Sustainability Statement ( ‘Sustainability
Statement’) of PTSB Group Holdings PLC
and its consolidated undertakings (“the
Group”) for the year ended 31 December
2024, prepared in accordance with Part
28 of the Companies Act 2014 and set out
on pages 140 to 275, which is a dedicated
section of the Directors’ Report.
Based on the procedures performed and
evidence obtained, nothing has come
to our attention to cause us to believe
that the Group’s Sustainability Statement
for the year ended 31 December 2024
is not prepared, in all material respects,
in accordance with Part 28 of the
Companies Act 2014, including:
• the compliance of the Sustainability
Statement with the European
Sustainability Reporting Standards
(ESRS);
• the process carried out by the Group to
identify material sustainability related
impacts, risks, and opportunities in
accordance with ESRS;
• the compliance with the reporting
requirements of Article 8 of Regulation
(EU) 2020/852 (the “Taxonomy
Regulations”); and
• compliance with the requirement to
mark up the Sustainability Statement
in accordance with Section 1600 of the
Companies Act 2014.
Basis for our conclusion
We conducted our limited assurance
engagement in accordance with
International Standard on Assurance
Engagements (ISAE) (Ireland) 3000,
as adopted by the Irish Auditing and
Accounting Supervisory Authority (IAASA).
Our responsibilities under this standard
are further described in the section titled
‘Our responsibilities’ in this report.
The procedures in a limited assurance
engagement vary in nature and timing
from, and are less in extent than for,
a reasonable assurance engagement.
Consequently, the level of assurance
obtained in a limited assurance
engagement is substantially lower than
the assurance that would have been
obtained had a reasonable assurance
engagement been performed.
Any internal control structure, no
matter how effective, cannot eliminate
the possibility that fraud, errors or
irregularities may occur and remain
undetected and because we use selective
testing in our engagement, we cannot
guarantee that all errors or irregularities, if
present, will be detected.
The Sustainability Statement includes
prospective information such as
ambitions, strategy, plans, expectations
and estimates. Prospective information
relates to events and actions that have
not yet occurred and may never occur.
We do not provide any assurance on the
assumptions and achievability of this
prospective information.
Our responsibilities under this standard
are further described in the section titled
‘Our responsibilities’ in this report.
We have fulfilled our ethical
responsibilities under, and we remained
independent of the Group in accordance
with, ethical requirements applicable in
Ireland, including the International Code
of Ethics for Professional Accountants
(including International Independence
Standards) issued by the International
Ethics Standards Board for Accountants
(IESBA Code), the independence
requirements of the Companies Act
2014 and the Code of Ethics issued
by Chartered Accountants Ireland that
are relevant to our limited assurance
engagement of the Sustainability
Statement in Ireland.
Our firm applies International Standard on
Quality Management (ISQM) 1 (Ireland),
Quality Management for Firms that
Perform Audits or Reviews of Financial
Statements, or Other Assurance or
Related Services Engagements, issued
by the IAASA. This standard requires the
firm to design, implement and operate
a system of quality management,
including policies or procedures regarding
compliance with ethical requirements,
professional standards and applicable
legal and regulatory requirements.
We believe that the evidence we have
obtained is sufficient and appropriate to
provide a basis for our conclusion.
Other matter – Compliance with
the requirement to mark-up the
Sustainability Statement
We note that Section 1613(3)(c) of the
Companies Act 2014 requires us to
report on the compliance by the Group
with the requirement to mark-up the
Sustainability Statement in accordance
with Section 1600 of that Act. Section
1600 of the Companies Act 2014 requires
that the Directors’ Report is prepared in
the electronic reporting format specified
in Article 3 of Delegated Regulation
(EU) 2019/815 and shall mark-up the
Sustainability Statement. However, at
the time of issuing our limited assurance
report, the electronic reporting format has
not been specified nor become effective
by Delegated Regulation. Consequently,
the Group is not required to mark-up the
Sustainability Statement. Our conclusion
is not modified in respect of this matter.
Other information
The directors are responsible for the
other information. The other information
comprises the information in the assured
parts of the Strategic Report set out on
pages 2 to 67, the Governance section
on pages 68 to 130, the Consolidated
Financial Statements set out on pages
292 to 401, the Company Financial
Statements on pages 402 to 408 and
General Information set out on pages 410
to 421.
The Sustainability Statement and our
Limited Assurance Report thereon do not
comprise part of the other information.
Our limited assurance conclusion on the
Sustainability Statement does not cover
the other information and we do not
express any form of assurance conclusion
thereon.
The comparative sustainability reporting
in the Sustainability Statement included
in the Directors’ Report for the period
from 01 January 2023 to 31 December
2023 has not been part of the assurance
engagement. Consequently, the
comparative sustainability reporting
PTSB Group Holdings plc - Annual Report 2024
137
Strategic Report
Governance
Sustainability
Financial Statements
General Information
and thereto related disclosures in the
Sustainability Statement for this period
are not assured.
Responsibilities for the Sustainability
Statement
As explained more fully in the Statement
of Directors’ Responsibilities for the
Sustainability Statement, the directors of
the Group are responsible for:
• preparing, measuring, presenting and
reporting the Sustainability Statement
in accordance with the relevant
criteria, contained in the applicable
sustainability reporting framework being
the ESRS, Part 28 of the Companies
Act 2014; the Taxonomy Regulations;
the requirement to mark up the
Sustainability Statement in accordance
with Section 1600 of the Companies
Act 2014; and any additional criteria
used by the Group to supplement and/
or interpret the sustainability reporting
framework criteria; and
• developing, implementing and reporting
its double materiality assessment
process to identify the information
reported in the Sustainability
Statement in accordance with ESRS
and for disclosing this process in
the Sustainability Statement. This
responsibility includes identifying and
engaging with the Group’s stakeholders
as identified in the Group’s double
materiality assessment process
(stakeholders) to understand their
information needs.
Inherent limitations in preparing the
Sustainability Statement
We obtained limited assurance over
the preparation of the Sustainability
Statement in accordance with the
Companies Act 2014. Inherent limitations
exist in all assurance engagements.
There are inherent limitations regarding
the measurement or evaluation of the
Sustainability Statement subject to limited
assurance, which have been set out
below:
• Estimates, approximations and/
or forecasts used by the Group
in preparing and presenting their
Sustainability Statement are subject
to significant inherent uncertainty.
The extent to which the Sustainability
Statement contains, qualitative,
quantitative, objective, subjective,
historical and prospective disclosures,
also represents a significant degree
of uncertainty. The selection by
management of different but
acceptable estimation, approximation
or forecasting techniques, could have
resulted in materially different amounts
or disclosures being reported. For the
avoidance of doubt, the scope of our
engagement and our responsibilities
will not involve us performing work
necessary for any assurance on
the reliability, proper compilation,
or accuracy of the prospective
information.
• In determining the disclosures in the
Sustainability Statement, management
of the Group interprets undefined
legal and other terms. Undefined
legal and other terms may be
interpreted differently, including the
legal conformity of their interpretation
and, accordingly, are subject to
uncertainties.
• Certain metrics reported within the
Sustainability Statement may be subject
to inherent limitations, for example,
value chain information relating to
emissions data provided by third
parties.
• Where estimated, approximated and/
or forecast information is provided
by management in respect of value
chain information, the verification or
benchmarking of this information is
subject to a high degree of uncertainty
and the actual value chain information
may be different to the estimated,
approximated or forecast value chain
information provided by management
• When applicable, as described in your
disclosures relating to ESRS E1 Climate
Change, GHG emissions quantification
is subject to significant inherent
measurement uncertainty because
of incomplete scientific knowledge
used to determine emissions factors
and the values to combine emissions
of different gases. Greenhouse gas
quantification is unavoidably subject
to significant inherent uncertainty as a
result of both scientific and estimation
uncertainty. Estimation uncertainty can
arise because of:
1.
The inherent uncertainty in
quantifying inputs, such as activity
data and emission factors, that are
used in mathematical models to
estimate emissions (measurement
uncertainty);
2.
the inability of such models to
precisely and accurately characterise
under all circumstances the
relationships between various inputs
and the resultant emissions (model
uncertainty); and
3.
the fact that uncertainty can
increase as emission quantities with
different levels of measurement
and calculation uncertainty
are aggregated (aggregation
uncertainty).
• The self-defined nature of the Basis
of Preparation, the nature of the
sustainability matters, and absence of
consistent external standards allow for
different, but acceptable, measurement
methodologies to be adopted which
may result in variances between
entities. The adopted measurement
methodologies may also impact the
comparability of sustainability matters
reported by different organizations and
from year to year within an organization
as methodologies develop.
Our responsibilities
Our objectives are to plan and perform
the assurance engagement to obtain
limited assurance about whether the
Sustainability Statement in scope of
our conclusion, is free from material
misstatement, whether due to fraud or
error, and to issue a Limited Assurance
Report that includes our conclusion.
Misstatements can arise from fraud or
error and are considered material if,
individually or in the aggregate, they could
reasonably be expected to influence
decisions of users on the basis of the
Sustainability Statement.
As part of a limited assurance
engagement in accordance with ISAE
(Ireland) 3000, we exercise professional
judgment and maintain professional
skepticism throughout the engagement.
We also:
• Perform risk assessment procedures,
including obtaining an understanding
of internal controls relevant to the
engagement, to identify disclosures
where material misstatements are likely
to arise, whether due to fraud or error,
but not for the purpose of providing a
conclusion on the effectiveness of the
Group’s internal control.
Independent Practitioner’s Limited Assurance Report
to the Directors of PTSB Group Holdings Plc Group PLC (continued)
PTSB Group Holdings plc - Annual Report 2024
138
• Design and perform procedures
responsive to where material
misstatements are likely to arise in the
Sustainability Statement. The risk of
not detecting a material misstatement
resulting from fraud is higher than for
one resulting from error, as fraud may
involve collusion, forgery, intentional
omissions, misrepresentations, or the
override of internal control.
• Design and perform procedures to
evaluate whether the Sustainability
Statement has been prepared in
accordance with the ESRS, which
includes the process carried out by the
Group to identify material sustainability
related impacts, risks and opportunities.
• Design and perform procedures to
evaluate whether the Sustainability
Statement has been prepared in
in compliance with the Taxonomy
Regulations.
• With respect to our conclusion in
respect to the Group’s reporting
obligations and responsibility to mark
up the Sustainability Statement in
accordance with Section 1600 of
the Companies Act 2014, we assess
whether we have become aware
of anything to suggest that the
Sustainability Statement has not been
prepared, in all material respects in this
specified format. However, as explained
in the ‘Other matter- Compliance
with the requirement to mark-up the
Sustainability Statement’ section of
our assurance report, the Group is
not currently required to mark-up the
Sustainability Statement.
Summary of the work performed
A limited assurance engagement involves
performing procedures to obtain evidence
about the Sustainability Statement. The
nature, timing and extent of procedures
selected depend on professional
judgment, including the identification of
disclosures where material misstatements
are likely to arise, whether due to fraud or
error, in the Sustainability Statement.
The procedures in a limited assurance
engagement vary in nature and timing
from, and are less in extent than for,
a reasonable assurance engagement
and depend on professional judgment,
including the identification of disclosures
where material misstatements are likely to
arise, whether due to fraud or error, in the
Sustainability Statement. Consequently,
the level of assurance obtained in a limited
assurance engagement is substantially
lower than the assurance that would
have been obtained had a reasonable
assurance engagement been performed.
In conducting our limited assurance
engagement, the procedures we have
performed included the following:
• Obtaining an understanding of the
Sustainability Statement reporting
process performed by the Group,
including the preparation of the
Sustainability Statement.
• Obtaining an understanding of the
Group’s double materiality assessment
process by performing inquiries
to understand the sources of the
information used by management
and reviewing the Group’s internal
documentation of this process; and
evaluating whether the evidence
obtained from our procedures about the
Group’s process is consistent with the
description of the process set out in the
Sustainability Statement;
• Performing risk assessment procedures
to understand the Group and its
environment, including the Group’s
reporting boundary, its value chain
information and identify risks of material
misstatement;
• Designing and performed further
assurance procedures (which included
inquiries and analytical procedures)
to respond to the identified risks of
material misstatement; and
• Evaluating the overall presentation
of the Sustainability Statement, and
considering whether the Sustainability
Statement as a whole, including the
sustainability matters and disclosures,
is disclosed in accordance with the
applicable criteria.
The purpose of our limited assurance
work and to whom we owe our
responsibilities.
Our report is made solely in accordance
with Section 1613 of the Companies Act
2014 to the Directors of the Group.
Our assurance work has been undertaken
so that we might state to the Directors
those matters we are required to state to
them in a limited assurance report and
for no other purpose. To the fullest extent
permitted by law, we do not accept or
assume responsibility to anyone other
than the Group and its Directors, as a
body, for our limited assurance work, for
this report, or for the conclusions we have
formed.
Patricia Carroll
For and on behalf of
KPMG
Chartered Accountants, Statutory Audit
Firm
1 Harbourmaster Place
IFSC
Dublin 1
3 March 2025
PTSB Group Holdings plc - Annual Report 2024
139
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Sustainability Statement
In accordance with Section 1592 Part 28 of the companies Act 2014, the Group has prepared a Sustainability Statement for the year
ended 31 December 2024. This Sustainability Statement is set out on pages 136 to 275 and represents a dedicated section of the
Director’s Report. The following abbreviations are used throughout the statements to support navigation of the disclosure.
BP
Basis for Preparation
E1
ESRS E1 - Climate Change
ESRS
European Sustainability Reporting Standards
G1
ESRS G1 - Business Conduct
GOV
Governance
IRO
Impacts, Risks and Opportunities
MDR
Minimum Disclosure Requirements
MDR -A
Minimum Disclosure Requirements (Actions)
MDR-P
Minimum Disclosure Requirements (Policies)
MDR-M
Minimum Disclosure Requirements (Metrics)
MDR-T
Minimum Disclosure Requirements (Targets)
S1
ESRS S1 - Own Workforce
S4
ESRS S4 - Consumers and End-Users
SBM
Strategy and Business Model
Sustainability Statement Content Index
Section
Page
ESRS 2 - General Disclosures
144
BP-1 – General basis for preparation of the Sustainability Statement
BP-1
144
BP-2 – Disclosures in relation to specific circumstances
BP-2
144
GOV-1 – The role of the administrative, management and supervisory bodies
GOV-1
144
GOV-2 – Information provided to, and sustainability matters addressed by the
undertaking’s administrative, management and supervisory bodies
GOV-2
149
GOV-3 – Integration of sustainability-related performance in incentive schemes
GOV-3
149
GOV-4 – Statement on due diligence
GOV-4
150
GOV-5 – Risk management and internal controls over sustainability reporting
GOV-5
150
SBM-1 – Strategy, Business Model and Value Chain
SBM-1
150
SBM-2 – Interests and views of stakeholders
SBM-2
151
SBM-3 – Material impacts, risks and opportunities and their interaction with strategy and
business model
SBM-3
152
IRO-1 – Description of the processes to identify and assess material impacts, risks and
opportunities
IRO-1
158
IRO-2 – Disclosure requirements in ESRS covered by the Bank’s Sustainability Statement
IRO-2
140 &
233
MDR-P – ESRS 2 Policies associated with this Sustainability Statement
MDR-P
159
ESRS E1 – Climate Change
174
PTSB Group Holdings plc - Annual Report 2024
140
Sustainability Statement
Sustainability Statement Content Index
Section
Page
E1-1 – Transition plan for climate change mitigation
E1-1
174
E1-2 – Policies related to climate change mitigation and adaptation
E1-2
177
E1-3 – Actions and resources in relation to climate change policies
E1-3
177
E1-4 – Targets related to climate change mitigation and adaptation
E1-4
180
E1-5 – Energy consumption and mix
E1-5
183
E1-6 – Gross Scopes 1, 2, 3 and Total GHG emissions
E1-6
184
E1-7 – GHG removals and GHG mitigation projects financed through carbon credits
E1-7
186
E1-8 – Internal Carbon Pricing
E1-8
186
E1-MDR1 - Own Emissions
E1-MDR1
187
Policies MDR-P – Policies adopted to manage Own Emissions
E1-MDR1-P
188
Actions MDR-A – Actions and resources in relation to Own Emissions
E1-MDR1-A
188
Metrics MDR-M – Metrics in relation to Own Emissions
E1-MDR1-M
189
Targets MDR-T – Tracking effectiveness of policies and actions through targets
E1-MDR1-T
189
E1-MDR2 - Own Operations
E1-MDR2
189
Policies MDR-P – Policies adopted to manage Own Operations
E1-MDR2-P
190
Actions MDR-A – Actions and resources in relation to Own Operations
E1-MDR2-A
190
Metrics MDR-M – Metrics in relation to Own Operations
E1-MDR2-M
190
Targets MDR-T – Tracking effectiveness of policies and actions through targets
E1-MDR2-T
190
E1-MDR3 - Regulatory Risk
E1-MDR3
191
Policies MDR-P – Policies adopted to manage Regulatory Risk
E1-MDR3-P
192
Actions MDR-A – Actions and resources in relation to Regulatory Risk
E1-MDR3-A
193
Metrics MDR-M – Metrics in relation to Regulatory Risk
E1-MDR3-M
193
Targets MDR-T – Tracking effectiveness of policies and actions through targets
E1-MDR3-T
194
E1-MDR4 - Product Financing
E1-MDR4
194
Policies MDR-P – Policies adopted to manage Product Financing
E1-MDR4-P
196
Actions MDR-A – Actions and resources in relation to Product Financing
E1-MDR4-A
197
Metrics MDR-M – Metrics in relation to Product Financing
E1-MDR4-M
198
Targets MDR-T – Tracking effectiveness of policies and actions through targets
E1-MDR4-T
198
ESRS S1 – Own Workforce
199
S1-1 – Policies related to Own Workforce
S1-1
199
S1-2 – Processes for engaging with own workforce and workers’ representatives about
impacts
S1-2
200
S1-3 – Processes to remediate negative impacts and channels for own workforce to raise
concerns
S1-3
201
PTSB Group Holdings plc - Annual Report 2024
141
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Sustainability Statement Content Index
Section
Page
S1-4 – Taking action on material impacts on own workforce, and approaches to managing
material risks and pursuing material opportunities related to own workforce, and
effectiveness of those actions
S1-4
201
S1-5 – Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
S1-5
202
S1-6 – Characteristics of the Bank’s employees
S1-6
202
S1-8 – Collective bargaining coverage and social dialogue
S1-8
203
S1-9 – Diversity metrics
S1-9
203
S1-10 – Adequate wages
S1-10
203
S1-14 – Health and safety metrics
S1-14
203
S1-16 – Remuneration metrics (pay gap and total remuneration)
S1-16
203
S1-17 – Incidents, complaints and severe human rights impacts
S1-17
204
S1-MDR1 – Working Conditions
S1-MDR1
204
Policies MDR-P – Policies adopted to manage Working Conditions
S1-MDR1-P
205
Actions MDR-A – Actions and resources in relation to Working Conditions
S1-MDR1-A
206
Metrics MDR-M – Metrics in relation to Working Conditions
S1-MDR1-M
208
Targets MDR-T – Tracking effectiveness of policies and actions through targets
S1-MDR1-T
209
ESRS S4 – Consumers and End-Users
210
S4-1 – Policies related to Consumers and End-Users
S4-1
210
S4-2 – Processes for engaging with Consumers and End-Users about impacts
S4-2
211
S4-3 – Processes to remediate negative impacts and channels for Consumers and End-
Users to raise concerns
S4-3
211
S4-4 – Taking action on material impacts on Consumers and End-Users, and approaches
to managing material risks and pursuing material opportunities related to Consumers and
End-Users, and effectiveness of those actions
S4-4
212
S4-5 – Targets related to managing material negative impacts, advancing positive impacts,
and managing material risks and opportunities
S4-5
212
S4-MDR1 Housing
S4-MDR1
212
Policies MDR-P – Policies adopted to manage Housing
S4-MDR1-P
213
Actions MDR-A – Actions and resources in relation to Housing
S4-MDR1-A
213
Metrics MDR-M – Metrics in relation to Housing
S4-MDR1-M
213
Targets MDR-T – Tracking effectiveness of policies and actions through targets
S4-MDR1-T
213
S4-MDR2 Customer Experience
S4-MDR2
214
Policies MDR-P – Policies adopted to manage Customer Experience
S4-MDR2-P
215
Actions MDR-A – Actions and resources in relation to Customer Experience
S4-MDR2-A
215
Metrics MDR-M – Metrics in relation to Customer Experience
S4-MDR2-M
217
Targets MDR-T – Tracking effectiveness of policies and actions through targets
S4-MDR2-T
217
Sustainability Statement
Content Index (continued)
PTSB Group Holdings plc - Annual Report 2024
142
Sustainability Statement
Sustainability Statement Content Index
Section
Page
ESRS G1 – Business conduct
218
ESRS 2 GOV-1 - The role of the administrative, management and supervisory bodies
GOV-1
218
ESRS 2 IRO-1 - Description of the process to identify and assess material impacts, risks
and opportunities
IRO-1
220
G1-1– Business conduct policies and corporate culture
G1-1
220
G1-2 – Management of relationships with suppliers
G1-2
223
G1-3 – Prevention and detection of corruption and bribery
G1-3
224
G1-4 – Incidents of corruption or bribery
G1-4
225
G1-5 – Political influence and lobbying activities
G1-5
225
G1-6 – Payment practices
G1-6
225
G1-MDR1 Compliance
G1-MDR1
225
Policies MDR-P – Policies adopted to manage Compliance
G1-MDR1-P
227
Actions MDR-A – Actions and resources in relation to Compliance
G1-MDR1-A
227
Metrics MDR-M – Metrics in relation to Compliance
G1-MDR1-M
228
Targets MDR-T – Tracking effectiveness of policies and actions through targets
G1-MDR1-T
228
G1-MDR2 Managing Suppliers
G1-MDR2
228
Policies MDR-P – Policies adopted to manage Managing Suppliers
G1-MDR2-P
229
Actions MDR-A – Actions and resources in relation to Managing Suppliers
G1-MDR2-A
230
Metrics MDR-M – Metrics in relation to Managing Suppliers
G1-MDR2-M
230
Targets MDR-T – Tracking effectiveness of policies and actions through targets
G1-MDR2-T
230
G1-MDR3 Sponsorships and Community Partnerships
G1-MDR3
230
Policies MDR-P – Policies adopted to manage Sponsorships and Community Partnerships
G1-MDR3-P
231
Actions MDR-A – Actions and resources in relation to Sponsorships and Community
Partnerships
G1-MDR3-A
231
Metrics MDR-M – Metrics in relation to Sponsorships and Community Partnerships
G1-MDR3-M
232
Targets MDR-T – Tracking effectiveness of policies and actions through targets
G1-MDR3-T
232
Appendix
233
Appendix A - List of datapoints in cross-cutting and topical standards that derive from
other EU Legislation
233
Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation)
238
PTSB Group Holdings plc - Annual Report 2024
143
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Basis for preparation
BP-1 General basis for
preparation of sustainability
statements
This disclosure has been prepared on
a consolidated basis, incorporating
Permanent TSB Group Holdings plc and
its subsidiary undertakings (herein ‘PTSB’
or ‘the Bank’). The scope of consolidation
for this disclosure is the same as for the
financial statements. The Sustainability
Statement has been prepared in
accordance with Part 28 of the
Companies Act 2014. The Sustainability
Statement is a dedicated section of the
Report of the Directors Report on pages
140 to 275.
As part of the Bank’s Double Materiality
Assessment (DMA) that was performed
to assess sustainability-related Impacts,
Risks and Opportunities (IROs), PTSB
considered its value chain, beyond
its own operational footprint. This
included upstream actors (for example,
investors and suppliers), downstream
actors (for example, customers and
the environment), and the Bank’s own
operations.
PTSB recognises the importance of
its relationship with actors across its
value chain and has developed a range
of Policies that supports the Bank in
engaging with them in an effective way,
as outlined at ESRS 2-MDR-P. Details of
any associated actions and targets, are
disclosed within the Minimum Disclosure
Requirement (MDR) sections.
PTSB has not omitted any information
corresponding to intellectual property,
know-how or the results of innovation.
Similarly, the Bank has not omitted
impending developments or matters in
the course of negotiation.
ESRS 2 General Disclosures
BP-2 Disclosures in relation to specific circumstances
In preparation of the Bank’s DMA, PTSB used the time horizons as defined in ESRS 1.
The Bank recognises that the time horizons that it uses for CR&E risk are not aligned
to the DMA time horizons disclosed within the Sustainability Statement. This is a
result of assessment activities being completed at different intervals, with some being
conducted earlier in the year.
The time horizons utilised in our assessments are outlined below:
Assessment Time Horizon
Short-term
Medium-term
Long-term
Double Materiality Assessment
(Sustainability Statement)
0-1 years
1-5 years
5+ years
Climate-Related and Environmental
Risk (TCFD Report)
0-3 years
3-5 years
5+ years
As part of this disclosure, the value chain-related metrics include Scope 3 emissions.
The basis of preparation for these metrics, as well as the associated caveats, are
outlined in E1-4.
The only quantitative metrics subject to estimation relate to the Bank’s Scope 3
Financed Carbon Emissions. Details of the methodology applied are referenced in
section E1-4 related to climate change mitigation.
PTSB has not included any voluntary disclosures within this Sustainability Statement.
PTSB has not incorporated any disclosures by reference within this Sustainability
Statement.
Governance
GOV-1 The role of the administrative, management and
supervisory bodies
PTSB defines its administrative, management, and supervisory (AMS) bodies as the
Board, the Executive Committee, and their respective Sub-Committees. The Board's
Sub-Committees include the Audit Committee, Risk and Compliance Committee,
Remuneration Committee, and the Nomination, Culture, and Ethics Committee. The
Executive Committee's sub-committees include the Sustainability Committee, which is
responsible for the delivery of the Bank’s Sustainability Strategy by ensuring that there
is sufficient oversight, alignment, governance and challenge of activity across key areas
of focus for the Bank’s overall sustainability programming.
PTSB’s Board of Directors (Board) is comprised of 11 members; two Executive Directors
and nine Non-Executive Directors (of which seven are Independent)
Board
Executive
Committee
Board Audit
Committee
Risk and
Compliance
Committee
Remuneration
Committee
Nomination,
Culture
and Ethics
Committee
Sustainability
Committee
Number of Executive
Directors
2
9
-
-
-
-
8
Number of Non-Executive
Directors
9
-
5
5
4
5
8
Total
11
9
5
5
4
5
16
Male
5
7
2
2
1
2
11
Female
6
2
3
3
3
3
5
Note: Representation of employees and other workers occurs on an ad-hoc basis.
The PTSB Board’s gender diversity ratio is 6:5 Female to Male Ratio.
PTSB Group Holdings plc - Annual Report 2024
144
Sustainability Statement
The Board is responsible for setting, approving and overseeing the implementation of the overall business strategy and the key
policies/frameworks of the Bank within the applicable regulatory and legal requirements, taking into account the Bank’s long-term
financial interests and solvency. The Board will set, approve and oversee implementation of the Bank’s risk strategy, including the risk
appetite and risk management framework, and monitor the implementation of risk culture within the Bank, and consider the impact of
risk culture on the financial stability, risk profile and robust governance of the Bank and recommend amendments where necessary.
The relevant experience of each Board member in relation to the Bank’s sectors, products and geographical location is outlined below.
Name
Role
Relevant Sector, Product and Geographical Experience
Julie O’Neill
Chair/ Independent
Non-Executive
Director
• An accomplished business leader with extensive Executive and Board experience,
having held a number of senior government positions.
• Extensive business and leadership experience and brings an in-depth knowledge
of the Bank and wider banking/insurance industry to the Board.
Eamonn
Crowley
Chief Executive
Officer (CEO)
Executive Director
• 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.
• Stakeholder management experience with particular focus of building effective
relationships with colleagues, regulators, government and markets (shareholders,
investors and analysts).
• An accomplished business leader who takes a broad perspective and has a deep
commitment to both organisational culture and operational transformation for the
benefit of key stakeholders such as shareholders, customers, colleagues.
Barry D’Arcy
Chief Financial
Officer (CFO)
Executive Director
• A CIMA Fellow and qualified Chartered Global Management Accountant (FCMA,
CGMA).
• A finance and risk professional with significant banking and leadership experience
having worked in the Commercial and Retail Banking sector in Ireland for more
than 15 years.
• Brings a wealth of financial, risk, commercial, strategic, operational and regulatory
knowledge to the Bank.
• Experience in delivering large complex programmes successfully. Barry was
appointed CFO in February 2025, having joined the Bank as CRO in October 2023.
Dr Ruth
Wandhöfer
Independent Non-
Executive Director
• Substantial banking and leadership experience with extensive knowledge of both
regulatory and market strategy.
• Insight on regulatory and financial technology innovation providing invaluable
insight for the Board as it provides oversight for the Bank’s digital and payments
transformation programmes.
Ronan O’Neill
Independent Non-
Executive Director
• A chartered accountant, with extensive banking and leadership experience with a
particular competency in finance, risk and treasury.
• Strategic and corporate development insights providing challenge and support to
the development of the Bank’s organisational change programmes.
PTSB Group Holdings plc - Annual Report 2024
145
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Name
Role
Relevant Sector, Product and Geographical Experience
Anne Bradley
Independent Non-
Executive Director
• Broad Executive and Non-Executive leadership and advisory experience having
led strategy development in technology and business transformations, Executive
leadership and strategy development.
• Experience centered on transformation and business change, resilience,
emergency response, technology evaluation, crisis management, operational
efficiency, and IT infrastructure.
• Cross-industry skills in stakeholder management, risk management, corporate
governance and technology-enabled transformation benefits the Board as the
Bank’s strategy and change programmes evolves at an ever increasing pace.
Celine
Fitzgerald
Independent Non-
Executive Director
• Led culture transformation in challenging environments.
• Practical experience of handling ethical challenges in the charity sector during her
time as Managing Director of Goal.
• In-depth understanding of strategic differentiation to deliver customer value.
Catherine
Moroney
Independent Non-
Executive Director
• Extensive experience in retail, corporate and business banking and an
accomplished business leader who has spent a large portion of her career at
Senior Executive level in the Irish financial services sector.
• Expertise in leading customer-facing businesses with a focus on strategic
planning, business growth, innovation, transformation and sustainability.
Richard Gildea
Independent Non-
Executive Director
• Former Independent Non-Executive Director at Alpha Bank (a domestic and
international bank listed on the Stock Exchange in Athens) where he chaired
the Remuneration Committee and was a member of the Risk Committee, with a
particular focus on non-performing loan risk management.
• Deep experience of client coverage and risk management together with capital
markets.
Paul Doddrell
Independent Non-
Executive Director
• Significant Executive leadership experience spanning finance, asset servicing,
lending, operations, and sales with specific management expertise in business
strategy development and execution, risk management and change management.
• Provides strategic insights and experience particularly in the area of mortgage
servicing and credit provide core skills which the Board requires.
• Experience operating at Executive Management level in a number of organisations
globally.
Marian
Corcoran
Independent Non-
Executive Director
• Broad Executive and Non-Executive leadership and advisory experience having
led strategy development in technology and business transformations, executive
leadership and strategy development.
• Wide-ranging experience in advising and leading transformational programmes
across in multiple industries, including banking.
• Cross-industry skills in stakeholder management, risk management, corporate
governance and technology-enabled transformation benefits the Board as the
Bank’s strategy and change programmes evolves at an ever increasing pace.
Conor Ryan
Company Secretary
• Responsible for advising the Board, through the Chairperson, on all governance
matters.
• Align the interests of different parties around the boardroom table, facilitate
dialogue, gather and assimilate relevant information, and support effective
decision-making.
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
146
Sustainability Statement
PTSB’s Governance Structure
The DMA conducted as part of the CSRD
process to identify material sustainability-
related IROs was finalised during the
second half of 2024. The IROs that were
identified through the process all relate to
topics that the Bank is familiar with, and
many are covered by existing Policies as
outlined in the respective MDR sections.
The Committees that monitor Risks and
Opportunities are outlined below and also
consider the relevant outputs of the DMA
on a go forward basis. While the Bank
considers the important role it plays in
society in the development and delivery
of its strategy, as well as the mitigation
of both financial and non-financial
risks, the definition of formal ‘Impacts’
is new terminology for PTSB. Based on
the DMA outputs, we will review the
opportunity to incorporate sustainability-
related Impacts into the appropriate
governance structures (including updating
its Committee Terms of Reference)
with the view of including the concept
of sustainability-related Impacts, as
appropriate.
This will be supported by the ongoing
delivery of ‘Our Customer Yes’ Checks,
which are designed to help us weigh up
the impact of our decisions and consider
the consequences before we make them.
‘Our Customer Yes’ Checks encourage the
Bank to reflect on the impact of a proposal
or delivery of an initiative through various
different lenses, including sustainability.
The Board is collectively responsible
for the governance of the Bank. Various
Committees assist the Board and
Executive Committee in managing and
monitoring the risks and opportunities
that sustainability (including CR&E risk)
present.
Within the Bank, sustainability is
coordinated and managed at an
enterprise-level via a central Sustainability
Function, with the wider Bank functions
being responsible for managing different
sustainability risks and opportunities.
The PTSB Group Governance
Structure
The Board Committees with sustainability
oversight responsibility can be found
below.
Board Audit Committee (BAC)
The BAC is responsible for overseeing the
process of disclosure and communication
with external stakeholders and competent
authorities, which includes sustainability
disclosures.
Board Risk and Compliance Committee
(BRCC)
The BRCC has delegated responsibility
from the Board to assess the impact
of CR&E risk on the Bank’s overall Risk
Profile. The BRCC has approved and
provides oversight on the execution of
a bank-wide CR&E Risk Implementation
Plan.
Nomination, Culture and Ethics
Committee (NomCo)
The NomCo is the overarching Board
advisory committee responsible for the
review, design, implementation, and
effectiveness of the Bank’s Sustainability
Strategy. A key pillar within the Bank’s
Sustainability Strategy is ‘Addressing
Climate Change and Supporting the
Transition to a Low Carbon Economy’,
which includes a focus on CR&E risk.
Executive Management Oversight
The Executive Committee (ExCo) is the
Senior Management Committee of PTSB
with authority to operate and make
decisions within limits set by the Board.
This will include consideration of the
Bank’s sustainability-related IROs.
The ExCo is the custodian of the Bank’s
collective Strategic Portfolio, Medium
Term Plan (MTP) and Risk Management,
as developed through the annual
Strategic Planning Process (SPP). The
ExCo is the accountable body for the
Bank’s operations, compliance and
performance; defining the organisation’s
organisational structure; ensuring the
adoption, application and maintenance
of all standards set by the Board; and a
forum for bank-wide colleagues and other
functional issues and ensuring that a
robust and resilient operating framework
exists within which PTSB’s activities are
undertaken. The ExCo is the ultimate
management committee responsible for
the development and implementation of
the Bank’s Sustainability Strategy and the
management of CR&E risk.
The ExCo meets frequently to discuss
business strategy, planning, change
management, financial planning,
risk management, operations, and
performance. During 2024, the ExCo met
at regular intervals to receive updates in
relation to sustainability. Meetings took
place at least once per quarter, and more
often as required with updates being
provided as part of scheduled ExCo
sessions.
The management level roles and
responsibilities are outlined below, as is
the detail on the management committees
with sustainability-related responsibilities.
The Chief Executive Officer (CEO) is
responsible for championing PTSB’s
Sustainability Strategy and climate action
agenda. The CEO sits on the Board, is
Chair of the ExCo and attends the NomCo
as requested. The CEO is responsible
for assessing and managing CR&E risks
and opportunities and is a member of the
Sustainability Committee (SusCo).
The Chief Financial Officer (CFO) is
responsible for the Bank’s financial
planning including capital management
and all external reporting and disclosures
for PTSB. The CFO is responsible for
oversight and reporting of climate-related
disclosures. The CFO reports directly
to the CEO and sits on the ExCo and
the Board of PTSB. The CFO is also an
attendee of the BAC, the Committee
who oversee material climate-related
disclosures. The CFO is a member of the
SusCo.
The Chief Risk Officer (CRO) is
responsible for assessing the impact of
CR&E risk on the Bank’s overall Risk Profile
and supports the CEO in overseeing
PTSB’s Sustainability Strategy and
climate action agenda. The CRO attends
the Board to present their monthly CRO
Report, which includes an update on
CR&E risk, is a member of the ExCo and
attends the BRCC, which has delegated
responsibility from the Board to assess
the impact of CR&E risk on the Bank’s
overall Risk Profile. The CRO is a member
of the SusCo.
The Chief Sustainability and Corporate
Affairs Officer (CSCAO) is responsible
for leading the development and
implementation of the Bank’s Sustainability
Strategy in line with regulation and
supervisory expectation, while ensuring
all activity is aligned with the Bank’s
overarching Business Strategy and
Purpose. The CSCAO sits on the ExCo of
the Bank and reports directly to the CEO.
The CSCAO chairs the SusCo.
The Chief Customer and People Officer
(CCPO) is responsible for developing and
implementing key elements outlined in the
Bank’s Sustainability Strategy, for example
the delivery of sustainable finance
products and propositions that support
the Bank’s customers in transition. The
CCPO is a regular attendee of the NomCo
and is a member of the Bank’s ExCo.
PTSB Group Holdings plc - Annual Report 2024
147
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB’s DMA was completed during the
second half of 2024 and identified the
sustainability-related IROs that were
material to the Bank. While the themes
identified are familiar to the Bank, formal
integration of the DMA output into internal
functions and controls will follow the
Bank’s Three Lines of Defence Model as
outlined below. No formal interaction on
policies, actions and targets related to
these outputs was conducted with the
Board or ExCo or their associated Sub-
Committees during 2024. However, the
policies, actions and targets that were
already in existence and overlap with the
IROs are detailed throughout the MDR
sections of this Sustainability Statement.
Each Line of Defence performs its duties
by identifying and assessing sustainability
matters, analysing the relevance of risks,
evaluating the impact on the Bank’s
operations and business and formulating
control measures and response strategies.
The First Line of Defence (1LOD Business
Units and Functions), undertake frontline
commercial and operational activities and
their support function is responsible for
identifying, owning, managing, monitoring,
and mitigating against sustainability-
related risk.
The Second Line of Defence (2LOD Risk
and Compliance Function), ensure that
all sustainability matters are identified,
assessed, measured, monitored,
managed, and properly reported on by the
relevant business units from across the
Bank.
As the Third Line of Defence (3LOD),
Group Internal Audit provide independent
assurance to the Board over the
adequacy, effectiveness and sustainability
of the Bank’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 Bank, in relation to its sustainability
matters.
The composition of the Board and its
sub-committees is reviewed by the
NomCo and the Board annually to ensure
there is an appropriate mix of knowledge,
experience, and skills. This detailed
assessment considers tenure, succession
planning, Board diversity and assessment
of the continued collective suitability of
the Board.
The wide range of knowledge,
experience and skills encapsulated
in the biographies are 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/information
technology (IT), strategy, 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.
The Board has a formal and rigorous
performance review process to assess
the effectiveness of the Board, its
Committees, the Chairperson and
individual Directors. The performance
evaluation is conducted internally on an
annual basis, and externally facilitated
every three years.
The Board regularly reviews the
knowledge, experience and skills of
its membership to ensure they are
aligned with the current, emerging and
future needs of the Bank. Knowledge
of sustainability, and ESG is one of
the lenses considered, and has been
considered as part of Board Training
Sessions during 2024.
Board
CEO
GRC
ExCo
BAC
BRCC
NomCo
ALCo
CustCo
SusCo
GCC
Sustainability Programme
Steering Group
PTSB’s Corporate Governance Structure - Sustainability
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
148
Sustainability Statement
Board and ExCo Training Sessions
Several training sessions were facilitated
during 2024 to support ongoing business
awareness and Director induction,
as well as training and development
requirements. Topics for training sessions
are recommended by the NomCo and
include a balance of technical, governance
and professional development themes.
Training delivered during 2024 included:
• Cyber Security Awareness Training;
• Operational Resilience;
• IRB Capital Model Programme:
Understanding Modelling Part;
• Capital Models Programme Update Part
II;
• Annual Legal and Regulatory Update:
Market Abuse Training and UK
Corporate Governance Code;
• The implications of an effective ICAAP/
ILAAP to the Strategic Planning
Process, Decision Making and Risk
Management/Appetite;
• Anti-money Laundering, Anti-Bribery
and Anti-Corruption Training (AML and
CTF); and,
• Science Based Carbon Emission
Reduction Targets and associated
Carbon Reduction Planning.
In addition to this knowledge, the Bank
engages an external third-party advisory
firm to support ongoing sustainability
upskilling across all management levels,
while providing insight into market trends
and guidance on impending regulation.
The Bank’s material IROs from an ESRS
reporting perspective cover Climate
Change Mitigation, Own Workforce,
Consumers and End-Users and Business
Conduct. The cumulative experience of
the Board covers all aspects of these
topics.
GOV-2 Information provided
to and sustainability matters
addressed by the undertaking’s
administrative, management
and supervisory bodies
The Bank’s DMA was completed during
the second half of 2024 and identified
the sustainability-related IROs that were
material to the Bank. As a result, no formal
interaction on policies, actions and targets
related to these outputs was conducted
with the Board and the ExCo, or their
associated sub-committees, during 2024.
However, the material IROs identified
by the DMA are all topics that are core
to the Bank’s Strategy and as such,
are addressed as part of the existing
governance structures.
The Board, ExCo and members of their
associated Sub-Committees were
engaged in the DMA process as outlined
in ESRS 2 IRO-1. The formal identification
of IROs was validated by the Bank’s SusCo
and shared with the GRC, ExCo and Board
as part of the DMA process and formally
signed off as part of the finalisation of
the Bank’s Sustainability Statement.
The Bank will review its sustainability-
related policies and corresponding
implementation activity as part of its
policy review cycle, as appropriate.
GOV-3 Integration of
sustainability-related
performance in incentive
schemes
At present, the Bank does not have in
place a Variable Pay Scheme (outside of
a commission-based scheme in place in
our Retail Banking Network), and therefore
does not currently have a mechanism to
directly link Executive pay to sustainability
outcomes.
Under the leadership of the Chief
Sustainability and Corporate Affairs
Officer, a Head of Sustainability and
supporting team are in place to manage
and deliver the Bank’s Sustainability
Strategy. Similarly, under the leadership
of the Chief Risk Officer, an Enterprise
Risk Management Team and a Climate
Risk Manager are in place to manage and
deliver all CR&E risk programming.
Specific objectives aligned to the
Bank’s overall Sustainability Strategy
are included within team member
objectives, depending on their role within
the function. Delivery of objectives is
assessed through a formal performance
review process that occurs at regular
intervals throughout the year. Delivering
on strategy, as well as the overall
performance in the role, impacts the level
of monetary base pay increase achieved.
The Bank is at an advanced stage of
design of an enterprise-wide Variable
Pay Scheme. This Scheme will include
the delivery of sustainability factors as a
key metric in determining the appropriate
reward on a collective and individual
basis. Further information on the structure
of the Scheme will be included within the
Bank’s future Sustainability Statements as
it becomes available.
PTSB Group Holdings plc - Annual Report 2024
149
Strategic Report
Governance
Sustainability
Financial Statements
General Information
GOV-4 – Statement on due diligence
Core Elements of Due Diligence
Paragraphs in the sustainability statements
a) Embedding due diligence in governance, strategy and business model
ESRS 2ESRS
2-GOV-2
ESRS 2ESRS
2-GOV-3
ESRS 2-SBM-3
b) Engaging with affected stakeholders in all key steps of the due diligence
ESRS 2-GOV-2
ESRS 2-SBM-2
ESRS 2-IRO-1
ESRS 2-MDR-P
c) Identifying and assessing adverse impacts
ESRS 2- IRO-1
ESRS 2- SBM-3
d) Taking actions to address those adverse impacts
ESRS 2-MDR-A
E1-MDR1-A
E1-MDR2-A
E1-MDR3-A
E1-MDR4-A
S1-MDR1-A
S4-MDR1-A
S4-MDR2-A
G1-MDR1-A
G1-MDR2-A
G1-MDR3-A
e) Tracking the effectiveness of these efforts and communicating
ESRS 2-MDR-M
ESRS 2-MDR-T
E1-MDR1-T
E1-MDR2-T
E1-MDR3-T
E1-MDR4-T
S1-MDR1-T
S4-MDR1-T
S4-MDR2-T
G1-MDR1-T
G1-MDR2-T
G1-MDR3-T
GOV-5 Risk management
and internal controls over
sustainability reporting
The Board Audit Committee (BAC)
oversees the implementation of the Bank’s
financial and internal control policies,
practices and decisions. It aims to align
these with the Bank’s Strategy and
shareholder interests, while operating
within applicable regulatory and legal
requirements. Key responsibilities include:
• Monitoring the effectiveness and
adequacy of internal control, internal
audit, and IT systems, including those
that deal with sustainability-related
matters;
• Reviewing the effectiveness of risk
management procedures;
• Reviewing the integrity of the
Company’s internal financial
controls (including those related to
sustainability), monitoring the integrity
of the financial statements and
sustainability reporting of the Company,
and recommending approval of the
Annual and Interim Reports to the
Board;
• Considering the independence of the
external auditors, and objectivity and
effectiveness of the audit process;
• Monitoring and reviewing the
effectiveness of the Internal
Audit Function, safeguarding the
independence of the Internal Audit
Function and providing oversight of the
function alongside the Head of Internal
Audit;
• Reviewing instances of fraud, violations
of laws and regulations as raised by the
Head of Internal Audit; and,
• Ensuring an integrated approach
to sustainability-related disclosure
preparation and delivery and providing a
link between the Board and the external
auditors who provide assurance on
disclosures, where it’s required.
3. Strategy
SBM–1 Strategy, business
model and value chain
PTSB is one of Ireland’s longest serving
financial services institutions tracing its
operations back more than 200 years
through the savings bank and building
society movements. Throughout this
time, our focus has been on delivering
exceptional customer service and
connecting with local communities. Today,
PTSB is operating in 98 branch locations
nationwide and is a leading provider of
Personal and Business Banking services
focused solely on the Irish Market.
The Bank serves more than one million
customers. As of the 31 December 2024,
PTSB employed 3,457 employees (total
Headcount as of 31st Dec 2024) and
recorded revenues of €1,002m.
The Bank offers a broad range of
banking products and financial services
to its growing customer base including
Current Accounts, Deposits, Residential
Mortgages, Term Lending (Personal and
Business), Credit Cards and Overdrafts.
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
150
Sustainability Statement
Our upstream value chain includes
regulators, investors and shareholders.
Colleagues and suppliers are core to our
operations, while customers and wider
society are significant actors downstream.
Our sustainability related IROs have
considered these value chain actors
throughout the process. The approach to
stakeholder engagement throughout the
DMA process is outlined in IRO-1.
As an organisation, we recognise that
climate change creates financial risks
and economic consequences, and the
cost of inaction is far greater than the
cost of action. Unaddressed, the financial
implications from climate change will likely
impact everyone, from governments to
companies and families in communities
across the country.
As such, managing CR&E risks and
opportunities is a key area of focus for
the Bank under the ‘Addressing Climate
Change and Supporting the Transition
to a Low Carbon Economy’ Pillar of our
Sustainability Strategy. Through this
Strategy, we are working to manage and
mitigate CR&E risk, while also finding
new and innovative ways to help our
stakeholders to navigate the transition to
a low carbon economy through our Green
Product Strategy. For more information on
CR&E risks please refer to E1-MDR3-A and
for more on CR&E opportunities please
refer to S4-MDR1-A.
Permanent TSB Group Holdings plc is a
company whose shares are listed on the
Main Market Stock Exchanges in Dublin
and London. Permanent TSB plc (its
subsidiary) is a licensed bank regulated by
the Central Bank of Ireland.
In line with our Strategy, the Bank's
Business Lending Credit Policy states
that finance must not be provided to
Borrowers that engage in Excluded
Business Activities which the Bank deem
to contribute to irreversible environmental
and/or social harm to society, including
non-renewable energy (for example,
extraction of gas, oil, coal etc.). For more
on our Business Lending Policy, please
refer to ESRS 2- MDR-P.
The Bank does not derive any revenue
from the following sectors: fossil
fuel (coal, oil and gas); coal; oil; gas;
Taxonomy-aligned economic activities
related to fossil gas; chemicals production;
controversial weapons; or, the cultivation
and production of tobacco.
The Bank reports one operating segment
which is in accordance with IFRS 8
‘Operating Segments’.
A representation of PTSB’s value
chain was identified through a series
of workshops with Senior Leaders
representing Business Units from across
the Bank. The final output of this exercise
captured the key activities of the Bank,
namely, Products and Propositions,
Customer Fulfilment Management, and,
Funding Activities. It also identified key
value chain actors related to each activity,
as well as those that were cross cutting
(for example, colleagues and customers).
Each value chain actor was considered
in light of their potential to be a ‘hotspot’
(an actor exposed to the likelihood of
actual and potential impacts) or a ‘key
dependency’ (an actor who generates
risks and opportunities for the undertaking
which may be financially material).
We understand the importance of our role
in Irish society, and as one of Ireland’s
three Pillar Banks, the responsibility that
we have in enabling the financial wellbeing
of our customers and communities.
Our own operations are centered around
our branch network, our colleagues and
third-party suppliers who provide specific
support and services.
In addition to our product offerings
outlined above, we recognise and
embrace the role we play in the
community at both a local and national
level. We have focused on creating a
positive social impact through strong
community partnerships and continuing to
support local communities through PTSB
Community programming.
SBM-2 Interests and views of
stakeholders
We recognise that building strong
relationships with our stakeholders,
and ensuring that we engage with them
regularly, plays a fundamental role in
the delivery of our Business Strategy. It
guides our reporting, allows us to identify
risks 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.
As part of the development of this
Sustainability Statement, the Bank
engaged its stakeholders through the
DMA process. This process ensured that
stakeholders views were considered
in identifying the ESG issues that are
not only material to our business, but
important to our stakeholders.
As part of the DMA the Bank engaged
with the stakeholder groups listed below.
Internal
• Board
• Executive Committee
• Colleagues (including members of the
Senior Leadership Team)
External
• Shareholders
• Brokers
• Retail Customers
• Business Banking Customers
• Asset Finance Customers
• Community Partners
• Oireachtas members
• Industry Influencers
• Media
• Suppliers (including Third Party
Advisory Firms)
Table for presenting information on employee Headcount
Employee Headcount 2024
Number of employees
(Headcount) as of 31st
December 2024
Average number of
employees (Headcount) for
2024
Total employees*
3,457
3,442
* For the purposes of the Sustainability Statement, total employee figures are based on Headcount. The Bank
also reports a Full Time Equivalent (FTE) figure of 3,359.
PTSB employees are all based in Ireland.
PTSB Group Holdings plc - Annual Report 2024
151
Strategic Report
Governance
Sustainability
Financial Statements
General Information
For more information, please refer to
IRO-1. The findings of the DMA were
insightful and will play an important role in
informing the development of a refreshed
Sustainability Strategy for the Bank during
2025. As appropriate, we will look to assess
the effectiveness of this stakeholder
engagement once the Strategy is launched.
Outside of the materiality exercise, we
interact with our 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,
Employee Resources Groups, People
Experience Council and other channels
as appropriate;
• Investors Shareholders – 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 – Political engagement and
communications with the media through
the Corporate Affairs Team, community
partnership and charity engagement
through the Bank’s Community Fund
channels and sponsorship rights
engagement through the Bank’s Brand
and Marketing Team; and,
• Regulators – Regular engagement
including regulatory reporting and other
channels as appropriate.
Nomination, Culture and Ethics
Committee (NomCo)
A key role of the NomCo is to ensure
there is effective engagement with
and participation from the Bank’s key
stakeholders.
Stakeholder relationship owners
across the Bank interact with a variety
of stakeholders at regular intervals
throughout the year and provide regular
updates to the Committee on same.
Key stakeholders for the group include
shareholders, customers, colleagues,
suppliers, society and the Bank’s
regulators.
These updates include information related
to the views and interest of affected
stakeholders, as appropriate.
Voice of the Customer (VOC)
VOC feedback is reported weekly to key
stakeholders covering business functions
across the Bank, including our customer
facing teams, Senior Leadership Team and
Executive Committee.
Speak Freely
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 G1-1.
UK Corporate Governance Code
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.
There are currently a number of ways the
Board engages with the Bank’s workforce and
hears the employee ‘voice’ on an on-going
basis through alternative arrangements to
those set out in the UK Code.
SBM-3 Material impacts, risks
and opportunities and their
interaction with strategy and
business model
PTSB’s material IROs cross several themes as
outlined below. While this is the first time the
Bank has completed an exercise in Double
Materiality, the outputs of the process align
to the areas that we have already prioritised
as part of our wider Corporate Strategy.
ESRS 2 General Disclosures(continued)
Impact Materiality
Financial Materiality
E1
S4
S1
G1
S2
E2
E3
E4
E5
S3
Material Impacts, Risks and Opportunities
E1
Climate Change Mitigation
Own Emissions
Regulatory Risk
Product Financing
Own Operations
E2
E3
E4
E5
Pollution
Water and Marine Resources
Biodiversity and ecosystems
Circular Economy
S1
Own Workforce
Working conditions including
Diversity, Equity and Inclusion,
Collective Bargaining, Adequate
Wages, Health and Safety, Learning
and Development, Remuneration
and Human Rights
S2
S3
Workers in the value chain
Affected Communities
S4
Consumers and End-Users
Housing
Customer Experience
G1
Business Conduct
Sponsorships and Community
Partnerships
Managing Suppliers
Compliance
Note: The position of a topical standard does not denote significance of a standard relative to another in the same quadrant.
Materiality Threshold Indicator
Topics disclosed under ESRS 2
Basis of Preparation
Governance
Strategy and Business Model
Impacts, Risk and Opportunities
Minimum Disclosure Requirements
A sustainability topic that is considered important to PTSB but has not been deemed material based on the outputs of
the Double Materiality Assessment.
Materiality Matrix
PTSB Group Holdings plc - Annual Report 2024
152
Sustainability Statement
The time horizons outlined in the below table align to the time horizons in the DMA as outlined in ESRS 2-BP2.
IRO-Ref
IRO
Upstream/
Downstream
Description
Short
(0-1yr)
Medium
(1-5yrs)
Long
(5+yrs)
Positive or
Negative
Potential or
Actual
E
S
G
MDR Reference
I-1
Impact
Downstream
The impact on the environment by considering
climate change and energy use when financing
projects.
Both
Both
E1
E1-MDR4
(Product
Financing)
I-2
Impact
Downstream
The impact PTSB has on the environment by
reducing emissions, in business operations.
Positive
Both
E1
E1-MDR1
(Own
Emissions)
I-3
Impact
Own
Operations
The impact PTSB has on its employees by ensuring
adequate working conditions, equal opportunities
for all, and protection of worker’s rights.
Both
Both
S1
S1-MDR1
(Working
Conditions)
I-4
Impact
Downstream
The impact on society, and Consumers and
End-Users from failing to implement appropriate
measures to protect customer information and
ensure vulnerable customers avail of PTSB’s
services.
Negative
Potential
S4
S4-MDR2
(Customer
Experience)
I-5
Impact
Downstream
The impact PTSB has on society and Consumers
and End-Users by promoting financial wellbeing and
providing customer supports.
Positive
Both
S4
S4-MDR2
(Customer
Experience)
I-6
Impact
Downstream
The impact on society and the environment due to
the financing of criminal activity.
Negative
Potential
G1
G1-MDR1
(Compliance)
I-7
Impact
Upstream
The impact on society and the environment by
ensuring suppliers are appropriately managed.
Positive
Both
G1
G1-MDR2
(Managing
Suppliers)
I-8
Impact
Downstream
The impact PTSB has on society and local
communities through engaging in community
partnerships, providing charitable donations and
delivering the Bank’s sponsorship rights activity.
Positive
Both
G1
G1-MDR3
(Sponsorships)
PTSB Group Holdings plc - Annual Report 2024
153
Strategic Report
Governance
Sustainability
Financial Statements
General Information
IRO-Ref
IRO
Upstream/
Downstream
Description
Short
(0-1yr)
Medium
(1-5yrs)
Long
(5+yrs)
Positive or
Negative
Potential or
Actual
E
S
G
MDR Reference
O-1
Opportunity
Downstream
Providing sustainable products, propositions and
funding activities which integrate environmental
considerations can provide PTSB with a competitive
advantage, meet customer demand and reduce
PTSB’s impact on the environment.
n/a
n/a
E1
E1-MDR4
(Product
Financing)
O-2
Opportunity
Own
Operations
The opportunity for PTSB to reduce operational
costs and improve its reputation by making internal
investments/decisions that are considerate of the
environment.
n/a
n/a
E1
E1-MDR1
(Own
Emissions)
O-3
Opportunity
Own
Operations
A working environment that has appropriate
working conditions, protects worker’s rights,
promotes inclusion and offers adequate training
and innovation opportunities may lead to increased
productivity, reduce costs and enhanced brand and
reputation.
n/a
n/a
S1
S1-MDR1
(Working
Conditions)
O-4
Opportunity
Downstream
The opportunity for the Bank to enhance its’ brand
and reputation by providing exceptional customer
experience.
n/a
n/a
S4
S4-MDR2
(Customer
Experience)
O-5
Opportunity
Downstream
Providing adequate housing via mortgage financing
for customers across Ireland can lead to an
enhanced reputation and increased market share.
n/a
n/a
S4
S4-MDR1
S4-MDR1
(Housing)
R-1
Risk
Own
Operations
Change Management: The risk arising from inability
of the Bank to manage projects and changes to a
high quality standard and in a timely and controlled
manner, in particular for large and complex change
programmes will not achieve the desired outcomes,
will have a negative impact on resource levels of the
Bank or in case of regulatory based requirements
may result in fines or sanctions.
n/a
n/a
E1
E1-MDR3
(Regulatory
Risk)
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
154
Sustainability Statement
IRO-Ref
IRO
Upstream/
Downstream
Description
Short
(0-1yr)
Medium
(1-5yrs)
Long
(5+yrs)
Positive or
Negative
Potential or
Actual
E
S
G
MDR Reference
R-2
Risk
Downstream
Climate-related and Environmental Risk: The risk
of financial loss or an adverse outcome arising
from the consequences, likelihoods and a lack of
inadequate response to the impacts of climate
change.
n/a
n/a
E1
E1-MDR3
(Regulatory
Risk)
&
E1-MDR4
(Product
Financing)
R-3
Risk
Upstream
Credit Risk: The risk of financial loss due to the
failure of a customer, or counterparty, to meet their
financial obligations to the Bank as they fall due.
n/a
n/a
E1
E1-MDR3
(Regulatory
Risk)
R-4
Risk
Own
Operations
Cyber Security Risk: The risk of unauthorised
access, modification, malicious disruption or use of
IT systems and data from within or outside the Bank
(for example, cyber-attacks).
n/a
n/a
S4
G1
S4-MDR2
(Customer
Experience)
&
G1-MDR1
(Compliance)
R-5
Risk
Upstream/
Own
Operations /
Downstream
Fraud Risk: The risk of losses or unplanned
gains arising from acts intended to defraud,
misappropriate property, circumvent regulations, the
law or company Policy by either an internal party or
external parties or a combination of both.
n/a
n/a
G1
G1-MDR1
(Compliance)
R-6
Risk
Upstream
Outsourcing and Third-Party Risk: The risk
of current or prospective 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 (ICT) systems), including lack of
third party diversification, inadequate business
continuity plans or insufficient monitoring and
oversight of the engagement.
n/a
n/a
G1
G1-MDR2
(Managing
Suppliers)
PTSB Group Holdings plc - Annual Report 2024
155
Strategic Report
Governance
Sustainability
Financial Statements
General Information
IRO-Ref
IRO
Upstream/
Downstream
Description
Short
(0-1yr)
Medium
(1-5yrs)
Long
(5+yrs)
Positive or
Negative
Potential or
Actual
E
S
G
MDR Reference
R-7
Risk
Own
Operations
People Risk: The risk of financial, operational or
reputational damage to the Bank arising from failure
of the Bank to meet its employment obligations
and duty of care to staff or the failure to ensure
adequate resources and or skills are in place, that
succession planning is not effective or that the
operation of the Bank may be impacted by labour
disputes.
n/a
n/a
S1
G1
S1-MDR1
(Working
Conditions)
&
G1-MDR1
(Compliance)
R-8
Risk
Own
Operations
Process and Ability to Execute Risk: Process
and execution risk can significantly impact
PTSB’s operational risk, leading to higher loss
risk, impacting operational resilience, customer
dissatisfaction, a loss of trust and limits the ability
to realise stated ambition (especially against the
risk of optimistic bias in forecasting). Risk is linked
with internal complexity, a high volume of change,
increasing collaboration with third parties and
outsourcing providers, people risk and transition
speed. Making end to end processes more digitally
straight forward is necessary to reduce complexity
and embed/automate controls, and consistent
customer service quality.
n/a
n/a
G1
G1-MDR1
(Compliance)
R-9
Risk
Own
Operations
Regulatory Compliance Risk: 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 change
to, official sector policy, laws, regulations, major
industry standards, compliance policies and
procedures or the expectations or customers and
stakeholders.
n/a
n/a
E1
S1
G1
E1-MDR4
(Product
Financing)
&
E1-MDR3
(Regulatory
Risk)
&
G1-MDR1
(Compliance)
&
S4-MDR2
(Customer
Experience)
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
156
Sustainability Statement
IRO-Ref
IRO
Upstream/
Downstream
Description
Short
(0-1yr)
Medium
(1-5yrs)
Long
(5+yrs)
Positive or
Negative
Potential or
Actual
E
S
G
MDR Reference
R-10
Risk
Own
Operations
Reputational and Conduct Risk: 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 change
to, official sector policy, laws, regulations, major
industry standards, compliance policies and
procedures or the expectations or customers and
stakeholders.
n/a
n/a
E1
E1-MDR4
(Product
Financing)
R-11
Risk
Own
Operations /
Upstream
Service Availability: The risk that the performance
and availability of IT systems and data are adversely
impacted (for example, customer experience or
business processes), including the inability to
recover the Bank's services in a timely manner, due
to a failure or IT hardware or software components;
weaknesses in IT system management; or any other
event.
n/a
n/a
E1
G1
E1-MDR2
(Own
Operations)
&
G1-MDR2
(Managing
Suppliers)
R-12
Risk
Upstream
/ Own
Operations
Business Risk: 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 Bank's strategic
ambitions.
n/a
n/a
E1
E1-MDR4
(Product
Financing)
The Bank is involved in the identified
material impacts through its business
relationships, funding activity and through
its role as a large-scale employer.
At this time, we don’t expect that the
Bank’s identified sustainability-related
risks will result in a material adjustment
to the Bank’s financial position including
carrying amounts of assets and liabilities.
At present, the Bank does not yet formally
use climate-related scenario analysis to
assess business strategy resilience.
An updated CR&E Risk Materiality
Assessment was completed in 2024 that
adopted a forward-looking perspective
using CR&E risk transmission channels
to identify how CR&E risk drivers may
manifest risk across other Risk Categories
as defined in the Enterprise Risk
Management Framework. In addition,
CR&E risk was measured as part of the
Bank’s Operational and IT Risks Pillar 2
Internal Capital Adequacy Assessment
(ICAAP).
For more information on the outputs of the
Bank’s Risk Materiality Assessment and
ICAAP, please refer to E1-1.
All material IROs that have been identified
are disclosed under the ESRS standards.
There are no entity-specific disclosures
included within this Sustainability
Statement.
PTSB Group Holdings plc - Annual Report 2024
157
Strategic Report
Governance
Sustainability
Financial Statements
General Information
4. Impact, risk and opportunity
management
4.1 Disclosures on the
materiality assessment process
IRO-1 Description of the
process to identify and assess
material impacts, risks and
opportunities
Facilitated by an independent Third Party
to ensure confidentiality and impartiality,
the Bank’s DMA process involved the
following process:
An initial sectoral review was completed
to identify potential material sustainability
topics. This review included an industry
benchmarking exercise, as well as an
analysis of regulatory and supervisory
expectations aligned to the ESRS topics
and sub-topics. In addition, a value chain
was developed, challenged, and validated
through a workshop process with
representatives of functions from across
the Bank. Potential ‘hotspots’ and ‘key
dependencies’ were highlighted as part
of value chain workshop process, which
informed the value chain actors engaged
as part of the wider DMA.
The outputs of the sectoral review,
together with value chain ‘hot spots’
and ‘key dependencies’, formed the
basis for an initial longlist of IROs. The
assessment of PTSB’s impacts were
primarily informed by a sectoral review,
which highlighted the actual and potential
impacts on customers, colleagues and
the environment as a result of the Bank’s
financing activities. Considerations
of geography and specific business
relationships were not identified as
likely contributors. This longlist also
incorporated existing resources (for
example, enterprise risk management
registers, strategic roadmaps and
customer insights). Workshops with
subject matter experts (SMEs) from
across the Bank were held to draft,
validate and produce a shortlist of
sustainability related IROs. This shortlist
of IROs formed the basis for stakeholder
engagement.
Fourteen stakeholder cohorts were
engaged through a combination of
surveys, workshops and 1:1 interview
in order to gain an understanding of the importance of the shortlisted sustainability-
related topics to each cohort and provide an opportunity to seek feedback regarding
potential topics that may have been omitted. Internal stakeholders were engaged with
through 1:1 interview, workshops and a bank wide survey, while external stakeholders
were engaged with exclusively through a survey.
The nature of each engagement is outlined below.
Stakeholder
Engagement Method
Internal Stakeholders
Board
Survey
ExCo
Interview
Colleagues
Survey, Workshops
External Stakeholders
Shareholders
Survey
Brokers
Survey
Asset Finance
Customers
Survey
Personal Customers
Survey
Business Customers
Survey
Community Partners
Survey
Industry Partnerships
Survey
Oireachtas
Survey
Industry Influencers
Survey
Media
Survey
Suppliers
Survey
External Experts
Incorporated as part of
advisory services
The results of this stakeholder
engagement exercise were then
integrated with internal stakeholder views
to rank, and ultimately set thresholds to
establish the Bank’s material IROs and
related sustainability topics. Assessment
of sustainability-related matters (including
impacts) sits within the remit of the
Bank’s External Reporting Workstream
within the Sustainability Programme and
established governance fora. The Bank’s
Sustainability Committee is responsible for
final oversight.
Where possible, IROs were assessed by
the Banks’s SMEs using existing criteria.
Risks
Sustainability-related risks were deemed
material if they mapped to an enterprise
level risk, an emerging risk or a material
CR&E risk. The threshold for shortlisting
the material sustainability-related risks
was developed based on this mapping.
Where a longlist sustainability-related risk
was sufficiently related to an enterprise
level risk, an emerging risk or a material
CR&E risk it was deemed material. This
was validated through work with SMEs.
No other thresholds were applied. The
Bank views sustainability-risks as drivers
of its current identified risks, as such
the assessment of sustainability-related
matters falls within the Bank’s Enterprise
Risk Management (ERM) process. In
addition, the Bank conducted a CR&E
Risk Materiality Assessment in 2024.
The decision-making process follows the
Bank’s established governance fora and
is in line with its Three Lines of Defence
Model.
At this time, we don’t expect that the
Bank’s identified sustainability-related
risks will result in a material adjustment
to the Bank’s financial position including
carrying amounts of assets and liabilities.
Impacts and Opportunities
Opportunities were assessed by SMEs
leveraging elements of the Bank’s internal
opportunity evaluation framework.
Impacts were also assessed by SMEs.
Negative impacts were rated and ranked
by considering their relative severity
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
158
Sustainability Statement
(scale, scope and remediation) and
likelihood, while the prioritisation of
positive impacts considered scale, scope
and likelihood using a scoring matrix
developed as part of the DMA process.
During a workshop with SMEs, a threshold
was established based on this scoring
matrix.
Once potential and actual impacts were
ranked, thresholds were applied by the
Bank in order to determine materiality. The
threshold setting process for Impacts and
Opportunities considered the themes that
were deemed to be potentially financially
material taking into account the Bank’s
Enterprise Risk Management Framework,
regulatory expectation, stakeholder
feedback and Risk Appetite. Impacts and
Opportunities were discussed by selected
SMEs within the Bank during facilitated
workshops to determine a final list of
material Impacts and Opportunities.
The process to identify, assess and
manage Opportunities is integrated into
overall management processes through
the Bank’s established governance fora
(please refer to ESRS 2-GOV-1) and
through its annual strategic and financial
planning cycle.
PTSB has in place an overarching three-
year strategic and financial plan - The
Integrated Strategic Plan.
The Plan sets out the core priorities of
the Bank and considers the needs of
our stakeholders. PTSB channels its
investment and efforts into the activity
required to deliver on the strategic
initiatives that have been agreed within
the Plan.
Sustainability is at the heart of the Plan,
enabling us to put it at the centre of
how we run and grow our business. Key
commitments include:
• Embedding consideration for
sustainability into all areas of our
business;
• Meeting sustainability-related regulation
and mitigating against ESG risk;
• Ensuring that our workforce have the
right knowledge and capability to
deliver our sustainability objectives;
• Enhancing mortgage and retrofit
propositions for personal customers;
and,
• Introducing sustainability propositions
for our Business Banking customers.
4.2 Minimum disclosure requirement on policies and actions
MDR-P Policies adopted to manage material sustainability matters
The below table contains the full list and descriptions of the Bank’s Policies and Frameworks that are referenced across the
Sustainability Statement. All Policies and Frameworks are available on the Bank’s Internal Website.
Policy
Description
Accountable for
Implementation
Reference
Adverse
Weather
Policy
PTSB is committed to the support and promotion of Health and Safety
for all our colleagues. In accordance with the Safety, Health and
Welfare at Work Act, 2005 (‘the Act’), PTSB shall ensure, in so far as is
reasonably practicable, a safe and healthy work environment for our
colleagues. We believe that ensuring the safety of our colleagues at all
times throughout their working day is central to the Bank’s core values.
The Bank recognises that there may be times when adverse, and
deteriorating weather conditions can affect the ability to open for
business as well as impacting on the ability of colleagues to travel to
work safely. The Bank will make every effort to maintain normal working
hours during these periods of adverse weather and facilitate working
from home where appropriate. Although such events will be rare, this
Policy has been written to provide guidance should such circumstances
arise.
Head of Shared
Services
ESRS-2-
MDR-P
E1-MDR2
Anti-
Bribery and
Corruption
Policy
The Bank’s Anti-Bribery and Corruption Policy is in place to support
PTSB in effectively managing the risks associated with bribery and
corruption. The Policy aligns with the Bank’s Code of Ethics which
states that ‘Bribery and corruption are unacceptable, and everyone
involved in or dealing with the Group is expected to act honestly and
with integrity at all times’. PTSB’s Anti-bribery and Corruption Policy
complies with the Criminal Justice (Corruption Offences) Act 2018,
which has in turn been informed by The United Nations Convention
against Corruption.
Head of Financial
Crime Compliance
and MLRO
ESRS-2-
MDR-P
S1-MDR1
G1-1
G1-1
G1-MDR1
PTSB Group Holdings plc - Annual Report 2024
159
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Anti-Money
Laundering/
Terrorist
Financing
The Bank’s Anti-Money Laundering/Terrorist Financing Policy sets out
the guidelines and controls adopted by PTSB to ensure appropriate
AML compliance and effective management of money laundering or
terrorist financing risk within the business in line with Bank policy.
Head of Financial
Crime Compliance
and MLRO
ESRS-2-
MDR-P
S1-MDR1
G1-1
G1-1
G1-MDR1
Business
Continuity
Policy
The Bank’s Business Continuity Policy sets out the minimum
requirements necessary to ensure that there is consistent and
continuous management of Business Continuity risk across PTSB
and that roles and responsibilities are clearly assigned for identifying,
assessing, mitigating (including controlling), monitoring and reporting
Business Continuity risk.
To ensure that the Bank identifies, monitors and manages its material
Business Continuity and IT Disaster Recovery risks and regulatory
obligations adequately, the Policy aims to provide the minimum
requirements necessary to ensure that there is consistent and
continuous management of Business Continuity and IT Disaster
Recovery risk across the Bank and that roles and responsibilities for
carrying out the key components are clearly assigned.
Head of
Operational
Resilience and
Payments
ESRS-2-
MDR-P
E1-2
E1-MDR1
E1-MDR2
Business
Lending
Credit Policy
The Business Lending Credit Policy provides guidance on minimum
standards that must be met and applied to all aspects of Business
Lending. This includes consideration of ESG factors and exposure to
Physical and Transition CR&E risk.
The Business Lending Policy states that finance must not be provided
to Borrowers that engage in a list of Excluded Business Activities which
the Bank deem to contribute to irreversible environmental and/or social
harm to society, this includes areas such as non-renewable energy (for
example, extraction of gas, oil or coal), unnecessary deforestation or
the sale of weapons. Meeting the requirements set out in the Policy is a
condition of doing business with PTSB. The Business Lending Policy is
approved by the Board, and delivered via the Bank’s Credit Committee
and delegated authority structures.
In addition, PTSB’s Business Lending Policy requires that all credit
applications include commentary on how ESG factors are likely to
impact the applicant’s future business performance. Governance
arrangements are considered with reference to items such as
compliance with industry standards and tax records.
Chief Credit
Officer
ESRS-2-
SBM-1
E1-2
E1-MDR3
S4-MDR1
Change
Framework
The purpose of the document is to:
• Provide a standard to support a consistent approach for the delivery
of Change across the Bank including the initiation process for new
projects;
• Document the definition of change and categories of change
prioritised as part of the Strategic Planning Process (SPP);
• Outline the Change Governance Process and define clear roles,
responsibilities, and accountabilities for managing Change projects.
Provide an overview of the Stage Gate Process; and,
The framework will support the management of change in PTSB as well
as details of relevant & supporting policies, guidelines, and standards.
Head of Enterprise
Risk
ESRS-2-
MDR-P
E1-
MDR3-P
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
160
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Change Risk
Policy
The purpose of this Policy is to set out, at a high level, the minimum
requirements and approach for the consistent, continuous, and effective
identification and mitigation of Change Risk, including Information
Technology (IT) Change across the Bank. The Policy also sets out clear
accountability and roles and responsibilities including how Risk Appetite
is overseen and controlled.
Head of Non-
Financial Risk
ESRS-2-
MDR-P
E1-
MDR3-P
Climate-
related &
Environmental
Risk
Management
Framework
The CR&E Risk Management Framework, which sits under the
overarching Enterprise Risk Management Framework (ERMF), describes
PTSB’s approach to the management of CR&E risk including setting
out the Bank’s approach to CR&E Risk identification, assessment,
measurement, monitoring, mitigation and reporting.
CR&E Risk, which is defined as a Key Risk Category within the ERMF,
is a cross-cutting risk that may manifest through other relevant Key
Risk Categories, the management of which is maintained through the
individual Risk Management Frameworks under the ERMF.
Chief Operating
Officer
ESRS-2-
MDR-P
E1-2
E1-MDR3
E1-MDR1
Code of
Ethics
The Bank has in place a Code of Ethics that provides a general
framework for expected behavior 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 behavior and minimise
opportunities for misconduct. Complying with the requirements and
principles of the Code is a condition of employment for our colleagues.
Aligned to the introduction of the IAF, from 31st December 2023 it is
also a regulatory requirement of the Central Bank of Ireland as it sets
out the behaviors expected of all colleagues in relation to the Business
Standards, and for those in Control Function and PCF roles the Common
and Additional Standards expected. 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 has in place an industry-wide
DECiDE (Ethical Decision Making) Framework. This was incorporated
into ethics training which is delivered annually to all colleagues. The
DECiDE Framework is communicated across all areas of the Bank and
includes an interactive animation which demonstrated to colleagues
how the Framework can be used within everyday decision making.
At a more strategic level, the Bank also introduced the ‘Our Customer
‘Yes’ Checks’, which now form an integral part of decision making within
the Bank’s Committees.
Chief Customer
and People Officer
ESRS-2-
MDR-P
S1-MDR1
G1-1
G1-3
G1-MDR 3
Collateral
Valuations
Policy
This policy relates to the Valuation of both Residential Properties and
Commercial Properties
for both New Lending and Back Book management.
The policy has been designed to ensure that the Bank’s valuation
standards are:
•
Independent, accurate and reflect current market conditions;
•
Comply with best practice international valuation standards;
•
Include details of the terms of engagement with a valuer; and,
•
Comply with the Capital Requirements Directive (CRD).
Valuation reports are considered key to the lending process, reviewed
and evaluated in a similar manner to other key credit risk and financial
documentation inputs.
The Valuation Report captures BER and Eircode data to aid the
assessment of the mortgage portfolio for CR&E risk.
Chief Credit
Officer
ESRS-2-
MDR-P
E1-MDR3
E1-MDR4
PTSB Group Holdings plc - Annual Report 2024
161
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Colleague
Conduct
Policy
The Bank has in place a Colleague Conduct Policy, an overarching
colleague 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.
PTSB has a zero-tolerance for inappropriate colleague conduct. A
colleague conduct paper is produced and presented to the Board on a
bi-annual basis. The paper 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 several other
documents that encourage appropriate colleague conduct and
behavior, including our Code of Ethics and Speak Freely.
The Colleague Conduct Policy is reflected within the overarching IAF
Conduct Standards Policy. In addition, the Colleague Conduct Policy
considers 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.
Head of People
ESRS-2-
MDR-P
S1-MDR1
S4-MDR1
G1-1
G1-3
G1-MDR1
Community
Fund
Constitution
The Bank’s Community Fund Constitution describes the principles
and practices that the Bank applies when engaging with charitable
organisations. The Constitution sets out the expectations of all
colleagues and provides details of how PTSB engages in charitable
giving, including an overview of the processes that are in place,
governance structures and appropriate due diligence procedures.
Community Fund
Committee Chair
ESRS
2-MDR-P
G1-MDR3
Community
Policy
PTSB’s Community Policy describes the principles and practices the
Bank applies to engage with our community and charity partners in the
most effective way, ensuring that we support local communities across
the country by having a positive and meaningful impact.
Chief
Sustainability and
Corporate Affairs
Officer
ESRS
2-MDR-P
G1-MDR3
Complaints
Charter
The Complaints Charter outlines how complaints are managed within
PTSB.
It provides an overview of:
• Our promise – that customers can be sure that we will deal with their
complaint fairly, courteously and promptly. We will log and investigate
their complaint as quickly and efficiently as possible. We will look at
all the facts of their complaint and all issues raised on the basis of
all the evidence available to us and determine a fair and reasonable
outcome;
• How customers can make a complaint (through contacting
our Open24 Team, utilising our online complaint form, written
correspondence, or visiting a local branch);
• What happens next (how complaints are registered, investigated and
responded to); and,
• What happens if the customer is still not satisfied (what customers
can do if they remain dissatisfied with our response).
Head of Customer
Complaints &
Resolution
ESRS
2-MDR-P
S4-3
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
162
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Complaints
Management
Policy
The Complaints Management Policy consists of two principal
components:
• The process for managing the lifecycle of a complaint from the initial
complaint by a complainant through to resolution; and,
• Analysis of complaints from complainants to identify trends and
improve customer experience and outcomes. The Complaints
Management Policy does not address the Legal Departments
arrangements to respond to legal action or engage with Court
proceedings.
The objectives of the Complaints Management Policy are to:
• Ensure complaints are handled in a speedy, efficient and fair manner;
• Manage complaints effectively within the governance structure set
out in the Complaints Management Framework;
• Deliver the fair outcomes for customers by embedding a customer
focused culture;
• Ensure complaint trends are identified and root cause undertaken in
order to identify emerging and potential Compliance, Conduct Risk
and Operational risk;
• Incorporate lessons learnt from Complaints Management into
the Group (including incorporating into product reviews, product
approvals and design);
• Support RCSA in embedding an enhanced internal control
environment and reduce unnecessary operational losses; and,
• Ensures the Group meets its regulatory obligations with respect to
complaint handling.
The objectives have been developed in accordance with the Bank’s
customer centric strategy, which is to ensure that consideration of the
customers’ best interests is placed at the centre of the organisation’s
decision-making. This focus should highlight the patterns of unfair
customer outcomes and enable proactive steps to prevent these
outcomes from recurring, thereby reducing the number of complaints.
Head of Customer
Complaints &
Resolution
ESRS
2-MDR-P
S4-MDR2
PTSB Group Holdings plc - Annual Report 2024
163
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Conduct
Management
Framework
The Conduct Management Framework describes PTSB’s approach
to risk management of the Conduct Standards under the Individual
Accountability Framework (IAF) and Conduct Risk. Managing of the
IAF Conduct Standards and Conduct Risk helps to ensure that the
best interests of, and fair outcomes for, our customers are considered
which will help build trust with our customers as well as our other key
stakeholders.
The Framework aims to ensure that PTSB acts honestly, fairly and
professionally in the best interests of our customers, the Bank and all
stakeholders, so that:
• The required behaviors for individual staff as well as the wider Bank
(as detailed in the IAF Conduct Standards) are fully understood and
practiced by all applicable stakeholders;
• Our customers can be confident that their best interests are central
to the Bank’s culture;
Our products, services and channels are designed to meet the needs
of identified consumer groups and are targeted accordingly, this
extends to customers that require enhanced support;
• Our customers are provided with clear information and are kept
appropriately informed before, during and after the point of sale;
• Where we provide information, it is suitable and takes account of our
customers circumstances;
• Products will perform, and the associated service is of an acceptable
standard, as the Bank has led customers to expect; and,
Our customers will not face unreasonable post-sale barriers to
change product, switch provider, submit a claim or make a complaint.
Head of
Compliance
ESRS
2-MDR-P
S1-MDR1
G1-1
G1-MDR 1
Conflict of
Interest
A 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.
PTSB has in place a Conflict of Interest Policy to provide guidance
to employees and to ensure that the Bank proactively manages both
personal and organisational Conflict of Interests. Every employee is
responsible for identifying, reporting and managing Conflict of Interests
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.
Head of People
ESRS
2-MDR-P
S1-MDR1
G1-1
G1-MDR 1
Consumer
Non-
Mortgage
Lending
The Consumer Non-Mortgage Lending Policy provides the minimum
standards that must be met when approving a loan. These standards
are applied to all aspects of Consumer Non-Mortgage lending and
act as an overarching policy document that sets out the Bank’s “Core
Lending Principles”.
This Policy ensures that policy approvals and changes to the Bank’s
Consumer Non-Mortgage lending framework are appropriately
recognised, approved and managed. Ensuring a consistent approach to
the assessment of credit applications.
Chief Credit
Officer
ESRS
2-MDR-P
E1-MDR3
E1-MDR4
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
164
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Credit Risk
Management
Framework
The Credit Risk Management Framework (CRMF) for the Bank supports
the overarching RMF and Internal Control Framework (ICF) by detailing
the Bank’s specific approach to Credit Risk Management
PTSB is dedicated to fostering a sustainable future and recognises the
critical role of Environmental, Social and Governance (ESG) factors,
particularly in the context of Climate Change. PTSB is committed to
responsible banking practices including lending with view to proactively
managing associated ESG risks.
Our Credit Risk Management Framework is guided by regulatory
requirements, market sentiments and customer requirements, and is
aimed at understanding and mitigating climate-related risks (Physical
and Transition risk). As the ESG agenda continues to evolve, so too will
our approach to support Bank Risk appetite to ensure we continue to
contribute to a resilient and sustainable financial future, while always
being mindful of Customer impact, in line with our community-based
banking values.
This Framework is intended to promote sound Credit Risk management
across the Bank. It aims to embed and communicate the method
by which PTSB manages Credit Risk, details the key principles,
objectives, and primary components of PTSB’s approach to Credit
Risk management, and distributes Credit Risk responsibilities across
the Bank’s three lines of defence. This includes adherence to the
Data Protection Policy which includes Storage Limitations. Pursuant
to the RMF, the Bank shall manage Credit Risks within the limits and
thresholds established in PTSB’s Risk Appetite Statement (RAS)
approved by the Board. This Framework is aligned with PTSB’s RMF and
applicable regulatory requirements.
Chief Credit
Officer
ESRS
2-MDR-P
E1-MDR1
S4-MDR1
Data
Protection
Data Protection is a fundamental right under the EU Charter of
Fundamental Rights and therefore PTSB safeguards the data protection/
privacy rights of customers and employees. The Bank has a strong data
protection culture in place, including a Data Protection Policy that sets
out PTSB’s policy objectives in respect of the protection of personal
data. The Policy includes the data protection principles, objectives, and
primary components of PTSB’s approach to the management of data
protection risk and sets out responsibilities across the Three Lines of
Defence Model. The scope of this Policy is Bank‐wide, for example, it
applies to all entities and activities within the Bank which involve the
processing of personal data. Adherence to this Policy is mandatory for
all employees, contractors and the Board of Directors.
Data Protection
Officer
ESRS
2-MDR-P
S1- MDR 1
S4- MDR 1
G1- MDR 1
Dignity and
Respect Code
The Code sets out the Bank’s procedures for dealing with allegations
of bullying and harassment and inappropriate behaviours, as laid
within the Code. The Code applies to colleagues while they are both
in the workplace and at work-associated events such as meetings,
conferences and work-related social events, whether on the company's
premises or off-site. It also applies to people that our colleagues may
reasonably expect to come into contact with during the course of their
employment such as customers, clients or business partners.
Head of People
ESRS
2-MDR-P
S1- MDR1
S4-1
PTSB Group Holdings plc - Annual Report 2024
165
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Disciplinary
Procedure
The procedure is to be followed for disciplinary action taken on behalf
of the Company, is in line with the Workplace Relations Commission's
(WRC) Code of Practice on Grievance and Disciplinary Procedures and
takes cognisance of previous cases within the Bank. It ensures that
employees are treated equitably in relation to any complaints about
performance or behaviour and that action is not taken without having
regard to the facts and circumstances of each case.
Head of People
ESRS
2-MDR-P
S1- MDR1
Driving for
Work Protocol
In accordance with the Safety, Health and Welfare at Work Act, 2005,
PTSB must provide, in so far as is reasonably practicable, a safe and
healthy work environment for our employees. Under the Act, a vehicle
used in the course of business is classified as a place of work.
Driving for work is an activity undertaken by employees of the Bank and
as such, poses as a potential hazard to both employees, and other road
users including pedestrians. It is a shared responsibility between the
Bank, and its employees with two main types of legislation applicable
to this activity in Ireland, Road Traffic Acts and the Safety, Health and
Welfare at Work Act, 2005. The purpose of the Protocol is to set out
guidelines for any employee who drives for work along with clearly
defined responsibilities of both the Bank and the driver.
Head of Shared
Services
ESRS
2-MDR-P
E1-MDR1
Employee
Volunteering
Policy
PTSB’s Employee Volunteering Policy describes the principles and
practices the Bank applies to encourage and support employees at all
levels of the organisation to take part in volunteering opportunities in
local communities.
Chief
Sustainability and
Corporate Affairs
Officer
ESRS
2-MDR-P
G1-MDR3
Enhanced
Customer
Support
Policy
The Bank has in place an Enhanced Customer Support Policy that
sets requirements to be adhered across the bank in relation to the
identification, assessment, management, and support for customers
who may require additional support or support with decision-making,
including customers in vulnerable circumstances.
PTSB is dedicated to raising staff awareness in recognising customer
challenges and vulnerable circumstances, understanding that such
circumstances can affect anyone, at any stage in their lifetime, and
providing guidance to staff on how best to secure customer interests in
relation to their interactions with the Bank.
This Policy reflects our commitment to fostering trust, inclusivity,
and compliance with relevant legislation, including CPC and ADMA. It
provides the Bank’s business areas with structured guidance on how to
embed enhanced support measures within their processes, ensuring all
customers can access the financial services, they need, in a way that is
inclusive and responsive to their circumstances.
At the heart of this Policy, are key principles that reflect the Bank’s
commitment to customer care, including proactive identification of
support needs, tailored assistance, where possible depending on
circumstances, and a culture of continuous improvement in how we
serve customers in vulnerable circumstances.
The Policy is overarching and ensures that customers in vulnerable
circumstances are also considered during product and service design
to ensure exceptional customer outcomes, including when in vulnerable
circumstances.
The Policy also ensures that all staff members understand their role
in delivering a consistent and exceptional level of customer care,
especially for customers in vulnerable circumstances.
This Policy is updated and communicated across the bank on a yearly
basis, and it is also included in the bank-wide mandatory training
delivered to all staff.
Chief Retail
Banking Officer
ESRS
2-MDR-P
S4-MDR2
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
166
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Enterprise
Risk
Management
Framework
(ERMF)
ERMF describes PTSB’s overarching approach to enterprise risk
management, forming a critical component of the Bank’s Internal
Control Framework (ICF). The ERMF outlines the structures and
practices that enable the Bank to recognise the economic substance of
all risk exposures and make informed risk-taking decisions. It sets forth
the Bank’s approach to risk governance, risk culture, risk strategy, risk
appetite, risk management processes (including risk identification, risk
assessment & measurement, risk mitigation, risk monitoring & testing,
risk reporting & escalation), risk assurance, and the monitoring and
maintenance of risk data and IT systems. The Framework is further
supported by the Risk Appetite Framework, risk category frameworks,
risk policies, and risk procedures, which collectively guide the Bank’s
risk management practices.
A key component of the ERMF is the Bank’s Risk Categories, which
provide a structured classification of risks faced by the Bank, including
those arising from its revenue-generating activities and those inherent
in its operations and business support functions. These categories
establish a common language for understanding, discussing, and
managing risks across the enterprise, forming the foundation for risk
governance structures and core risk management processes. The Level
1 – Key Risk Categories represent the most significant risk areas that
could materially impact the Bank and include Capital Adequacy Risk,
Liquidity and Funding Risk, Market Risk, Credit Risk, Business Risk,
Operational Risk, Information Technology Risk, Model Risk, Compliance
Risk, Conduct & Reputational Risk, and Climate-Related & Environmental
Risk. Supporting these are Level 2 – Sub-Risk Categories, which provide
a more detailed classification of specific risk types, facilitating targeted
risk management practices and enabling risk aggregation within each
key risk category.
The ERMF is designed to support the Board of Directors and
management in ensuring the financial and operational soundness
of the Bank while enabling the execution of its strategic priorities. It
defines a Three Lines of Defence model, assigning clear ownership
and accountability for risk identification, assessment, measurement,
mitigation, monitoring, and reporting across business units (First Line
of Defence), Group Risk & Compliance (Second Line of Defence), and
Group Internal Audit (Third Line of Defence). The Framework also seeks
to embed a strong risk culture, establish a robust risk governance
structure, and implement sustainable risk management processes that
ensure the timely identification, assessment, and control of current and
emerging risks.
Head of Enterprise
Risk and
Operations
ESRS
2-MDR-P
E1-MDR3
E1-MDR4
Environmental
Policy
Statement
PTSB’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.
Chief
Sustainability and
Corporate Affairs
Officer
ESRS
2-MDR-P
E1-2
E1-MDR1
Equality
through
Diversity and
Inclusion
Charter
The purpose of the Charter is to set out the Bank’s position in terms
of its commitment to promoting equality, through diversity, equity
and inclusion and in challenging discriminatory behaviour together
with setting the supports available for colleagues in promotion and
challenging such behaviour.
Head of People
ESRS
2-MDR-P
S1-MDR1
S4-1
PTSB Group Holdings plc - Annual Report 2024
167
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Financial
Crime
Compliance
Framework
PTSB 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.
PTSB 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.
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, thereafter,
conducting enhanced due diligence reviews and undertaking Politically
Exposed Persons (PEPs) and Sanctions screening in accordance with
our Policies.
Head of Financial
Crime Compliance
and MLRO
ESRS
2-MDR-P
S1-MDR1
G1-1
G1-3
G1-MDR1
G1-MDR 3
Fitness and
Probity Policy
The objective of the PTSB Fitness and Probity Policy is to clearly define
the specific roles, responsibilities and accountabilities across the Bank
in relation to the implementation of Fitness and Probity requirements.
Head of IAF
Governance and
Operations
ESRS
2-MDR-P
S1-MDR1
G1-1
Green Bond
Framework
The Green Bond Framework was established by PTSB, under which
it or any of its subsidiaries can issue green bond instruments, which
may include senior bonds (preferred and non-preferred), subordinated
bonds, green securitisation and medium-term notes to finance (the
‘Green Bond Instruments’) and/or refinance green eligible loans with
a positive environmental benefit. The Framework is based on the
International Capital Markets Association (ICMA) Green Bond Principles
2021, including the updated Appendix I of June 20221.
The Framework is presented through the key pillars of the ICMA
principles 1. Use of Proceeds 2. Process for Project Evaluation and
Selection 3. Management of Proceeds and 4. Reporting.
This Framework will remain under review internally and may from time
to time be updated. The Framework may evolve to account for changes
to the ICMA Green Bond Principles, and any regulatory developments
deriving from the EU Taxonomy or other relevant regulation/legislation.
Head of Debt
Capital Markets
ESRS
2-MDR-P
E1-2
E1-MDR4
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
168
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Green
Product and
Proposition
Design
Principles
The Bank has developed Green Product and Proposition Design
Principles which aim to support the Bank in aligning its Corporate and
Product Strategies to its Science-based Targets (SBTs), and work
to guide, inform and prioritise the development of end-to-end green
product offering(s) over the short to medium-term.
Senior Product
Manager
ESRS
2-MDR-P
E1-2
E1-MDR4
Grievance
Procedure
The Grievance Procedures purpose is to address a colleague’s
grievance and attempt to resolve it, if possible. The Bank recognises
that for many colleagues matters will be resolved informally and locally
with their own management however, at times, it will be necessary to
formally invoke the Grievance Procedures.
Head of People
ESRS
2-MDR-P
S1-MDR1
Group Credit
Policy
PTSB have in place a Group Credit Policy. The policies in place address
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.
The Group Credit Policy takes account of the Group’s Risk Appetite
Statement, applicable sectoral credit limits, the Group’s historical
experience and resultant loan losses, the markets in which the business
units operate, risk outlook 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.
The GCC is responsible for developing, maintaining and overseeing
implementation of credit policy within the Group.
Group credit policy and procedures are designed to comply with the
requirements of relevant regulation.
In setting the Group Credit Policy and Enhanced Customer Support
Policy, careful consideration was given to the interests of key
stakeholders to ensure it addresses their needs and concerns
effectively. This included consultation with relevant subject matter
experts (SMEs) and colleagues to understand their expectations and
the potential impact the policy may have on them.
Chief Credit
Officer
ESRS
2-MDR-P
E1-MDR3
E1-MDR4
S1-MDR1
Group Safety
Statement
The Group Safety Statement is based on the identification of hazards
and assessment of risks and its purpose is to specify the manner in
which the safety, health and welfare at work of employees, and of all
persons who work for or come into contact with the organisation shall
be secured. The Group Safety Statement is the main Health and Safety
Policy that covers the Bank’s employees.
Head of Shared
Services
ESRS
2-MDR-P
S1-MDR3
PTSB Group Holdings plc - Annual Report 2024
169
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Individual
Accountability
Framework
(IAF) Conduct
Standards Policy
The IAF Conduct Standards requires CF role holders to take reasonable
steps to adhere to the standards of conduct that the Bank (and by
extension our customers and the CBI) expect from each of us. PTSB is
obligated to establish, maintain, and give effect to policies on how the
IAF Conduct Standards are integrated into the culture and conduct of
the affairs of PTSB, as well as notify and train in-scope colleagues on
how the IAF Conduct Standards apply to them.
The IAF Conduct Standards Policy sets out the requirements across
PTSB for the embedding of the IAF Conduct Standards. An IAF Conduct
Standards Handbook has been prepared by PTSB which provides
practical support to colleagues in understanding the concept of
reasonable steps and guiding them in understanding the steps that
are reasonable for them to take to uphold the relevant IAF Conduct
Standards.
Head of
Governance,
Conduct and
Planning (Retail
Banking)
ESRS
2-MDR-P
E1-2
S1-MDR1
G1-1
Information
Security
Policy
This Information Security Policy sets out the requirements for the
Bank to manage its information and information technology systems
in a manner that appropriately protects the security of the information
stored and processed in those systems. This includes the requirements
for Bank staff, contractors and suppliers, who access PTSB’s systems
and information, to ensure IT systems are operated in alignment with
Bank’s risk appetite and the legal and regulatory environment that
encompasses Bank activities.
Chief Information
Security Officer
(CISO)
ESRS
2-MDR-P
S1-MDR1
S4-MDR2
G1-MDR1
Learning and
Development
Policy
The purpose of this Policy is to ensure that induction, training and
professional development are planned and delivered to a high standard
consistently throughout the Bank enabling colleagues to perform
effectively in their current role and enabling them to develop their
capability to progress to different and/or more senior roles in the future.
Head of Talent
ESRS
2-MDR-P
S1-MDR1
Liquidity and
Funding Risk
Policy
This Policy details the Bank’s focus on the identification, measurement,
management and monitoring of Liquidity and Funding Risk over an
appropriate set of time horizons. This includes recognition of the
impact of Physical and Transition risks that may impact liquidity and
funding in the future. This document also outlines those activities of
irreversible environmental and/or social harm to society are excluded
from eligibility.
Head of Financial
Risk
ESRS
2-MDR-P
E1-2
Lobbying
Policy
The purpose of the Bank’s Lobbying Policy is to outline the Bank’s
obligations regarding lobbying activities as related to the Regulation of
Lobbying Act 2015 and the Lobbying Amendment Act 2023 (the ‘Acts’).
PTSB is registered as a lobbyist and, as such under the Acts, it must
publish material details of its lobbying activities with certain categories
of Designated Public Officials (DPOs) on the ‘Register of Lobbying’ (the
Register). The Register is publicly available on the Lobbying.ie website
and is maintained by the Standards in Public Office Commission.
Chief
Sustainability and
Corporate Affairs
Officer
ESRS
2-MDR-P
G1-5
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
170
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Operational
Resilience
Framework
The Bank’s Operational Resilience Framework details the Bank’s
structured and systematic approach to managing Operational Resilience
activities, with its key focus of ensuring that the Bank can withstand
severe but plausible situations and recover effectively and efficiently
from major disruptive events.
The Framework sets out high-level requirements to: identify, assess and
manage Critical Business Services to ensure the Bank can respond to
disruptions in line with the agreed Impact Tolerance limits set, set clear
resilience standards, governance and management structures to allow
the key stakeholders to meet their roles and responsibilities effectively
and , continuously improve the operational resilience of the Bank by
identifying vulnerabilities and ensuring remediation to address those
vulnerabilities is completed.
Head of
Operational
Resilience and
Payments
ESRS
2-MDR-P
E1-2
E1-MDR1
E1-MDR2
Our Culture
Charter
Our Culture Charter sets out our Purpose, Values and beliefs that
guide colleague interactions to support the delivery of our Ambition.
It ensures that all colleagues have a consistent understanding of our
culture and the expectations of them, as well as reflecting our evolved
Purpose and Ambition, and our Brand Promise. Our Culture Charter
is reviewed annually under our PR 5 Culture & DEI Reasonable Steps
Approach and is a core cultural artefact for the Bank.
Head of People
ESRS-2-
MDR-P
S1-1
G1-1
Regulatory
Compliance
Framework
The Regulatory Compliance Framework supports the Bank in achieving
its strategic priorities while managing regulatory compliance risks within
the Board-approved Regulatory Compliance Risk Appetite. In addition,
it sets out how the Bank manages current and emerging Regulatory
Compliance Risk (including CR&E risk) and details the key principles,
objectives, and primary components of PTSB’s approach to Regulatory
Compliance Risk Management and sets out Regulatory Compliance Risk
Management responsibilities across the Three Lines of Defence Model.
Head of
Compliance and
Conduct Risk
ESRS
2-MDR-P
E1-MDR3
E1-MDR4
Remuneration
Policy
This Remuneration Policy sets out how the remuneration components
used by PTSB operate. It applies to all remuneration components which
may be received by any employee, director (including non-executive
directors) but excluding any staff seconded from a third party. It applies
across the whole of PTSB including all operations and legal entities.
Head of People
Operations
ESRS
2-MDR-P
S1-MDR1
Reputational
Risk Policy
The purpose of the Bank’s Reputational Risk Policy is to define the
minimum requirements and accountabilities for PTSB employees
with regards to Reputational Risk. The Policy supports the Bank in
understanding the role every colleague plays in impacting the Bank’s
reputation, and the risks associated with same.
Chief
Sustainability and
Corporate Affairs
Officer
ESRS
2-MDR-P
E1-MDR-4
G1-3
Residential
Mortgage
Lending
Policy
The Residential Mortgage Lending Policy provides guidance on
minimum standards that must be met and applied to all aspects of
Residential Mortgage lending. This includes requirements for Retail
Mortgage customers to demonstrate insurance cover for Physical Risk
impacts (for example, flooding and subsidence).
Chief Credit
Officer
ESRS
2-MDR-P
E1-2
E1-MDR3
E1-MDR4
PTSB Group Holdings plc - Annual Report 2024
171
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Policy
Description
Accountable for
Implementation
Reference
Senior Executive
Accountability
Regime (SEAR)
Handbook
SEAR is designed to improve governance, performance and
accountability in Financial Services firms by obliging firms and
colleagues in Pre-Approved Controlled Function (PCF) roles to clearly
document where responsibility and decision-making lie in the firm.
This promotes a culture of accountability within PTSB. The PTSB SEAR
Handbook outlines how SEAR operates within PTSB and sets out the
steps that PCFs, their teams and all relevant stakeholders must take to
manage the obligations under SEAR. The SEAR Regulations include a
number of Prescribed Responsibilities (PRs) which must be allocated
to a PCF role holder. The CEO has allocated PR24 ‘responsibility for
managing financial risks from climate change’ to the CRO under SEAR.
Head of IAF
Governance and
Operations
ESRS
2-MDR-P
G1-1
G1-3
Smart
Working
Framework
The Smart Working Framework aims to bring different types of Flexible,
Smart and Home Working policies under one framework for Colleagues
within the Bank. The Framework outlines PTSB’s Smart Working options
available to employees and how those options can be requested.
It also outlines the factors that influence the approval of requested
Smart Working arrangements and the steps available to employees
if their request is not approved. Aligned to the 2024 Workplace
Relations Commission launch of the ‘Code of Practice for Employers
and Employees Right to request Flexible Working and Right to Request
Remote Working’. PTSB’s Smart Working Framework has been reviewed
to ensure compliance with this Code of Practice.
Head of People
ESRS
2-MDR-P
E1-MDR1
E1-MDR2
S1-MDR1
Sourcing and
Procurement
Policy
The Bank’s Sourcing and Procurement Policy is aimed at providing
an understanding of the process requirements for the purchase of
goods, services or works on behalf of the Bank, to ensure compliance
to internal governance and associated regulations, and to ensure the
selection of the most competitive suppliers based on commercials and
technical capability, aligned to the Bank’s priorities.
Head of Sourcing
ESRS
2-MDR-P
G1-2
G1-MDR 2
Speak Freely
To support the cultural evolution of PTSB, 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.
Head of People
ESRS
2-MDR-P
S1-MDR1
S4-1
G1-2
G1-MDR2
Stakeholder
Engagement
Policy
The Bank’s Stakeholder Engagement Policy encompasses our
overarching approach to stakeholder engagement in PTSB, from who
we identify as our stakeholders, to the processes currently in place
to ensure that they are genuinely involved and considered in key
decisions.
Chief Corporate
Affairs and
Sustainability
Officer
ESRS
2-MDR-P
G1-MDR2
G1-MDR 3
Succession
Planning
Policy
Succession Planning is the process by which PTSB identifies and
develops in a planned manner, the pipeline of individuals whose
performance and potential marks them out as ‘next-in-line’ for specific
roles or levels across the Bank. The objective of the Policy is to
document the standards that apply to the succession planning process
in the Bank.
Head of Talent
ESRS
2-MDR-P
S1-MDR1
Supplier
Relationship
Standards
The Bank’s Supplier Relationship Standards detail the requirements
to staff managing Third Party arrangements, generally described
a ‘Supplier Relationship Management’. The Standards outline the
activities that must be carried out by the business area/or specifically
the identified contract owner to comply with the Third Party Risk
Management Policy and other associated Polices that outline
obligations in relation to Third Party Management.
Head of
Third Party
Management
ESRS
2-MDR-P
G1-MDR2
G1-MDR3
ESRS 2 General Disclosures(continued)
PTSB Group Holdings plc - Annual Report 2024
172
Sustainability Statement
Policy
Description
Accountable for
Implementation
Reference
Sustainable
Supplier
Charter
The Sustainable Supplier Charter sets out the Bank’s expectations of
suppliers and acts as a ‘Code of Conduct’ detailing what is expected
from all suppliers with regard to business practice and responsibilities
as a supplier to PTSB. We have categorised the Charter into the
following 7 core areas, in line with ISO20400 which outline our
expectations of suppliers of PTSB. They include:
• Environmental;
• Human Rights;
• Operating Practices;
• Labour practices;
• Supply Chain;
• Social; and,
• Health, Safety and Wellbeing.
Head of Sourcing
ESRS
2-MDR-P
E1-2
E1-MDR1
G1-2
G1-MDR2
G1-MDR3
Third Party
Management
Framework
The Bank’s Third Party Management Framework provides guidance
relating to the Third Party Management Lifecycle on the necessary
steps for stakeholders planning to engage in Third Party arrangements.
Head of
Operational
Resilience
ESRS
2-MDR-P
G1-MDR2
G1-MDR3
Third Party
Outsourcing
Strategy
The Bank’s Third Party and Outsourcing Strategy is designed to set out
the appetite for outsourcing in line with the Bank’s Business Strategy
and the overall Risk Appetite. The goal is to leverage outsourcing, where
appropriate, to enable the successful delivery of the Bank’s Business
Strategy.
Head of
Operational
Resilience
ESRS
2-MDR-P
G1-MDR2
G1-MDR3
Third
Party Risk
Management
Policy
The Bank’s Third Party Risk Management Policy sets out the
approach and minimum requirements, clear accountability and roles
and responsibilities, for the consistent, continuous, and effective
identification and mitigation of the risks associated with Third Party
(including outsourcing) engagements across the Bank.
Head of
Operational and
IT Risk
ESRS
2-MDR-P
G1-MDR2
G1-MDR3
Minimum Disclosure Requirements
The Bank has outlined additional information based on its material IROs in relation to its Policies, Actions, Metrics and Targets in the
MDR sections Please refer to associated MDR-P, MDR-A, MDR-M and MDR-T sections below.
PTSB Group Holdings plc - Annual Report 2024
173
Strategic Report
Governance
Sustainability
Financial Statements
General Information
ESRS E1 Climate Change
Strategy
E1-1 Transition plan for climate
change mitigation
As of the 31 December 2024, the Bank
does not have a Climate Transition
Plan in place. The Bank will keep the
development of a Climate Transition
Plan under review as part of its wider
Sustainability Strategy in the medium to
long-term.
Following a significant programme of
work, during 2024 the Bank worked to
develop our science-based targets (SBTs)
in line with the Science Based Target
Initiative’s (SBTi) Version 2 Guidance for
Financial institutions. The work included
the development of a corresponding
Carbon Reduction Plan to support us
in achieving our Targets once set. The
Targets and Plan will be submitted to the
Science-based Target Initiative during Q1
2025 for validation. We will communicate
our Targets once the validation process
reaches completion.
The SBTi provide a pathway for
companies to reduce greenhouse gas
emissions, aiming to mitigate the severe
impacts of climate change while ensuring
sustainable business growth. Targets are
deemed 'science-based' when they align
with the latest climate science necessary
to limit global warming to 1.5°C above pre-
industrial levels, as outlined in the Paris
Agreement.
The Bank has already made progress with
respect to its carbon emissions, achieving
a c.15% reduction in Scope 1 and Scope 2
location-based emissions in 2024, when
compared to 2023.
Sustainability is at the heart of PTSB’s
Business Strategy and focuses on putting
Sustainability at the centre of how we
grow and run our business, as well as
manage and mitigate against ESG risk.
Disclosures pursuant to Article 8 of Regulation (EU) 2020/852 (Taxonomy Regulation)
The Bank’s SBTs Programme will be a
key element of our Climate Transition
Plan, while also supporting our future
sustainability reporting commitments.
To address GHG emissions across Scope
1, 2 and 3, the Bank has a number of
initiatives in place aligned to Ireland’s
Climate Action Plan. These include:
Scope 1 decarbonisation levers:
• Sustainable Transport (PTSB internal
factor): The adoption of sustainable
transport. Hybrid vehicles can reduce
CO2 emissions by up to 34% compared
to conventional engines, while
electric vehicles produce zero tailpipe
emissions. As of the 31 December 2024,
PTSB has replaced 56% of its fleet
with hybrid petrol/electric options. The
remaining petrol and diesel vehicles
are due to be phased out between
2025-2030 as part of the Bank’s Fleet
Strategy.
Scope 2 decarbonisation levers:
• Grid Decarbonisation (external factor):
The greening of the National Electricity
Grid in Ireland will support the reduction
of Scope 2 location-based emissions
assuming the Kilowatt hours (kWh)
usage of electricity does not increase
dramatically.
• Building Upgrades (PTSB internal
factor): The Bank continues to
implement LED lighting across our
branch network as part of our ongoing
branch refurbishment process.
• Data Centre Migration (PTSB internal
factor): The Bank has migrated our
data centre to a new and more efficient
building.
• Renewable Electricity (PTSB internal
factor): The Bank currently procures
100% energy certified as renewable
from our electricity provider and
receives a green certificate from the
provider every year. We will continue
this practice across our operations to
maintain our Scope 2 market-based
emissions at 0.
Scope 3 decarbonisation levers:
• Greening of the Electricity Grid (external
factor): Decarbonisation of the National
Electricity Grid in Ireland will contribute
to a c.16% reduction in household
emissions by 2033, which will naturally
reduce Scope 3 financed emissions
associated with PTSB’s Mortgage
Portfolio.1
• Greening of the Housing Stock (external
factor): Government plans equate to
a carbon reduction of c.29%by 2030,
which will have a positive impact on
PTSB’s Mortgage Portfolio.2
• Green Products and Propositions
(PTSB internal factor): PTSB’s Green
Mortgage Product and partnership
with the Strategic Banking Corporation
of Ireland (SBCI) for low-cost home
energy upgrade loans are strategies
for reducing emission intensity
across the Bank’s Mortgage Portfolio.
By expanding these products and
introducing additional incentives, the
Bank can accelerate progress towards
meeting its Scope 3 financed emission
reduction targets.
In accordance with EU Taxonomy
Regulation, PTSB has not elected to
differentiate between capital expenditure
(CapEx) and turnover for the material
Mortgage Portfolio.
In accordance with the EU Paris-aligned
benchmarks exclusion criteria, PTSB has
no exposure to coal, oil, or gas-related
economic activities, with 1% of lending to
non-financial corporates excluded from
these benchmarks.
PTSB confirms that it has identified
counterparties excluded from the EU
Paris-aligned benchmarks, as per the
relevant regulatory criteria. While no
significant testing against the Do No
Significant Harm (DNSH) criteria has been
conducted, 1% of lending to non-financial
corporates falls within this exclusion.
1.
Ireland’s Climate Action Plan 2024 (https://www.gov.ie/en/publication/79659-climate-action-plan-2024/)
2.
Ireland’s Climate Action Plan 2024 (https://www.gov.ie/en/publication/79659-climate-action-plan-2024/)
PTSB Group Holdings plc - Annual Report 2024
174
Sustainability Statement
Material impacts, risks and
opportunities and their interaction
with strategy and business model
During the Bank’s Double Materiality
Assessment (DMA), it identified Climate-
related and Environmental (CR&E) risk as a
material risk.
CR&E risk is a Key Risk Category
defined within the Bank’s Enterprise Risk
Management Framework (ERMF) of which
there are two sub-risk categories, Physical
Risk and Transition Risk. Both sub-risk
types may act as a driver that impacts
the financial services sector to varying
degrees over a range of plausible climate
scenarios, across the short, medium and
long-term.
The Physical and Transition Risk
definitions outlined within the ERMF, for
reference by all Business Units, are as
follows:
Physical Risk
Physical Risk, the risk of economic cost
and financial losses resulting from the
increasing severity and frequency of:
• Acute Physical Risk - arises from
extreme weather events, such
as floods, storms, droughts, and
heatwaves; and,
• Market Risks that arise through
changing demand and supply for
commodities, products and services;
and,
• Reputation Risk that relates to the
changing stakeholder perception
of institutions’ commitments to, or
detraction from, the transition to a
lower-carbon economy.
The impacts of climate change are
predicted to occur over longer time
horizons then the typical cycle of financial
institutions’ analysis and forecasting. To
ensure a meaningful assessment of CR&E
risk a review of existing defined time
horizons within PTSB was conducted,
considering European Central Bank (ECB)
good practice, industry peers and internal
processes, resulting in the below time
horizons being applied within the Bank’s
CR&E Risk Materiality Assessment.
The Bank recognises that the time
horizons that is uses for CR&E risk are
not aligned to the Double Materiality
Assessment (DMA) time horizons
disclosed within the Sustainability
Statement. This is a result of assessment
activities being completed at different
intervals, with some being conducted
earlier in the year.
• Chronic Physical Risk - arises
from longer-term gradual shifts in
climate patterns, such as increasing
temperatures, sea-level rises, water
stress, biodiversity loss, land use
change, habitat destruction and
resource scarcity.
Transition Risk
The risk of economic cost, financial
loss or an adverse outcome related to
the process of adjustment towards a
low-carbon and more environmentally
sustainable economy. Transition to a low-
carbon economy may require substantial
policy, legal, technology and market
changes. These changes may result in
a financial loss and reputational risk to
organisations, with the severity of this
depending on the scope and speed of
change required.
Transition Risk may include:
• Policy Risks that come with the
evolution of policies and regulations
that promote the adaptation to a less
carbon intensive and more sustainable
economy, and those that constrain
actions that lead to climate change and
harm the environment.
• Legal Risks that relate to litigation
claims against institutions and their
representatives who fail to mitigate
and adapt to climate change, and who
fail to disclose material climate and
environmental information;
The time horizons utilised in our assessments are outlined below:
Assessment Time Horizon
Short-term
Medium-
term
Long-term
Double Materiality Assessment
(Sustainability Statement)
0-1 years
1-5 years
5+ years
Climate-Related and Environmental Risk (TCFD Report)
0-3 years
3-5 years
5+ years
At a Group level, Physical and Transition (CR&E) risk are considered through the following time horizons, Short-term 0-3 years,
Medium-term 3-5 years and Long-term 5+ years.
The Bank completed a qualitative CR&E Risk Materiality Assessment in 2023 that served as a key exercise in the assessment of CR&E
Risk and how it may impact upon other Risk Categories of the Bank. In 2024, a quantitative CR&E Risk Materiality Assessment was
completed which contains a detailed review of the potential impacts of CR&E risk upon the Gross Risk Profile of the Bank across the
Key Risk Categories defined in the ERMF.
The assessment included a detailed description of the relevant transmission channels between Physical and Transition Risk drivers
and Risk Categories as defined in the ERMF. It built upon the 2023 assessment by leveraging plausible climate futures as developed
by the Network for Greening the Financial System (NGFS) scenarios and applying quantitative analysis where appropriate.
PTSB Group Holdings plc - Annual Report 2024
175
Strategic Report
Governance
Sustainability
Financial Statements
General Information
At present, the Bank does not yet formally
use climate-related scenario analysis to
assess resilience.
An updated CR&E Risk Materiality
Assessment was completed in 2024 that
adopted a forward-looking perspective
using CR&E risk transmission channels
to identify how CR&E risk drivers may
manifest risk across other Risk Categories
as defined in the ERMF. This assessment
leveraged four plausible climate futures
based on the NGFS scenarios designed
for use in the financial sector and applied
quantitative analysis to material CR&E risk
transmission channels.
During 2024, CR&E risk was measured
as part of the Bank’s Operational and IT
Risks Pillar 2 Internal Capital Adequacy
Assessment (ICAAP). A CR&E Physical
Risk standalone sub-scenario was
assessed through a business disruption
scenario, in respect of non-financial risk
impacts. In addition, the impact of CR&E
risk on the Bank’s Mortgage Portfolio has
been completed by way of sensitivity
analysis based on data as of 31st
December 2023.
In addition, CR&E risk was evaluated
within the Internal Liquidity Adequacy
Assessment Process (ILAAP) during 2024.
Impact, risk and opportunity
management
Description of the processes
to identify and assess material
climate-related impacts, risks and
opportunities
Beyond the DMA the Bank has not
undertaken a formal process to screen
activities to identify actual and potential
future GHG emission sources.
The Bank has assessed its actual
impact on climate change (for example,
its GHG emissions). An overview of
the methodology and outcome of this
assessment can be found in E1-6.
In 2024, a quantitative CR&E Risk
Materiality Assessment was completed.
Please refer to Material impacts, risks
and opportunities and their interaction
with strategy and business model section
above for more information regarding the
assessment.
Additional Physical CR&E risk analysis
was performed on the Bank’s Mortgage
Portfolio, in line with Pillar 3 ESG
disclosure requirements. PTSB first
assessed the most material types of
climate physical risks for its Mortgage
Portfolio, with primary risk types
determined to correspond to coastal,
fluvial and pluvial flooding events.
The Bank has assessed sensitivity to
climate change physical events using
JBA Flood Risk Scores. All collaterals
have been mapped to a geolocation-
based Flood Score that considers the
likelihood, severity, and type of flooding
events under different scenarios and time
periods.
For the completion of Pillar 3 Template 5,
the Bank have considered ‘Very High Risk’
Flood Scores covering the period up to
2050 under the ‘RCP8.5’ scenario (which
forecasts a global temperature increase
of c. 5°C above pre-industrial levels by
2100).
The Bank will continue refining its Physical
Risk definitions, metrics and thresholds
over time as data/techniques continue to
evolve.
The Climate-related Opportunities and
Impacts that were identified as part of the
Bank’s Double Materiality Assessment can
be found in ESRS 2-IRO-1.
At present, the Bank does not yet formally
use climate-related scenario analysis to
identify Transition Risk over the short,
medium and long-term.
Through the embedding of CR&E risk
within the established ERMF structure and
risk categories, CR&E risk is considered
as integrated across the 3LOD model of
risk management. Each line of defence
performs its duties by identifying and
assessing CR&E risks, analysing the
relevance of risks, evaluating the impact
on the Bank’s operations and business
and formulating control measures and
response strategies.
ESRS E1 Climate Change (continued)
The below table provides a description of defined CR&E risk drivers used to structure the identification and attribution of CR&E risk
transmission channels. For the purposes of this exercise, the following definition of CR&E risk transmission channels was used: ‘the
causal impact chains that explain how CR&E Risk drivers give rise to the financial risks faced by PTSB (directly or indirectly).3
ERMF Sub-Risk
Driver
Description
Physical Risk
Acute
Extreme weather events and their impacts such as flooding.
Chronic
Long-term gradual shifts to climate patterns, sea-level rise, temperature rises, and
coastal erosion.
Transition Risk
Policy &
Regulation
Changes to external policy and regulation to support the transition towards a low carbon
economy and other climate impacts.
Technology
Technological advancements that require businesses to adapt to remain competitive or
may improve resilience to climate change.
Behaviour &
Sentiment
Changes to behaviour and sentiment (consumers, investors, suppliers, third parties,
and wider market) that may impact demand for certain sustainable or green products,
services, and performance.
3.
Basel Committee on Banking Supervision, 2021, ‘Climate-related risk drivers and their transmission
channels’ (https://www.bis.org/bcbs/publ/d517.pdf)
PTSB Group Holdings plc - Annual Report 2024
176
Sustainability Statement
The First Line of Defence (1LOD Business Units and Functions), undertake frontline commercial and operational activities and their
support function is responsible for identifying, owning, managing, monitoring, and mitigating against CR&E risk.
The Second Line of Defence (2LOD Risk and Compliance Function), ensure that all CR&E risks are identified, assessed, measured,
monitored, managed, and properly reported on by the relevant Business Units from across the Bank.
As the Third Line of Defence (3LOD), Group Internal Audit provide independent assurance to the Board over the adequacy,
effectiveness and sustainability of the Bank’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
Bank, in relation to CR&E risk.
E1-2 Policies related to climate change mitigation
Policies
Details of the Bank’s Frameworks and Policies and how they address climate change mitigation, energy efficiency and energy certified
as renewable deployment are stated below:
Policy
Climate Change
Mitigation
Energy Certified
as Renewable
Deployment
Energy
Efficiency
Climate-related & Environmental (CR&E) Risk Management Framework
ü
Individual Accountability Framework (IAF) Conduct Standards Policy
ü
ü
ü
Business Lending Credit Policy
ü
Residential Mortgage Lending Policy
ü
Liquidity and Funding Risk Policy
ü
Environmental Policy Statement
ü
ü
ü
Green Product and Proposition Design Principles
ü
Sustainable Supplier Charter
ü
Operational Resilience Framework
ü
Business Continuity Policy (BCP)
ü
Green Bond Framework
ü
For more information on policy contents and objectives, as well as the most senior level role in PTSB accountable for the
implementation, please refer to ESRS 2-MDR-P.
E1-3 Actions and resources
in relation to climate change
policies
Actions
The Bank has allocated resources and
undertaken actions regarding climate
change mitigation as follows and as
outlined in the four E1-MDR-As below.
Where appropriate, climate change
mitigation matters are integrated across
governance mechanisms within the Bank.
A CR&E Risk Management Framework
has been developed that is linked to the
Bank’s ERMF. Throughout 2024, the Bank
has continued to integrate these matters
into relevant policies, as appropriate.
Further to this, the Bank has in place
an overarching three-year strategic
and financial plan for the Bank - The
Integrated Strategic Plan.
The Plan sets out the core priorities of
the Bank and considers the needs of
our stakeholders. PTSB channels its
investment and efforts into the activity
required to deliver on the strategic
initiatives that have been agreed within
the Plan.
For more information on how sustainability
is considered within the Bank’s Integrated
Strategic Plan, please refer to ESRS
2-IRO1.
In addition, the Bank has invested in
resources to deliver on its sustainability
objectives, which includes the
appointment of a Chief Sustainability and
Corporate Affairs Officer and a Head of
Sustainability and supporting team. A
professional services firm is in place to
provide strategic guidance and advisory
support.
The Bank has identified the following
climate change mitigation actions:
Risk Management
The Bank follows a Three Lines of Defence
Model for CR&E risk, as outlined above.
PTSB Group Holdings plc - Annual Report 2024
177
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Sustainability Governance
For more information on Sustainability
Governance, please refer to ESRS 2-GOV-
1.
Emissions Measurement and
Monitoring
PTSB adopts best practice in relation
to the measurement of its carbon
emissions, across Scope 1, 2 and 3 using
the Greenhouse Gas (GHG) Protocol. In
the measurement of the Bank’s Scope 3
(financed emissions) the Partnership for
Carbon Accounting Financials (PCAF),
Financed Emissions Standard is utilised.
Limited assurance is undertaken on the
Bank’s full carbon footprint by the Bank’s
assurance provider.
Setting GHG Emissions Reduction
Targets:
Over the last number of years, we have
continued to focus on improving our data
and have completed a comprehensive
assessment of the Bank’s emissions
across Scope 1, Scope 2 and Scope 3,
including the Bank’s financed emissions.
This has enabled the establishment of
a carbon baseline for the organisation,
by which the Bank’s SBTs have been
developed. PTSB’s carbon baseline has
been established using FY2023 energy
consumption and carbon emissions data.
During 2024, a SBT workstream was
set up within the overall Sustainability
Programme structure. This workstream
was responsible for coordinating
programming and aligning activity across
the organisation, as the Bank worked
to develop its SBTs and corresponding
Carbon Reduction Plan. Please refer to
E1-1 for further information.
Lending Policies
PTSB has in place a Business Lending
Credit Policy which states that finance
must not be provided to Borrowers that
engage in a list of Excluded Business
Activities which the Bank deem to
contribute to irreversible environmental
and/or social harm to society. This
includes areas such as non-renewable
energy (for example, extraction of gas,
oil or coal), unnecessary deforestation
or the sale of weapons. Meeting the
requirements set out in the Policy is a
condition of doing business with PTSB.
PTSB’s Business Lending Policy requires
that all credit applications include
commentary on how ESG factors are likely
to impact the applicant’s future business
performance.
In addition, PTSB has in place a
Residential Mortgage Lending Policy
that outlines the requirement for the
Bank’s Retail Mortgage customers to
demonstrate insurance cover for Physical
Risk impacts (for example, flooding).
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of sustainability-related
activities. PTSB has not disclosed these
figures publicly.
Environmental, Social and
Governance (ESG) Due Diligence
In 2024, the Bank developed and
deployed an ESG Questionnaire (ESGQ),
which includes climate-change mitigation-
related questions for our Business Banking
customers. The ESGQ forms part of
the loan origination procedure for SME
lending. This due diligence facilitates
the Bank’s understanding regarding risks
related to climate change and integration
into its credit and lending decisions.
Product Development
PTSB has in place a Green Mortgage
offering, a 5-Year and 3-Year Fixed Rate
Product available to all new and existing
home loan customers, where their homes
have a confirmed or proposed BER of A1
to B3. The Bank built on the success of its
5-Year Fixed Rate product, by introducing
a 3-Year Fixed option for customers
during 2024.
In addition, the Bank was pleased to be
the first lender to participate in the SBCI’s
Home Energy Upgrade Loan Scheme,
aimed at supporting eligible applicants
who wish to invest and improve in the
energy efficiency of a residential property.
Procurement
Sustainable Sourcing and Procurement is
at the heart of the Bank’s Sustainability
Strategy and ensuring that we purchase
goods and services and engage with
our suppliers in a sustainable way
is fundamental to its delivery. 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. The Framework is supported by
our Sustainable Supplier Charter, which
sets out our expectations of suppliers and
acts as a ‘Code of Conduct’ detailing what
is expected from all suppliers regarding
business practice and responsibilities as a
supplier to PTSB. We have categorised our
Sustainable Supplier Charter into 7 core
areas, in line with ISO20400 which outline
our expectation, including Environmental
matters.
Disclosures
The Bank reports its climate-related
disclosures in line with its supervisory
expectations as part of Pillar 3, TCFD and
the Sustainability Statement. In addition,
the Bank voluntarily discloses through
CDP (formerly the Carbon Disclosure
Project) each year.
In alignment with the EU Taxonomy
requirements, below are the key
performance indicators (KPIs) that reflect
the Bank's commitment to sustainability
through the measurement of Taxonomy-
eligible and Taxonomy-aligned activities.
Green Asset Ratio (GAR)
GAR KPI Stock: This metric represents
the total value of assets or investments
that are classified as Taxonomy-eligible
or Taxonomy-aligned at a specific point in
time. It provides a snapshot of the Bank’s
exposure to economic activities that meet
the criteria set out in the EU Taxonomy,
reflecting the cumulative value of such
activities within the Portfolio.
GAR KPI Flow: This metric captures the
value of new investments or activities
that are classified as Taxonomy-eligible
or Taxonomy-aligned over a defined
reporting period. It highlights the Bank’s
ongoing commitment to supporting
sustainable economic activities and
demonstrates the transition towards
a greener Portfolio by tracking the
inflow of eligible investments during the
reporting cycle. PTSB has in place a
Green Mortgage offering, a 5-Year and
3-Year Fixed Rate Product available to all
new and existing home loan customers,
where their homes have a confirmed or
proposed BER of A1 to B3. The Bank’s
GAR flow considers the Bank’s Green
Mortgage Lending, however, not all
lending categorised as Green would have
met all of the data or technical screening
criteria for full taxonomy alignment as at
the reporting date.
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
178
Sustainability Statement
Main KPIs and Additional KPIs
2024
Total
environmentally
sustainable
assets
KPI **
KPI ***
% coverage (over
total assets)*
% of assets
excluded from
the numerator of
the GAR (Article
7(2) and (3) and
Section 1.1.2. of
Annex V)
% of assets
excluded from
the denominator
of the GAR
(Article 7(1) and
Section 1.2.4 of
Annex V)
Main KPI
Green asset
ratio (GAR)
stock
1854
7.98%
7.98%
6.32%
6.42%
20.82%
Additional
KPIs
GAR (flow)
360
14.80%
14.80%
9.61%
7.48%
35.07%
Trading book
-
-
-
Financial
guarantees
-
-
-
Assets under
management
-
-
-
Fee and
commissions
income
-
-
-
*
% of assets covered by the KPI over banks´ total assets
** Based on the Turnover KPI of the counterparty
*** Based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
Note 1: Fees and Commissions and Trading Book KPIs shall only apply starting 2026. SMEs´ inclusion in these KPI will only apply subject to a positive result of an
impact assessment.
2023
Total
environmentally
sustainable
assets
KPI **
KPI ***
% coverage (over
total assets)*
% of assets
excluded from
the numerator of
the GAR (Article
7(2) and (3) and
Section 1.1.2. of
Annex V)
% of assets
excluded from
the denominator
of the GAR
(Article 7(1) and
Section 1.2.4 of
Annex V)
Main KPI
Green asset
ratio (GAR)
stock
475
2.03%
2.03%
1.68%
6.51%
17.45%
Additional
KPIs
GAR (flow)
110
2.82%
2.82%
2.32%
8.44%
17.49%
Trading book
-
-
-
Financial
guarantees
-
-
-
Assets under
management
-
-
-
Fee and
commissions
income
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach i.e. total covered assets / total assets
* % of assets covered by the KPI over banks´ total assets
** Based on the Turnover KPI of the counterparty
*** Based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
Note 1: Fees and Commissions and Trading Book KPIs shall only apply starting 2026. SMEs´ inclusion in these KPI will only apply subject to a positive result of an
impact assessment.
For the 31 December 2024 disclosure, the Bank has reviewed the book for exposures to nuclear gas related and fossil gas related
activities based on the questionnaire provided in Annex XII Template 1. The Bank has no exposures to these activities as of the 31
December 2024 or 31 December 2023.
For the disclosure, the Bank reviewed the book for exposure based on the below questionnaire provided in Annex XII Template 1.
PTSB Group Holdings plc - Annual Report 2024
179
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Row
Nuclear gas related activities
1.
The undertaking carries out, funds or has exposures to research, development, demonstration and deployment
of innovative electricity generation facilities that produce energy from nuclear processes with minimal waste from
the fuel cycle.
NO
2.
The undertaking carries out, funds or has exposures to construction and safe operation of new nuclear
installations to produce electricity or process heat, including for the purposes of district heating or industrial
processes such as hydrogen production, as well as their safety upgrades, using best available technologies.
NO
3.
The undertaking carries out, funds or has exposures to safe operation of existing nuclear installations that
produce electricity or process heat, including for the purposes of district heating or industrial processes such as
hydrogen production from nuclear energy, as well as their safety upgrades.
NO
Fossil gas related activities
4.
The undertaking carries out, funds or has exposures to construction or operation of electricity generation
facilities that produce electricity using fossil gaseous fuels.
NO
5.
The undertaking carries out, funds or has exposures to construction, refurbishment, and operation of combined
heat/cool and power generation facilities using fossil gaseous fuels.
NO
6.
The undertaking carries out, funds or has exposures to construction, refurbishment and operation of heat
generation facilities that produce heat/cool using fossil gaseous fuels.
NO
Metrics and targets
E1-4 Targets related to climate change mitigation
Targets
As outlined in E1-1, during 2024 the Bank worked to develop our SBTs which will be submitted to the SBTi during Q1 2025 for
validation. We will communicate our Targets once the validation process reaches completion.
The GHG Protocol Corporate Standard was used to calculate the Bank’s carbon footprint. The process involved:
Setting Boundaries:
• PTSB employs the GHG Protocol methodology to establish the organisational boundaries for its greenhouse gas (GHG) inventories.
The calculation of its carbon footprint adopts an operational control approach, allowing PTSB to account for 100% of Scope 1 and
Scope 2 emissions from operations where it has full authority to implement operating policies.
• To effectively define its Portfolio Target Boundary, the Bank has ensured that its targets collectively cover at least 67% of its
relevant activities.4
• PTSB analysed the proportion of its total investment and lending activities to assess these boundaries. The calculation's
denominator includes all ‘Required Activities’ and ‘Optional Activities’, while the numerator consists of activities covered by the
targets. The Bank set boundaries to determine what was in and out of scope for the purpose of target setting in accordance with
the SBTi Framework. Setting boundaries was a critical stage for PTSB to ensure that the correct parameters were used throughout
the process, enhancing efficiency and facilitating obtaining the SBTi validation in a desirable timeframe.
Establishing a baseline for Targets:
• Following a programme of work, the Bank established a carbon baseline for the organisation on which its SBTs have been
developed. The baseline uses FY 2023 energy consumption and associated carbon emissions data to calculate Scope 1, 2 and
3 (Mortgage Portfolio) emissions. Baseline emissions represent the recorded GHG emissions before any reduction strategies are
implemented, serving as a reference point for measuring current and future emission reductions.
ESRS E1 Climate Change (continued)
4.
SBTi’s Version 2 Guidance for Financial institutions
PTSB Group Holdings plc - Annual Report 2024
180
Sustainability Statement
In 2024, the Bank achieved the following GHG Emissions Reductions for Scope 1, 2, and 3 (including financed emissions).
Emission source
Parameters
2023 (tCO2e)
2024
Absolute value
(tCO2e)
% Change
Scope 1
Fuel combustion
841
882
41
5%
Scope 2:
Location-based value
Purchased Electricity
2,217
1,714
-503
-23%
Scope 2:
Market-based value
Purchased Electricity
0
0
0
0%
Total Scope 1 & 2
Location-based value
3,058
2,596
-462
-15%
Total Scope 1 & 2
Market-based value
841
882
41
5%
Scope 3 Emissions
Scope 3 - Category 1
Purchased Goods and Services
19,117
19,586
469
2%
Scope 3 - Category 2
Capital Goods
662
869
207
31%
Scope 3 - Category 3
Other Fuel & Energy
335
317
-18
-5%
Scope 3 - Category 4
Upstream Transportation and
Distribution
1,827
838
-989
-54%
Scope 3 - Category 5
Waste
7
2
-5
-71%
Scope 3 - Category 6
Business Travel
167
272
105
63%
Scope 3 - Category 7
Employee Commuting
5,840
6,024
184
3%
Scope 3 – Category 15*
Financed Emissions
267,865
273,571
5,706
2%
Scope 3 - Total
295,820
301,479
5,659
2%
Combined Emissions
Total Scope 1, 2 & 3
Location-based value
298,878
304,075
5,197
2%
Total Scope 1, 2 & 3
Market-based value
296,661
302,361
5,700
2%
* Scope 3 Category 15 financed emissions include emissions for the Mortgage Portfolio for 2023. For 2024, this figure includes the Mortgage Portfolio and Asset
Finance – Motor Vehicle Loan emissions.
Notes:
•
Total Scope 1, 2, and 3 GHG emissions were previously reported as 345,093 tCO2e in the PTSB Annual Report 2023 The revision in the figure is due to
refinements in data quality and accuracy used in calculating the mortgage portfolio financed emissions.
•
Data was calculated using The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, Revised Edition, (‘GHG Protocol’) methodology and
Partnership for Carbon Accounting Financials (PCAF) Financed Emissions Standard.
•
Emission factors were sourced from DEFRA’s Greenhouse gas reporting: conversion factors 2024, the Commission of Utilities (CRU) 2023, Carbon Cube,
Climatque and Motorcheck.ie.
•
The CarbonCube® uses procurement spend data to calculate carbon emissions. Spend data is categorised, and emissions factors are matched to the
categorised spend to calculate emissions. This data can then be enhanced over time with supplier-specific data, as it becomes available.
•
We adopt the operational control approach on reporting boundaries. In 2024, the data covers 100% of our operations in the Republic of Ireland.
•
All 15 categories of Scope 3 emissions were evaluated, and material categories have been disclosed.
•
Category 15 includes the Bank’s Retail and Commercial Mortgage Portfolio and Asset Finance Motor Vehicle Loans for Personal and Business Banking
customers. Mortgage Portfolio emissions are calculated as a product of Carbon Intensity*LTV*Floor Area. LTV is calculated as (Accumulated Balance
Amount)/(Original Value Amount), generating a value between 0 and 1. Asset Finance Motor Vehicle Loan emissions are calculated as a product of attribution
factor*distance travelled*CO2 Emissions. Attribution factor is calculated as (Outstanding Amount / Total value at origination), generating a value between 0 and
1.
•
Data is subject to estimation and there exists limitations of the accuracy of the data as an input to the estimate. Our approach will continue to evolve in line with
industry developments and as data quality improves.
•
Figures are rounded.
PTSB Group Holdings plc - Annual Report 2024
181
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Detailed carbon emissions calculation methodology:
Scope 1 Emissions Methodology:
Scope 1 includes direct GHG emissions from sources that are owned or controlled by the Bank, such as natural gas combustion and
company owned vehicles.
To calculate the Bank’s carbon emissions (tCO2e) for Scope 1, the Bank used energy use activity data for its Scope 1 emissions
categories. The 2024 emission conversion factors, published by the UK Department for Environmental, Food and Rural Affairs
(DEFRA), was applied to each of the identified emission sources across the organisational boundary.
GHG emissions (tCO2e) = activity data (Unit) * Emissions factor (DEFRA 2024, tCO2e/unit)
Scope 2 Emissions Methodology:
Scope 2 accounts for GHG emissions from the generation of purchased electricity, heat and steam generated off-site. The emissions
are reported using both a location-based method and a market-based method.
Using a location-based approach, the Bank applies the emission conversion factor provided by the Irish Commission for Regulation of
Utilities (CRU).
GHG Emissions (tCO2e) = activity data (Unit) * Emissions factor (CRU 2023, tCO2e/kWh]
For Scope 2 emissions, the Bank procures 100% energy certified as renewable. As a result, the Bank’s Scope 2 emissions using a
market-based approach (emissions the Bank is responsible for through its purchasing decisions) are 0.
Scope 1 and 2
During 2024, we continued to make progress in reducing our Scope 1 and 2 carbon emissions. This has been achieved through the
procurement of 100% energy certified as renewable from 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.
Scope 3 Emissions Methodology
Scope 3 includes all the Bank’s other indirect emissions: Purchased Goods and Services, Capital Goods, Other Fuel and Energy,
Transportation and Distribution, Waste, Business Travel, Employee Commuting (including home working) and Investments (financed
emissions).
As part of our ongoing commitment to reduce our carbon footprint, during 2024, we progressed our data collection processes for our
Scope 3 emissions. Through our partnership with Efficio, we have used the CarbonCube® spend based carbon footprint calculator,
refining the methodology of calculating emissions through detailed classification of spend categories for Purchased Goods and
Services, Capital Goods, Upstream Transportation and Distribution and Business Travel.
For emissions associated with Waste and Water, activity data provided directly from our suppliers is used to calculate emissions. For
Employee Commuting, an employee survey is used to gather responses on our colleagues commuting and work from home habits.
Mortgage Portfolio
Over the past number of years, the Bank has been reporting on its Mortgage Portfolio emissions. Throughout 2024, this process was
streamlined, and further data enhancements have led us to revise our Mortgage Portfolio emissions which constituted 93% of the
Bank’s total Loan Book as of 31 December 2024. The data refinement approach has supported us in the development of our SBTs and
associated Carbon Reduction Plan. We will continue to monitor and measure our Mortgage Portfolio emissions.
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
182
Sustainability Statement
To calculate emissions associated with the Mortgage Portfolio, the Bank used available BER codes that have a kg CO2e/m2 identified,
currently c.22%. To address the gap, a BER proxy process was developed to estimate the BER rating where no valid BER certificate
was available.
This process relies on identifying the property location by matching property addresses to Eircodes and available collateral
characteristics (age, dwelling type, heating fuel type and location) to estimate BERs and kg CO2e/m2.
The proxy methodology stems from the creation of a Lookup Table which is generated using the data sourced externally from the
Sustainable Energy Authority of Ireland (SEAI), which contains a complete list of c.1.2 million properties from the national distribution.
This Lookup Table contains averaged ratings across key characteristic variables present in both datasets. These averages are
what are used to fill in the blanks of unknown data points within the mortgage book and are extrapolated to generate the Financed
Emissions estimate.
Using the standards set by the Partnership for Carbon Accounting Financials (PCAF), the emissions are calculated as follows:
Financed Emissions = Σ(Attribution Factor x Buildings Emissions)
This process resulted in a total estimate for Scope 3 Financed Emissions for the Retail Mortgage Portfolio of 252,817 tCO2e and
Commercial Mortgages of 3,677 tCO2e for 2024., resulting in a 4% reduction in absolute emissions since 2023.
Asset Finance
During 2024, the Bank measured the financed emissions associated with its Asset Finance Motor Vehicle Loans for the first time.
To calculate emissions associated with the Motor Vehicle Loans, the Bank sourced CO2 values for each vehicle measured in grams
per kilometre (g/km) and the average kilometres travelled in the year (segmented by vehicle and fuel types) from external sources,
currently for 60% of the motor vehicle exposure. A proxy value was then used to estimate the emissions for the remaining 40% of the
Portfolio.
This process resulted in a total estimate for Scope 3 Financed Emissions for Asset Finance Motor Vehicle Loans of 17,077 tCO2e for
2024.
E1-5 Energy consumption and mix
Energy Consumption and Mix
The below table outlines the Bank’s energy consumption and mix for 2024.
Energy Source
Unit
Conversion Formula
Activity Data
2024
Energy (MWh)
2024
Natural Gas
kWh
Energy (kWh)/1000
2,156,995
2,157.00
Kerosene
Litres
(Litres x density (MJ/l) /3600
6,500
63.84
Gas Oil
Litres
(Litres x density (MJ/l) /3600
3,664
40.84
Diesel
Litres
(Litres x density (MJ/l) /3600
127,892
1,173.41
Petrol
Litres
(Litres x density (MJ/l) /3600
52,916
538.12
F-Gas (R410A)
kg
(F-Gas in kg x density (MJ/kg))/ 3600
26
0.0016
Electricity
kWh
Energy (kWh)/1000
7,685,694
7,685.69
PTSB’s Scope 2 emissions related to electricity consumption for 2024 is 7,686 MWh (100% energy certified as renewable).
PTSB Group Holdings plc - Annual Report 2024
183
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Energy intensity based on gross carrying amounts
The Bank has undertaken an assessment of climate change Transition Risk: Exposures to GHG-intensive and energy intensive assets
and products.
The Bank’s alignment efforts with the Paris Agreement objectives for a selected number of sectors and the extent to which financial
flows are consistent with a pathway towards low greenhouse gas emissions and climate-resilient development as defined in the Paris
Agreement.
These sectors account for 0.26% of the total gross carrying amounts.
Sector
Portfolio gross carrying amount (Mn EUR)
1
Power
2
2
Fossil fuel combustion
-
3
Automotive
4
4
Aviation
42
5
Maritime transport
4
6
Cement, clinker and lime production
17
7
Iron and steel, coke, and metal ore production
-
8
Chemicals
-
Detailed above are the high impact sectors identified through the Bank’s assessment of climate change Transition Risk: Exposures to
GHG-intensive and energy intensive assets and products. The above reflects gross carrying amounts and not net revenue as required
by the CSR Regulation. The above gross carrying amounts aligns to the Bank’s Pillar 3, Template 3 disclosure.
E1-6 Gross Scope 1, 2, 3 and Total GHG emissions
The below table provides an overview of the Bank’s Gross Scope 1, 2, and Scope 3 emissions (including Scope 3 Financed Emissions)
in metric tonnes of CO2eq.
Emission Scope
2023 (tCO2e)
2024 (tCO2e)
Scope 1
841
882
Scope 2 (Location-based value)
2,217
1,714
Scope 2 (Market-based value)
0
0
Scope 3
295,820
301,479
Total*
298,878
304,075
* Total based on Scope 2 Location-based values
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
184
Sustainability Statement
PTSB will disclose change in the reported emissions on an annual basis, including the emissions related to our upstream and
downstream value chain. The Bank will explain the effect that this change has on the year-to-year comparability of our reported
GHG emissions.
The below table provides an overview of the gross Scope 1 GHG emissions for 2023 (Base Year) and 2024, by activity data and
tCO2e.
Emission source
Unit
Activity Data
2023
2023
(tCO2e)
Activity Data
2024
2024
(tCO2e)
Natural Gas
kWh
1,768,829
324
2,156,995
395
Kerosene
Litres
4,000
10
6,500
17
Gas Oil
Litres
2,907
8
3,664
10
Diesel
Litres
164,051
412
127,892
321
Petrol
Litres
1,460
3
52,916
110
F-Gas (R410A)
Kg
74
84
26
29
Total Scope 1 tCO2e
-
841
-
882
The below table provides an overview of the gross Scope 2 GHG emissions for 2024: Location-based and Market-based values by
activity data and tCO2e.
Emission source
Unit
Activity Data
2023
2023
(tCO2e)
Activity Data
2024
2024
(tCO2e)
Location- based
kWh
9,476,427
2,217
7,685,694
1,714
Market- based*
kWh
9,476,427
0
7,685,694
0
*PTSB's market-based emissions were 0 tCO2e in 2023 due to procurement of 100% energy certified as renewable in 2023. PTSB will continue to commit to
purchasing energy certified as renewable across its operations to maintain Scope 2 market-based emissions at 0
The below table details the sum of Scope 1, 2 and 3 GHG emissions using the Scope 2 location based and market-based values for
2023 and 2024.
2023 (tCO2e)
2024
(tCO2e)
2024
Change
(tCO2e)
2024
% Change
Scope 1
841
882
41
5
Scope 2 (Location-based value)
2,217
1,714
-503
-23
Scope 2 (Market-based value)
0
0
0
0
Scope 3
295,820
301,479
5,659
2%
Total (Location-based value)
298,878
304,075
5,197
2%
Total (Market-based value)
296,661
302,361
5,700
2%
• The Bank has no biogenic emissions of CO2 from the combustion or bio-degradation of biomass to disclose in 2024.
• No removals, or any purchased, sold or transferred carbon credits or GHG allowances have been included in the calculation of
GHG emissions in 2024.
• No activities reported under the EU Emissions Trading System.
PTSB Group Holdings plc - Annual Report 2024
185
Strategic Report
Governance
Sustainability
Financial Statements
General Information
GHG Intensity based on net revenue and Headcount for 2023 and 2024
The below table provides an overview of the Bank’s GHG emissions intensity (total GHG emissions (CO2e per net revenue) for 2023
and 2024.
2023
(tCO2e/€m Rev)
2024
(tCO2e/€m Rev)
Change
(tCO2e/€m Rev)
% Change
Total (Location-based value)/€million Revenue
343.54
303.47
-40.07
-12%
Total (Market-based value)/€million Revenue
340.99
301.76
-39.23
-12%
PTSB’s intensity figures for 2023 and 2024 are based on revenues of €870m and €1,002m respectively.
The below table provides an overview of the Bank’s GHG emissions intensity (total GHG emissions (CO2e per Headcount) for 2024).
2023 (tCO2e/
Headcount)
2024
(tCO2e/
Headcount)
Change (tCO2e/
Headcount)
% Change
Total (Location-based value)/Headcount
89.75
87.96
-1.79
-2%
Total (Market-based value)/Headcount
89.09
87.46
-1.62
-2%
PTSB’s intensity figures for 2023 and 2024 are based on Total Employee Headcount of 3,330 and 3,457 respectively.
E1-7 – GHG removals and GHG mitigation projects financed through carbon credits
PTSB has no GHG removals and storage in its own operations or upstream and downstream value chain to report. PTSB procures
100% energy certified as renewable directly from its electricity provider which is certified by the Commission of the Regulation of
Utilities (CRU) of its use of Guarantee of Origin (GO) certificates.
PTSB has no GHG emission reductions or removals from climate change mitigation projects to report.
PTSB has not made any public claims of GHG neutrality that involve the use of carbon credits.
E1-8 – Internal carbon pricing
PTSB does not apply an internal carbon pricing scheme, for example, the shadow prices applied for CapEX or research and
development investment decision making, internal carbon fees or internal carbon funds.
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
186
Sustainability Statement
E1 Minimum Disclosure Requirements
As part of the development of the Bank’s Impacts, Risks and Opportunities (IROs), themes were identified, and the Minimum
Disclosure Requirements (MDRs) have therefore been consolidated under thematic headings. The four themes under which the Bank
has disclosed its material Environmental IROs are: E1 MDR1 Own Emissions; E1 MDR2 Own Operations; E1 MDR3 Regulatory Risk; and,
E1 MDR4 Product Financing.
E1 MDR 1 - Own Emissions
The IROs reflected in E1 MDR1 are outlined below.
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-2
Impact
The impact
PTSB has on
the environment
by reducing
emissions,
in business
operations.
The Bank’s own operations can impact the environment
in several ways including energy consumption, waste
generation, water usage, transportation, real estate,
technology infrastructure, procurement and through the
supply chain.
PTSB will have tangible and potential direct impacts on the
external environment by reducing emissions through the
decarbonisation of its operations including transitioning
to energy certified as renewable sources, the migration
of services to online channels, and the use of electric
vehicle charging points. Through the implementation of
sustainable water and waste management practices,
including monitoring consumption and adopting
water-saving measures, utilising recycling and waste
management stations, and by screening suppliers for
responsible practices, the Bank will also have tangible and
potential direct impacts on water consumption, resource
use, and waste in its business operations.
The similarities in each of these impacts have been
consolidated based on their shared actual or potential
impact of minimising the Bank’s environmental footprint
and contributing to a more sustainable future.
Positive
Both
O-2
Opportunity
The opportunity
for PTSB
to reduce
operational costs
and improve its
reputation by
making internal
investments/
decisions that are
considerate of
the environment.
PTSB has an opportunity to reduce operational costs and
improve reputation through environmentally considered
internal investments and decisions.
The Bank considered a wide range of related opportunities
including initiatives such as transitioning to energy
certified as renewable sources, improving water and
resource efficiency, implementing circular economy
principles, the digitalisation of external communications,
and a commitment to reduce waste and support
sustainable waste management practices. The extensive
suite of opportunities was consolidated due to their shared
objective of reducing operational costs through optimised
resource and energy management.
Additionally, each action supports PTSB’s alignment with
growing customer expectations surrounding sustainability
and sustainable practices, enhancing brand loyalty.
n/a
n/a
PTSB Group Holdings plc - Annual Report 2024
187
Strategic Report
Governance
Sustainability
Financial Statements
General Information
ESRS E1 Climate Change (continued)
E1- MDR1-P Policies adopted to
manage Own Emissions
The Bank has the following Frameworks
and Policies to address climate change
mitigation, energy efficiency, and
renewable energy deployment.
• Business Continuity Policy
• CR&E Risk Management Framework
• Environmental Policy Statement
• Operational Resilience Framework
• Regulatory Compliance Framework
• Smart Working Framework
• Sustainable Supplier Charter
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
The following Stakeholders are affected:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees, as defined in ESRS S1
Own Workforce;
• Shareholders and Investors; and,
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
The Assets and Liabilities Committee
(ALCo) is a sub-committee of the
ExCo and is responsible for overseeing
pricing decisions. As such, the Bank’s
Green Mortgage was brought through
the Committee for approval prior to
implementation.
The Sustainability Committee (SusCo)
is a sub-committee of the ExCo and is
responsible for the establishment and
oversight of the Carbon Reduction Plan
and associated Policies.
Customer Committee (CustCo) is a sub-
committee of the ExCo and is chaired
by the Chief Retail Banking Officer. The
Committee approves new, and changes
to current, products and services that
are aligned to the Bank’s Sustainability
Strategy which includes consideration
for climate-related sustainable finance
products and propositions.
The Bank has the following commitments
in place:
• PTSB is required to comply with
legislation and regulations relevant
to CR&E risk management, including
from the Central Bank of Ireland (CBI)
and the European Central Bank (ECB).
These include the ECB’s Guide on
Climate-related and Environmental Risk
and the European Central Bank’s Report
on the supervisory review of Banks’
approaches to manage climate-related
and environmental risks;
• The Bank recognises the role it will
play in financing elements of Ireland’s
Climate Action Plan (CAP) provides a
detailed plan for taking decisive action
to achieve a 51% reduction in overall
greenhouse gas emissions by 2030 and
setting the country on a path to reach
Net Zero emissions by no later than
2050. The Bank understands its role in
financing elements of Ireland’s CAP;
• A Board-approved Sustainability
Strategy aligned to the United Nation’s
Sustainable Development Goals (UN
SDGs);
• A commitment to setting SBTs and
developing a corresponding Carbon
Reduction Plan; and,
• PTSB is a supporter of the Task Force
on Climate-related Financial Disclosures
(TCFD) and issued its inaugural TCFD
Report during 2023.
The Bank has considered its value chain
when preparing its Carbon Reduction
Plan, and other relevant Frameworks and
Policies.
Public Communications
Details of sustainability considerations
for PTSB customers can be found on the
Bank’s website. This includes sharing
information on our Green Mortgage
offering, as well as the Bank’s participation
in the SBCI Home Energy Upgrade Loan
Scheme to support customers in their
transition to a low carbon economy.
Additional detail can be found in PTSB’s
Sustainability Strategy 2022-2026 and
Annual Report (which includes our TCFD
disclosure), outlining our commitment
to reducing our GHG Emissions. Both
documents can be found online.
E1- MDR1-A Actions and
resources in relation to Own
Emissions
At PTSB, we know that the use of energy
in our facilities and our Scope 3 financed
emissions are significant contributors to
our overall carbon emissions and that to
reduce our impact on climate change, we
need to address our own energy usage
and enhance our green product offerings
to support our customers.
To achieve reductions in our Scope 1
and 2 emissions associated with energy
use, we are committed to reducing our
overall consumption, while also moving
to low carbon energy sources. In 2024,
we took additional action to minimise the
carbon impact of our operations through
continuing to invest in energy efficiency
initiatives and programming, including:
• Purchasing 100% energy certified as
renewable from our electricity provider
and being provided a green energy
certificate;
• Introducing energy smart metres across
our branch locations to get information
relating to consumption in real time;
• Implementing LED lighting across our
branch network as part of our ongoing
branch refurbishment process; and,
• Completing the migration of our data
centre to a new and more efficient
building.
To achieve reductions in our Scope
3 financed emissions we continue to
advance green product and proposition
development and the provision of support
for customers on their sustainability
journey; including through our Green
Mortgage offering, a 5-Year and 3-Year
Fixed Rate Product available to all new
and existing home loan customers, where
their homes have a confirmed or proposed
BER of A1 to B3. The Bank built on the
PTSB Group Holdings plc - Annual Report 2024
188
Sustainability Statement
success of its 5-Year Fixed Rate product,
by introducing a 3-Year Fixed Rate option
for customers during 2024.
In addition, the Bank was pleased to be
the first lender to participate in the SBCI’s
Home Energy Upgrade Loan Scheme,
aimed at supporting eligible applicants
who wish to invest and improve in the
energy efficiency of a residential property.
PTSB was successful in obtaining €100m
in funding and was the first Bank to launch
the Scheme to the market in April 2024
Information regarding the calculations of
the Bank’s carbon emission values and
corresponding reduction activity can be
found in E1-6.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of Own emission reduction
activity. PTSB has not disclosed these
figures publicly.
E1- MDR1-M Metrics in relation
to Own Emissions
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions:
• The Bank is committed to measuring
and disclosing its carbon footprint
across Scope 1, 2 and 3, including
intensity metrics as well as calculating
and disclosing consumption data
related to energy use;
There is a CR&E risk metric in place that
is monitored following standard reporting
procedures to relevant governance
committees. This metric captures the
energy efficiency of the Mortgage
Portfolio through Building Energy Ratings
(BER). This metric is used to understand
exposure to Transition Risk and the impact
of financed emissions.
PTSB has not disclosed these metrics
publicly.
• c.€875 million in green lending drawn
down during 2024, accounting for 43%
of New Mortgage Lending and +28%
YoY; and,
• Drawdowns associated with the SBCI
Home Energy Upgrade Loan Scheme.
Further information regarding the
methodologies and assumptions behind
the metrics (including the limitations of
the methodologies used) can be found in
E1-1 to E1-7.
E1-MDR1-T Tracking
effectiveness of policies and
actions through targets
As outlined in E1-1, during 2024 the
Bank worked to develop our SBTs which
will be submitted to the SBTi during Q1
2025 for validation. We will communicate
our Targets once the validation process
reaches completion. As we worked to
set our SBTs, bank-wide stakeholder
engagement sessions were conducted
to establish targets, set decarbonisation
pathways, and gather insights that were
fed into the targets and the corresponding
Carbon Reduction Plan.
E1-MDR 2 – Own Operations
The IROs reflected in E1-MDR2 are outlined below.
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-11
Risk
Service Availability Risk
The risk that the performance and
availability of IT systems and data are
adversely impacted (e.g. customer
experience or business processes),
including the inability to recover the
Bank’s services in a timely manner, due
to a failure or IT hardware or software
components; weaknesses in IT system
management; or any other event.
Elements of this risk have
been mapped to the climate
change mitigation subtopic.
These relate to:
• Physical climate risk
of weather events on
the Bank’s operations
including data centres and
branch operations.
• Transition climate
risk as a result of the
transformation of
processes and systems
to meet regulatory
requirements.
n/a
n/a
PTSB Group Holdings plc - Annual Report 2024
189
Strategic Report
Governance
Sustainability
Financial Statements
General Information
E1-MDR2-P Policies adopted to
manage Own Operations
Physical Risk may impact the Bank’s
business operations and may trigger
the Business Continuity Plan (BCP) or
impact IT (data centre vulnerabilities).
This may also impact third party suppliers
depending on the geographical locations
of their supply chain.
The Bank has in place individual Business
Unit Business Continuity Management
(BCM) plans and an Enterprise Incident
Response Plan which consider adverse
weather conditions that may, in some
cases, cause a reduction in operational
capacity.
The following Frameworks and Policies
are in place to support delivery of the
Business Unit BCM plans as well as the
Enterprise Incident Response Plan:
• Operational Resilience Framework
• Business Continuity Policy
• Adverse Weather Policy
• Driving for Work Protocol
• Smart Working Framework
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
These Frameworks and Policies outline
the Bank’s approach to service availability
risk and business continuity. The following
stakeholders are affected by these
policies:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees, as defined in ESRS S1
Own Workforce;
• Shareholders and Investor;
• Business Banking Customers;
• Retail Customers;
• Third party service providers;
• External stakeholders, including
Regulators and Supervisors who require
an overview of the climate-related and
environmental regulatory compliance
management principles, process, and
governance arrangements; and,
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
The Board has overall responsibility for
oversight of the Frameworks and Policies
related to PTSB’s own operations and
operational resilience.
The Operational Resilience Framework
details the Bank’s approach to managing
Operational Resilience across the three
pillars of Identify and Prepare, Respond
and Adapt, and Recover and Learn, and
considers the interests of customers,
colleagues and wider society and the
importance of maintaining delivery of
services.
Annual Training is delivered through
the Operational Resilience eLearning
module in Q1 each year, with additional
BCM training provided to the Incident
Management Team, Exceptional Situation
Management Committee, Heads of
Function, and BCM Coordinators annually.
E1-MDR2-A Actions and
resources in relation to Own
Operations
PTSB has made the following progress
in relation to the management of Service
Availability risk within its Own Operations
across the Bank.
• The Bank’s Business Continuity
Management (BCM) Plan considers
adverse weather conditions that may,
in some cases, cause a reduction in
operational capacity.
• Our Enterprise Incident Response Plan
is driven by a dedicated Resilience
Committee who reviews our preparation
at regular intervals. There is an Adverse
Weather Policy in place that provides
guidelines should such circumstances
arise.
• The Bank has a tiered structure for
dealing with incidents, including
weather-related incidents that could
impact our operations. There is an
Incident Management Team (IMT) in
place, which is made up of the Head
of Functions from across the Bank.
This team has the option to escalate
incidents to the Exceptional Situation
Management Team (ESMT), which is a
subset of the Executive Committee.
• In line with our Operational Resilience
Framework, the Bank complete a
number of scenario tests each year
and in the past, severe weather
scenarios have been used for the
exercise. Learnings from the above are
reviewed and integrated into the Bank’s
BCM planning processes and shared
wider at the Resilience Committee as
appropriate.
• PTSB’s Hybrid Working Programme has
increased the resilience of the Bank’s
operations in recent years, with the
majority of colleagues having the ability
to work from home.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of activity. PTSB has not
disclosed these figures publicly.
E1-MDR2-M Metrics in relation
to Own Operations
PTSB has not disclosed these metrics
publicly.
E1-MDR2-T Tracking
effectiveness of policies and
actions through targets
PTSB has not disclosed these targets
publicly.
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
190
Sustainability Statement
E1-MDR3 - Regulatory Risk
The IROs reflected in E1-MDR3 are outlined below.
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-1
Risk
Change Management:
The risk arising from inability
of the Bank to manage
projects and changes to a
high quality standard and
in a timely and controlled
manner, in particular for
large and complex change
programmes will not achieve
the desired outcomes, will
have a negative impact on
resource levels of the Bank or
in case of regulatory based
requirements may result in
fines or sanctions.
Change Management has been identified as
a Top 10 risk for the Bank. Elements of this
risk have been mapped to the climate change
mitigation subtopic. The Bank will be subject to
challenges when implementing changes to its
operational processes and IT systems to fulfil
strategic change projects and meet changing
regulatory requirements associated with the
transition to a low carbon economy.
n/a
n/a
R-2
Risk
Climate-related and
Environmental Risk (CR&E):
The risk of financial loss or
an adverse outcome arising
from the consequences,
likelihoods and a lack of or
inadequate response to the
impacts of climate change.
CR&E risk has been mapped to the climate
change mitigation subtopic. CR&E risk for the
Bank is categorised into Physical and Transition
risk.
The Bank identified a number of elements
pertaining to CR&E risk, including adverse
weather conditions and long term climate shifts
causing a reduction in operational capacity;
strategy amendments, including climate
change mitigation ambitions, governmental
initiatives, credit risk and exposures to issues
with commercial and retail borrower repayment
ability; current and emerging climate-
related and environmental (CR&E) regulatory
requirements and compliance costs; IT risk
management; CR&E model risk; market risk and
public and investor opinion of ESG; and changes
to collateral impacting liquidity and funding.
n/a
n/a
R-3
Risk
Credit Risk:
The risk of financial loss due
to the failure of a customer,
or counterparty, to meet their
financial obligations to the
Bank as they fall due.
Credit Risk has been mapped to the climate
change mitigation subtopic. Within the topic of
climate change mitigation, the Bank identified a
number of factors as contributing to credit risk.
These include the types of properties financed;
emerging regulation affecting industries with
poor sustainability credentials; climate change
impacting economic growth and energy prices;
exposure of individuals and their income to
climate risks; increased exposure to climate
risk within the SME and commercial financing
portfolio and technological changes resulting in
reduced payment capacity and inability to meet
loan requirements.
n/a
n/a
PTSB Group Holdings plc - Annual Report 2024
191
Strategic Report
Governance
Sustainability
Financial Statements
General Information
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-9
Risk
Regulatory Compliance Risk:
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 change
to, official sector policy, laws,
regulations, major industry
standards, compliance
policies and procedures
or the expectations of
customers and stakeholders.
Elements of this risk have been mapped to
the climate change mitigation Subtopic. CR&E
risk continues to increase in prominence
globally resulting in additional supervisory and
regulatory requirements for the Bank. The Bank
considers these sustainability regulations as
adding to its regulatory compliance risk.
n/a
n/a
E1-MDR3-P Policies adopted to
manage Regulatory Risk
The Bank is committed to ensuring it
manages and monitors its Regulatory
Risk, Credit Risk, CR&E Risk and Change
Management practices appropriately. To
support this commitment the Bank has
implemented the following policies.
• Enterprise Risk Management
Framework
• Regulatory Compliance Framework
• Credit Risk Management Framework
• PTSB Business Lending Policy
• Group Credit Policy
• Collateral Valuations Policy
• Enterprise Risk Management
Framework
• Personal Lending Policy Consumer Non-
Mortgage Lending
• Residential Mortgage Lending Policy
• CR&E Risk Management Framework
• Change Framework
• Change Risk Policy
• Sourcing and Procurement Policy
• Third Party Risk Management Policy
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
Regulatory Compliance Risk, Credit Risk,
CR&E Risk and Change Management
Risk stakeholder groups within the Bank
include the following:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees, as defined in ESRS S1
Own Workforce;
• Shareholders and Investor;
• Business Banking Customers;
• Retail Customers;
• Third party service providers;
• External stakeholders, including
Regulators and Supervisors who require
an overview of the climate-related and
environmental regulatory compliance
management principles, process, and
governance arrangements; and,
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
Regulatory Risk, Credit Risk and
CR&E Risk
The Board has overall responsibility for
oversight of regulatory risk, including the
regulatory risk associated with CR&E risk.
The Head of Regulatory Compliance
and Conduct Risk is responsible for
the implementation of the Regulatory
Compliance Framework.
The Bank’s Three Lines of Defence Model
and function activities are outlined in
ESRS 2-GOV1.
The Bank is committed to complying with
European and local CR&E risk regulatory
requirements. This includes complying
with legislation and regulations relevant to
Climate Risk and CR&E risk management,
including from the Central Bank of Ireland
and the European Central Bank.
By promoting transparency, fairness, and
due diligence in credit assessments, the
Bank fosters trust and accountability,
enhancing customer confidence and
reducing the likelihood of defaults. This
approach supports a sustainable credit
environment, contributing to long-term
financial stability for both the Bank and its
customers.
The Bank demonstrates a strong
commitment to transparency and
accountability by actively respecting
a range of third party standards and
initiatives through its Policies. In addition,
we are 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. PTSB’s 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.
Change Management
The Board is collectively responsible for
the governance of the Bank and approves
the Bank’s Strategy and the associated
financial plans, of which the Three Year
Strategic Change Roadmap and In Year
Investment Plan are key components.
Enterprise Change provide Board with
monthly reporting on the performance of
the In Year Change Portfolio, highlighting
Portfolio performance (for schedule and
cost) and individual project exception
reports aligned to overall Change risk.
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
192
Sustainability Statement
To support the above, PTSB has in
place a Group Expenditure Committee,
Prioritisation and Intervention Forum,
Management Design Authority, and a
Business and IT readiness Forum made up
of key stakeholders from Business Units
across the Bank. These Committees and
Forums meet at regular intervals and are
in place to provide oversight of the Bank’s
Change Management activity.
E1-MDR3-A Actions and
resources in relation to
Regulatory Compliance Risk,
Credit Risk, CR&E Risk and
Change Management
Regulatory Compliance Risk
To ensure the effective implementation of
the Regulatory Compliance Framework,
the Bank continues to engage with
external information sharing forums,
including the Banking and Payments
Federation of Ireland, through which it
shares and receives information related
to Regulatory Compliance Risk trends
and threats and evolving industry best
practice.
Credit Risk
The Bank’s Credit Risk management
approach is focused on detailed credit
assessment at initial underwriting stage
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 defaulting.
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 Bank's Credit Risk management
actions include our Credit Policies
lending authorization, Credit Risk
mitigation, Credit Risk monitoring, arrears
management and forbearance and
Credit Risk measurement. They cover
a wide range of activities across the
entire lending process. These actions
primarily affect PTSB customers alongside
colleagues who are responsible for
lending or Credit Risk management. These
measures will be continuously reviewed
and updated to ensure their ongoing
effectiveness in mitigating risks and
adapting to evolving market conditions.
CR&E Risk
The Bank has outlined its actions in
relation to the identification, measurement
and management of CR&E risk in E1-1.
Change Management
Over the last of year, the Bank has
proactively reviewed of our enterprise
change maturity and has continued to
make progress:
• Enhancing our Stage Gate process,
whereby we continued to drive
organisational adoption through the
delivery portfolios;
• Leveraging the refreshed Corporate
Strategy to drive a three year strategic
change planning horizon;
• Extending planning horizon and
ambition in alignment with that of the
Corporate Strategy;
• Furthering our strategic planning,
utilising an enhanced Strategic Planning
Process (SPP) to create an interlock
between change, workforce shape,
technology, data and the associated
capabilities, investment cost and
benefits;
• Evolving our agile-based Digital Change
Model, an area of significant priority,
combined with the more traditional
waterfall oriented Change Model;
• Implementing a Project Portfolio
Management (PPM) tool;
• Continuing to review the Operating
Model investments across the Bank,
in recognition of the capacity and
competency required to ensure
excellence in the leadership and
execution of change delivery, advocacy
and benefits realisation; and,
• Improving Change and Risk culture
and underlying practices, by ensuring
focused enhancement around
Lessons Learned practices, increased
2LOD project level engagement, risk
awareness and assurance.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated to
the delivery of this Regulatory Risk, Credit
Risk, CR&E Risk and Change Management
activity.
PTSB has not disclosed these figures
publicly.
E1-MDR3-M Metrics in relation
to Regulatory Compliance Risk,
Credit Risk, CR&E Risk and
Change Management
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions
towards managing the Regulatory
Compliance Risk:
• Regulatory Compliance Risk may arise
from our ability to adapt or comply
with climate-related regulations. PTSB
has no appetite for not implementing
regulatory changes in full and on time.
In addition, the Bank has a medium
appetite for CR&E risk.
• Progress against these metrics is
reported upward to GRC/ExCo/Board on
a monthly basis via the CRO Report.
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions
towards managing Credit Risk:
• Credit Risk Appetite Metrics and Limits
are designed to align with the strategic
objectives of the Bank to maintain
stable earnings growth, stakeholder
confidence and capital adequacy.
• The Bank sets concentration limits
for higher risk product and business
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 and regulatory and
economic landscape, to ensure the
Bank 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 of 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.
PTSB has not disclosed these metrics
publicly.
PTSB Group Holdings plc - Annual Report 2024
193
Strategic Report
Governance
Sustainability
Financial Statements
General Information
E1-MDR4- Product Financing
The IROs reflected in E1-MDR4 are outlined below.
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-1
Impact
The impact on the
environment by
considering climate
change and energy
use when financing
projects.
The influence of the Bank on environmental impacts
extends through the financing and investment
decisions it makes.
Based on PTSB’s material Mortgage Portfolio (93%
as of 31 December 2024), it was determined that
its actual or potential impact on the environment
from its financing activities was primarily on climate
change and energy use through the associated
emissions and energy consumption of the collaterals
on the Retail Mortgage Portfolio. Through the Double
Materiality Assessment, impacts specifically related
to water consumption, (pollution) and biodiversity
were deemed not material at this time although these
factors can be influenced through a broader focus on
climate change and energy usage.
Both
Both
O-1
Opportunity
Providing
sustainable
products,
propositions and
funding activities
which integrate
environmental
considerations
can provide PTSB
with a competitive
advantage, meet
customer demand
and reduce PTSB’s
impact on the
environment.
Banks have a unique opportunity to finance
sustainable products and integrate environmental
considerations into their offerings. These
opportunities not only align with global sustainability
goals but also create new business opportunities,
enhancing the bank’s long-term profitability and
reputation.
The Bank considered a number of opportunities from
new and enhanced green products and propositions
including green bonds, loans, mortgages and
asset finance, retrofitting loans, renewable energy
investments, and strategic partnerships for climate
adaptation and sustainability projects. Collectively,
sustainable products provide the Bank with an
opportunity to address growing customer and
investor demand.
n/a
n/a
ESRS E1 Climate Change (continued)
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions
towards managing CR&E Risk:
• Please refer to E1.
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions
towards Change Management:
• Key Performance Indicators based on
level of Projects with a status of At Risk
and Off Track from a Strategic Change
Portfolio and Regulatory specific
perspective;
• Cost and forecast spend for the period
versus available investment funding set
out for the period; and,
• Forecast Compliance Status of all
material Change projects versus
regulatory deadline commitments.
PTSB has not disclosed these metrics
publicly.
E1-MDR3-T Tracking
effectiveness of policies and
actions through targets
Regulatory Compliance Risk - PTSB has
no appetite for regulatory non-compliance
and is committed to ensuring strict
adherence to laws, standards, and ethical
practices.
PTSB has not disclosed these targets
publicly.
PTSB Group Holdings plc - Annual Report 2024
194
Sustainability Statement
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-2
Risk
Climate-related
and Environmental
Risk (CR&E):
The risk of
financial loss or an
adverse outcome
arising from the
consequences,
likelihoods
and a lack of
or inadequate
response to the
impacts of climate
change.
CR&E risk has been mapped to the climate change
mitigation subtopic. CR&E risk for the Bank is
categorised into Physical and Transition risk.
The Bank identified a number of elements pertaining
to CR&E risk, including adverse weather conditions
and long term climate shifts causing a reduction in
operational capacity; strategy amendments, including
climate change mitigation ambitions, governmental
initiatives, credit risk and exposures to issues with
business and retail borrower repayment ability;
current and emerging CR&E regulatory requirements
and compliance costs; IT risk management; CR&E
model risk; market risk and public and investor
opinion of ESG; and changes to collateral impacting
liquidity and funding.
n/a
n/a
R-9
Risk
Regulatory
Compliance Risk:
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
change to, official
sector policy, laws,
regulations, major
industry standards,
compliance policies
and procedures or
the expectations
or customers and
stakeholders.
Elements of this risk have been mapped to the
climate change mitigation subtopic. CR&E. risk
continues to increase in prominence globally resulting
in additional supervisory and regulatory requirements
for the Bank. The Bank considers these sustainability
regulations as adding to its regulatory compliance
risk.
n/a
n/a
R-10
Risk
Reputational and
Conduct Risk:
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 change
to, official sector
policy, laws,
regulations,
major industry
standards,
compliance
policies and
procedures or the
expectations or
customers and
stakeholders.
E1: Climate Change Mitigation
Elements of this risk have been mapped to the climate
change mitigation subtopic. In relation to reputational
risk these pertain to growing demand to make
progress in integrating ESG factors; expectations to
align with government initiatives and comply with
regulations where failure to make progress can lead
to negative public opinion. Conduct risk emerges
for the Bank in relation to its practices; and meeting
its ethical business requirements and customer
expectations.
n/a
n/a
PTSB Group Holdings plc - Annual Report 2024
195
Strategic Report
Governance
Sustainability
Financial Statements
General Information
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-12
Risk
Business Risk:
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 Bank's
strategic
ambitions.
Elements of this risk have been mapped to the
climate change mitigation subtopic.
Regarding physical risk, the Bank considers these
associated risks to include customers concentrated
in high Physical Risk areas. Regarding transition risks,
these include planning, cost and resources related to
emerging and future regulation, impacts on customer
finances and changes in consumer preferences.
n/a
n/a
E1-MDR4-P Policies adopted to
manage Product Financing
The Bank has in place policies to manage
and mitigate its climate-related product
financing and associated IROs as follows:
• Collateral Valuations Policy
• Consumer Non-Mortgage Lending
• Enterprise Risk Management
Framework
• Green Bond Framework
• Green Product and Proposition Design
Principles
• Group Credit Policy
• Residential Mortgage Lending Policy
For more information on policy contents,
objectives, the most senior level in
the undertaking’s organisation that is
accountable for the implementation of the
policy and policy availability please refer
to ESRS 2-MDR-P.
These Frameworks and Policies cover
PTSB’s enterprise operations and apply
to the organisational functions and risk
management practices of the Bank’s
Three Lines of Defence, as defined in
PTSB’s ERMF.
The following Stakeholders are affected:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees, as defined in ESRS S1
Own Workforce;
• Shareholders and Investor;
• Business Banking Customers;
• Retail Customers;
• Third Party suppliers;
• External stakeholders, including
Regulators and Supervisors who require
an overview of the climate-related and
environmental regulatory compliance
management principles, process, and
governance arrangements; and
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
These Frameworks and Policies detail
relevant requirements and exclusions
such as the exclusion of environmentally
harmful activities from loan eligibility, the
requirement for Business Banking lending
of sufficient scale to complete a Business
Bank ESG Due Diligence Questionnaire
(ESGQ), and the requirement for
the Bank’s Mortgage customers to
demonstrate insurance cover for Physical
Risk impacts (for example, flooding).
The Board has overall responsibility for
the establishment and oversight of the
Bank’s ERMF and Credit Risk Management
Framework.
The ALCo is a sub-committee of the
ExCo and is responsible for overseeing
pricing decisions. As such, the Bank’s
Green Mortgage was brought through
the Committee for approval prior to
implementation.
Customer Committee (CustCo) is a sub-
committee of the ExCo and is chaired
by the Chief Retail Banking Officer. The
Committee approves new, and changes
to current, products and services that
are aligned to the Bank’s Sustainability
Strategy which includes consideration
for climate-related sustainable finance
products and propositions.
Framework and Policy Owners are
accountable for the implementation of
their respective Frameworks and Policies.
Please refer to E1-MDR1-P for the third
party standards or initiatives that the Bank
is committed to.
The Bank’s customers are a central focus
when considering the IROs associated
with its Green Products and Propositions.
In addition, the Bank’s investors,
regulators and other shareholders
(Government) are key stakeholders when
considering the IROs associated with the
Bank’s funding activities.
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
196
Sustainability Statement
E1-MDR4-A Actions and
resources in relation to Product
Financing
PTSB has made the following progress
in relation to the integration of CR&E risk
across the Bank:
• Investing in resources to deliver on our
Sustainability Programme objectives,
including the appointment of a Chief
Sustainability and Corporate Affairs
Officer, a Head of Sustainability and
supporting team;
• Partnering with a professional services
firm to provide strategic guidance and
advisory support;
• Closing the Bank’s 2023 CR&E
Implementation Plan and supporting
ongoing integration of CR&E risk
into the Bank’s wider Sustainability
Programme through an ESG Risk
Management Workstream and
corresponding ESG Risk Management
Strategy;
• Completing a quantitative Materiality
Assessment to provide the first
quantitative analysis of material CR&E
risk transmission channels;
• Updating the Risk Appetite Statement
(RAS) with relevant metrics for CR&E
risk (including Physical Risk) and
developing strategic Key Performance
Indicators (KPIs). Risk metrics
are included within the standard
governance reporting procedures with
corresponding escalation processes.
- The relevant metric related to
exposure to chronic Physical Risk
measures coastal erosion risk
through coastal flood scores. This is
supported through geo-location data
collected through the loan origination
process.
- The relevant metrics related to
the impact of financing upon the
environment and climate relates to
collecting energy efficiency (BER)
information of the Mortgage Portfolio.
This is supported by ongoing data
remediation and is a requirement as
part of loan origination;
• Implementing mitigation and control
processes to manage CR&E risk with a
‘Three Lines of Defence’ Model adopted
across the Bank to ensure robust and
fit for purpose CR&E risk oversight and
management;
• Issuing its inaugural €500m Green Bond
to fund green assets;
• Continuing to integrate CR&E risk into
the Bank’s ICAAP and ILAAP processes
in line with supervisory expectation;
• Continuing to evolve CR&E data
requirements and improve the data
availability and quality for use in
scenario analysis, stress testing,
strategy and reporting;
• Taking steps to understand, manage
and mitigate Physical CR&E risk,
including exposure to chronic risk.
Within the Retail Mortgage Portfolio,
for new Mortgage applications the
BER and Eircode are being captured,
where available. This has allowed the
development of metrics to monitor the
exposure to coastal erosion (chronic
Physical Risk), and the energy efficiency
of the Bank’s Mortgage Portfolio;
• Continuing to advance green product
and proposition development and the
provision of support for customers on
their sustainability journey through
our Green Mortgage Product and
participation in the SBCI’s Home Energy
Upgrade Loan Scheme;
• Developing and introducing an
enhanced ESG Due Diligence
Questionnaire (ESGQ) for our Business
Banking Customers. The ESGQ forms
part of the loan origination procedure
for SME lending for applications of
€250,000 and above. It aims to support
us in gathering data and information on
potential sustainability-related risks and
opportunities across the value chain,
while also ensuring that they adhere to
national and European sustainability-
related regulatory requirements. The
information captured as part of this
ESGQ provides insight into exposure to
chronic Physical Risk (coastal erosion)
and impact upon the environment
through emissions information;
• Ensuring lending officers consider
CR&E risk for each Business Banking
Lending application, and assessment
criteria for new Retail Property Lending
and incorporate an evaluation of
potential Physical Risk, 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; and,
• Providing CR&E risk training to relevant
colleagues, including the Board and
Senior Management.
Moving forward, the Bank is focused
on continuing to mature its approach to
sustainability-related risk management,
green product and proposition
development and disclosures. In addition,
we will continue to monitor and develop
the relevant CR&E risk indicators with a
view to assessing their potential impact on
the Bank’s Market Risk Profile over time.
PTSB has in place an overarching three-
year strategic and financial plan for the
Bank - The Integrated Strategic Plan.
Sustainability is at the heart of the Plan
enabling us to put it at the centre of how
we run and grow our business.
In addition to the investment into
resources, as part of PTSB’s annual
strategic and financial planning cycle, a
budget is allocated to the Sustainability
Function to deliver on the commitments
and actions that are outlined within the
Bank’s Sustainability Strategy, including
the provision for third party advisory and
support.
During Q2 2024, PTSB issued €500m
Green Senior HoldCo notes at a coupon
of 4.25%. The issuance had a final order
book of €2.2bn, comprising of 120
investors. The Green Bond was issued
under the Bank’s Green Bond Framework
and demonstrates our intent to embed
Sustainability into our funding strategy. A
key component of the Bank’s Sustainability
Strategy, the Green Bond Framework
has been established to help mitigate
climate change through reduced carbon
emissions and energy demand, protect
vulnerable ecosystems, and support the
strategic outcomes of Project Ireland
2040, the United Nation’s Sustainable
Development Goals and Ireland’s Climate
Action Plan.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated to
the delivery of these activities. PTSB has
not disclosed these figures publicly.
For more information the Banks’
action related to Green Products and
Propositions please refer to E1-MDR1-A.
PTSB Group Holdings plc - Annual Report 2024
197
Strategic Report
Governance
Sustainability
Financial Statements
General Information
E1-MDR4-M Metrics in relation
to Product Financing
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions:
There is a CR&E Risk metric in place that
is monitored following standard reporting
procedures to relevant governance
committees. This metric captures the
energy efficiency of the Mortgage
Portfolio through Building Energy Ratings
(BER). This metric is used to understand
exposure to Transition Risk and the impact
of financed emissions. The BER metric
uses a proxy score for those properties
where a validated BER is not available
based on property characteristics outlined
by the Sustainable Energy Authority of
Ireland. PTSB has not disclosed this metric
publicly.
• During 2024, c.€875m in green lending
was drawn down, accounting for 43% of
New Mortgage lending, +28% YoY; and,
• During 2024 €100m in funding was
made available to drawdown through
the SBCI’s Home Energy Upgrade Loan
Scheme
• Lending is measured annually.
E1-MDR4-T Tracking
effectiveness of policies and
actions through targets
As outlined in E1-1, during 2024 the
Bank worked to develop our SBTs which
will be submitted to the SBTi during Q1
2025 for validation. We will communicate
our Targets once the validation process
reaches completion.
Targets relating to lending activity include:
• The Bank has a lending target in place
associated with its Green Mortgage
Product; and,
• The Bank has a target in relation to
drawdowns associated with the SBCI’s
Home Energy Upgrade Loan Scheme.
PTSB has not disclosed these targets
publicly.
ESRS E1 Climate Change (continued)
ESRS E1 Climate Change (continued)
PTSB Group Holdings plc - Annual Report 2024
198
Sustainability Statement
For the purposes of this disclosure:
• Employees: Employees are defined as
individuals under a direct contract of
employment in the Bank (permanent
and fixed-term contract employees).
• Non-Employees: PTSB considers
non-employees to be those that do not
have a direct contract of employment
with the Bank. This includes third party
advisory services, contractors, agency
partners and self-employed individuals.
The Bank’s colleagues which may be
subject to the impact caused by adequate
working conditions, equal opportunities
for all and protection of worker’s rights
include:
• Permanent colleagues – Customer
Facing
• Permanent colleagues – Non-Customer
Facing
• Fixed-term contract colleagues –
Customer Facing
• Fixed-term contract colleagues – Non-
Customer Facing
• Part-time – Customer Facing
• Part-time – Non-Customer Facing
As part of the Bank’s DMA, we identified
the material impacts, risks and
opportunities in relation to Own Workforce
which have been outlined in ESRS 2 SBM-
3. Further detail is provided in S1-MDR1
below.
PTSB delivers a full-service banking
experience to all customers, framed within
the boundaries of a Low Risk Appetite.
Our Business Model is a full-service Retail
and Business Bank. As PTSB exclusively
provides financial services to customers
in a regulated environment and operates
in the Republic of Ireland, which is not
considered to be an ‘at risk’ geographic
area that is prone to incidents labour
breaches, there is no significant risk of
child labour, forced labour or compulsory
labour.
People with particular characteristics,
those working in particular contexts, or
those undertaking particular activities
may be at greater risk of harm were not
specifically identified as part of the DMA
but were considered as part of the Bank’s
colleague cohort as a whole.
Following our assessment of material
risks and opportunities related to impacts
and dependencies on our workforce, no
specific cohort was identified as being
uniquely affected.
Impacts, risks and
opportunities management
S1-1 Policies related to own
workforce
The Bank has policies, procedures and
codes in place to manage the material
IROs related to Own Workforce as outlined
in ESRS 2-MDR-P. Further detail is
provided in S1-MDR1.
We recognise our responsibility to respect
the human rights of every individual.
PTSB has procedures in place to support
the Bank in meeting all relevant human
rights legislation in the Republic of Ireland
in respect to Own Workforce. Additional
policies utilised to prevent or mitigate
against the risk and negative impact on
human rights are included in G1-Business
Conduct and S1-MDR1. We keep our
policies under review and update them as
required as part of our policy review cycle.
The Bank has in place a 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 states that employees
should be treated with dignity and respect
in the workplace.
In order to mitigate against human rights
risk, or violations that may occur, the Bank
has due diligence procedures in place
This includes the implementation of a
Colleague Conduct Policy that establishes
the requirements for the effective
management of appropriate behaviours
within the Bank, procedures to support
the Bank in meeting all relevant human
rights legislation in the Republic of Ireland
and a suite of reporting mechanisms
through our Speak Freely channels.
Procedures are in place for dealing with
reported human rights allegations and
instances to ensure they 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 a Conflict of
Interest Policy, Anti-Money Laundering/
Terrorist Financing, Sanctions, and
Anti-Bribery and Corruption policies and
procedures.
The Bank uses the following engagement
channels with its employees:
• Trade Unions/Employee Representative
Bodies (ERBs), including Unite, Mandate
and FSU;
• Employee surveys;
• Team meetings;
• Virtual and in-person networking
forums;
• Internal Intranet platform;
• A bank-wide communications platform
and app;
• In-house digital screens,
• People Experience Council (PEC);
• Employee Resource Groups (ERGs);
and,
• Other channels as appropriate.
For more information on how the Bank
listens to employees and acts on
feedback, as well as the detail relating to
PTSB’s Speak Freely procedure, please
refer to S1-MDR1.
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
As PTSB exclusively provides financial
services to customers in a regulated
environment and operates in the Republic
of Ireland, which is not considered to be
an ‘at risk’ geographic area that is prone
to incidents labour breaches, there is
no significant risk of child labour, forced
labour or compulsory labour. As such,
PTSB does not have policies which
explicitly address human trafficking,
forced labour or compulsory labour and
child labour. We keep our policies under
review and update them as required as
part of our policy review cycle. We will
continue to monitor the human rights
environment to ensure it does not become
a material risk for the Bank.
PTSB has a Group Safety Statement
in place which documents how the
ESRS S1 – Own workforce
Sustainability Statement
PTSB Group Holdings plc - Annual Report 2024
199
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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 Safety Statement
is reviewed on a regular basis and is
revised as necessary. For more on the
Group Safety Statement, please refer to
S1-MDR1.
The Bank is committed to fostering a
workplace that is free from discrimination,
harassment, and bias, ensuring that all
employees have the opportunity to thrive
in an inclusive environment.
Through the implementation of our Dignity
and Respect Code and Equality through
Diversity and Inclusion Charter, alongside
our Colleague Conduct Policy we aim to
eliminate discrimination, promote equal
opportunities, and ensure a diverse and
inclusive workforce. PTSB’s Equality
through Diversity and Inclusion Charter
celebrates and values the diversity of its
workforce and is committed to a fair and
inclusive culture. It provides an overview
of how we treat all colleagues with
dignity and respect and seek to provide
a positive working environment that is
free from discrimination, harassment, or
victimisation.
1. We have developed the ‘Our Culture
Charter’ as our guiding compass, which
brings together the core elements which
make up our culture, what we want our
culture to be, as well as the 12 culture
enablers that support our journey. The
Bank’s culture ambition is to have a
customer-centric, open, inclusive, risk
integrated, growth culture, characterised
by integrity, innovation, and accountability.
2. PTSB is committed to equality through
diversity, equity and inclusion and is
focussed on ensuring that all colleagues
are treated in a respectful manner.
Through our Speak Freely Procedure,
we seek to ensure that inappropriate
behaviour is challenged and addressed.
We recognise that a modern workforce
is made up of people with different
characteristics, backgrounds and
experiences, all of which are dimensions
of diversity that we recognise and value.
As a Bank, we believe that by valuing
and promoting diversity, equity, and
inclusion, we are providing a workplace
where colleagues are comfortable to be
themselves and will grow as individuals
within our environment. The Colleague
Conduct Policy outlines the 9 Grounds
of Discrimination considered by PTSB,
including gender, marital status, family
status, sexual orientation, religion, age,
disability, race, or membership of the
traveller community.
Please refer to ESRS 2 SBM-3 and S1-
MDR1 for more information on the Bank’s
Dignity and Respect Code, Equality
through Diversity and Inclusion Charter
and Colleague Conduct Policy.
The Bank takes deliberate steps to ensure
that policies are in place to advance
Diversity, Equity, and Inclusion (DEI) and
prevent discrimination and that these
policies are not just statements of intent,
but are actively implemented through
clear, enforceable procedures. This
includes:
• Mandatory Training Programmes:
in which all employees, including
leadership, are required to undergo
annual training on discrimination,
harassment, unconscious bias, and
inclusive behaviours. This includes a
requirement for all colleagues to be
familiar with and enact our Dignity
and Respect Code, Equality through
Diversity and Inclusion Charter and
Colleague Conduct Policy.
• Regular Employee Engagement: We
enable our colleagues to provide
feedback on matters relating to
discrimination through regular surveys
and our Speak Freely Procedure where
staff can voice concerns, share ideas,
and suggest improvements. This
ongoing dialogue helps us to proactively
identify and address potential issues
before they escalate.
• Employee Resource Groups (ERGs):
To support the delivery of our DEI
Strategy, the Bank has in place a
number of ERGs, whose aim is to
enable employees to join together
based on shared characteristics or life
experiences. Where issues are raised
through the ERGs, these are reviewed
and actioned on as required.
The ERGs include:
• 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 PTSB;
• DiCE - The Network promotes
and celebrates people of all races,
ethnicities, nationalities, and cultural
heritage;
• LiveWell – The Network provides
space, connection, and support for
colleagues to engage in areas of
wellbeing important to them regardless
of location; and,
• Adapt - The Network’s Vision is to
empower, educate, elevate, equip, and
empathise by creating an inclusive and
equitable place to work for abled and
disabled colleagues.
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. They include
representation from all areas of the Bank,
meet regularly and report into members of
the Bank’s People Experience Team.
S1-2 Processes for engaging
with own workforce and
workers’ representatives about
impacts
The Bank actively engages employees
across all levels, fostering a culture of
open communication, feedback, and
collaboration. This inclusive approach
allows us to gain diverse insights, manage
the actual and potential impacts of our
operations and identify potential risks
early, ensuring that our strategies are both
informed and responsive. For more detail,
please refer to S1-4 and S1-MDR1-A.
For detail relating to the Bank’s DMA and
wider stakeholder engagement with the
Bank’s Own Workforce, please refer to
ESRS 2 SBM-3 and S1-MDR1.
As a requirement of the UK Corporate
Governance Code,5 the Board is required
to review workforce engagement
mechanisms, to ensure they remain
effective.
ESRS S1 – Own workforce (continued)
5.
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”).
PTSB Group Holdings plc - Annual Report 2024
200
Sustainability Statement
Key examples of this include the
establishment of a NomCo with
accountability for culture, behaviour,
ethics and reputation management
oversight in the Bank, Senior Management
and ExCo attendance at employee events,
regular engagement with Employee
Representative Bodies (ERBs) and review
of employee engagement surveys.
The Bank gains insight into perspectives
of colleagues who may be particularly
vulnerable through a number of channels
including, our Every Voice Counts Survey,
Micro-pulse Surveys and through our
Speak Freely Procedure. For more
information on employee wellbeing
programmes to support colleagues,
please refer to S1-MDR1-A.
S1-3 Processes to remediate
negative impacts and channels
for own workforce to raise
concerns
The Bank has in place a Grievance
Procedure, Speak Freely Procedures and a
Dignity and Respect Code.
For further details on the specific
channels the Bank has in place for the
purpose of gathering employee feedback
and for our colleagues to raise concerns
or voice needs, please refer to S1-1. For
further details on the Bank’s Dignity and
Respect code, please refer to S1-1.
Speak Freely/Protected Disclosures
• We monitor the usage of the Bank’s
Speak Freely Procedure and include this
in our Key Risk Indicator (KRI) reporting,
which particularly focuses on a KRI of
trust – that colleagues feel confident to
raise concerns in a confidential manner.
• The implementation of the Bank’s Speak
Freely Procedure ensures colleagues
have trusted channels to raise
concerns, designed to ensure fairness,
transparency, and accessibility. This
channel is well known and easy to
access, with clear procedures and
timeframes communicated to all
employees. We prioritise accountability
through impartial oversight, ensuring
legitimacy and trust.
Grievance/Investigation/
Disciplinary Procedures
• PTSB has a Grievance Procedure in
place which sets out the procedures a
staff member can take in terms of the
staff member’s right to seek to address
grievances relating to their employment.
• In line with these procedures,
colleagues may raise complaints in the
workplace respective to themselves
and which may apply to other
cohort of colleagues. The Bank has
formal investigation and disciplinary
procedures in place to investigate
instances of misconduct in the
workplace.
• Conduct-related matters are reported
to the Bank’s Colleague Conduct
Committee on a quarterly basis and to
the NomCo on an annual basis, with
reporting outlining high-level themes
and actions to address common/
reoccurring issues. Where there are
common or reoccurring issues, these
are dealt with through policy updates
and HR People Management training.
• We maintain transparency by keeping
complainants informed throughout the
process and, where relevant, sharing
information with the public to meet
broader interests. Our focus is on
dialogue, working collaboratively with
employees to reach mutually agreed
solutions. Insights from complaints
guide and inform the development of
programming to improve our processes
and prevent future impacts, driving
continuous learning and improvement
across the organisation.
Workplace Relations Commission /
Labour Court
• The Bank manages complaints that are
raised with the Workplace Relations
Commissions and Labour Court through
mediation and adjudication. Where a
complaint is upheld action is taken to
address the outcome and determine
if there are further impacts to other
colleagues. Where appropriate, remedial
action is taken.
S1-4 Taking action on material
impacts on own workforce,
and approaches to managing
material risks and pursuing
material opportunities related
to own workforce, and
effectiveness of those actions
The Bank has outlined the description of
its action plans and resources to manage
its material IROs related to its Own
Workforce in S1-MDR1-A.
For more information on how the Bank
tracks and assesses the effectiveness
of its actions and initiatives in delivering
outcomes for its Own Workforce, please
refer to S1-MDR1-M.
Process for Identifying Appropriate
Action in Response to Negative
Workforce Impacts
The Bank has established a structured
process for identifying when and what
actions are necessary in response to
actual or potential negative impacts on
our workforce. This process enables us
to promptly address issues that arise,
whether they are caused by our direct
operations, contributed to through our
activities, or linked to our business
relationships.
The workforce environment is
continuously monitored and assessed to
identify any actual or potential negative
impacts. This includes:
Internal Reporting Systems: We
have implemented robust reporting
mechanisms such as Speak Freely, that
allow colleagues to raise concerns or
report incidents confidentially.
Risk Assessments: Regular risk
assessments are conducted by the
relevant teams to proactively identify
vulnerabilities in areas such as
workplace safety, employee wellbeing,
discrimination, and labour rights. These
assessments help us to identify potential
impacts before they materialise.
Stakeholder Engagement: We actively
engage with our workforce through
surveys, interviews, and open forums
to gather direct feedback on workplace
conditions. External stakeholders, such
as labour unions and advocacy groups,
are also consulted when needed to gain a
broader perspective on workforce-related
risks.
To ensure that the Bank’s practices
do not cause or contribute to material
negative impacts on our workforce,
we have implemented comprehensive
frameworks, policies and procedures that
extend across our operational functions.
This approach is designed to prevent
harm, promote ethical practices, and
balance business performance with our
responsibility to safeguard the wellbeing
of our employees.
PTSB Group Holdings plc - Annual Report 2024
201
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Employee Engagement and
Feedback Mechanisms
To effectively safeguard the wellbeing
of our workforce, we engage in regular
dialogue with our employees to gather
feedback and assess workplace
conditions. Key channels include our 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, Employee Resource Group and
People Experience Council engagement,
and other channels as appropriate.
Risk Management and Controls
The Bank has a comprehensive Risk
Management Framework that identifies,
assesses, and mitigates risks related to
workforce impacts.
Internal Policies and Controls: Ethics
and Employee Conduct
To reinforce ethical behaviour and protect
our workforce, we have implemented
robust internal policies and controls
related to ethics and employee conduct.
These policies ensure that all aspects
of our business operations, whether
procurement, sales, or data use, adhere
to high ethical standards and do not harm
employees.
Please refer to S1-MDR1 for further
information on the Banks material IROs
in relation to its Policies, Actions, Metrics
and Targets related to Own Workforce.
Information in relation to characteristics of the Bank’s employees has been compiled on
a headcount basis.
Gender
Number of employees
(Headcount) at of 31st December
2024
Average number of employees
(Headcount) for 2024
Male
1,601
1,619
Female
1,856
1,823
Other*
-
-
Total employees**
3,457
3,442
* PTSB currently does not have complete data to report this figure at present. However, we actively
encourage employees to provide a range of DEI metrics on a voluntary basis to support transparency
and progress.
** Total employees are based on Headcount figures for the purposes of this Sustainability Statement. The
Bank also reports a Full Time Equivalent (FTE) figure of 3,359.
PTSB currently operates exclusively in Ireland and therefore does not have employees
in operations outside of this region.
Category
Female
Male
Other*
Total
Number of employees (Headcount)
1,856
1,601
-
3,457
Number of permanent employees
(Headcount)
1,726
1,512
-
3,238
Number of temporary employees
(Headcount)
130
89
-
219
Number of full-time employees
(Headcount)
1,598
1,582
-
3,180
Number of part-time employees
(Headcount)
258
19
-
277
Number of non-guaranteed hours
employees (Headcount)
-
-
-
0
* PTSB currently does not have complete data to report this figure at present. However, we actively
encourage employees to provide a range of DEI metrics on a voluntary basis to support transparency
and progress.
Metrics and targets
S1-5 Targets related to
managing material negative
impacts, advancing
positive impacts, and
managing material risks and
opportunities
Please refer to S1-MDR1-M and S1-
MDR1-T for an overview of the metrics
and targets that the Bank has set to
manage material IROs including its Gender
Pay Gap, its Culture Index Score and
Board Diversity.
Our approach to setting targets for
improving working conditions is dynamic,
allowing us to adapt and respond to new
challenges and employee feedback as
it arises. We regularly review progress
toward our goals in collaboration with
internal workforce representatives and
adjust our strategies as necessary
to ensure that we continue to make
meaningful progress in creating a safer,
healthier, and more supportive work
environment. We track and monitor
progress through a Diversity, Equity and
Inclusion Dashboard and updates are
brought to ExCo and Board through the
quarterly Culture Paper.
S1-6 Characteristics of the
undertaking’s employees
The Bank has outlined the breakdown of
employees (as defined in S1-1) for 2024
below:
• Number of employees (Headcount):
3,457
• Average number of employees
(Headcount): 3,442
• Full Time Equivalent (FTE): 3,359
ESRS S1 – Own workforce (continued)
PTSB Group Holdings plc - Annual Report 2024
202
Sustainability Statement
The total number of employees who have
left the Bank since the beginning of 2024 is
424. The percentage of employee turnover
in 2024 was 12.3%. The data for employee
figures is generated from the PTSB HR
platform Tableau. This platform allows the
Bank to record and monitor in real time
the total headcount, average headcount,
gender, age, turnover and leavers etc.
The assumptions on the data include:
• For payroll purposes, we record only two
genders on our headcount file.
• Employees counted as “Long Term
Absent” are included as they may still be
in receipt of payments from the Bank.
• Employees on Career Break or Carers
Leave are not included as they are not in
receipt of any direct payment from the
Bank.
S1-8 Collective bargaining
coverage and social dialogue
The total percentage of employees covered
by collective bargaining agreements is 92%
PTSB currently operates exclusively
in Ireland and therefore does not have
employees in operations outside of this
region.
Employees that are not covered by
collective bargaining agreements are
treated as per their individual contracts.
Additionally, these conditions are aligned
with the standards established by the bank
for all employees, ensuring consistency and
fairness across the organisation.
The existence of an agreement with
employees for representation by a European
Works Council (EWC) is not applicable,
as the Bank does not operate in multiple
jurisdictions which is a requirement for
EWCs. However, the Bank engages with
the formally recognised Trade Unions as
outlined in S1-1.
S1-9 Diversity metrics
The Board and ExCo have been considered
as top management for the purposes of this
disclosure.
The gender distribution in number of employees (Headcount) at top management level
is as follows:
Gender
Number of Employees at top
management level
Male
12
Female
8
Other
0
Not Reported
0
Total Employees (Headcount)
20
The distribution of employees by age is as follows:
Age Group
Headcount
%
18-30
772
22%
30-50
1975
57%
50+
710
21%
Total
3,457
100%
S1-10 – Adequate wages
All employees in PTSB are employed subject to Republic of Ireland employment
contracts and legislation, and as such we have no employees paid below Ireland’s
national minimum wage of €23,940pa. The minimum under the PTSB Remuneration
Policy is €27,500. Please refer to S1-MDR1-P for more information on the Bank’s
Remuneration Policy.
S1-14 – Health and safety metrics
The percentage of people within PTSB who are covered by the internal health and
safety statement is 100%. There were no fatalities amongst the Bank’s workforce as a
result of work-related injuries or ill health which has occurred on sites in 2024.
The total number of work-related accidents for PTSB’s Own Workforce was 16.
S1-16 K– Remuneration metrics (pay gap and total remuneration)
The Mean Gender Pay Gap for the Bank is 16.9%.
Formula:
(Average gross hourly pay level of male employees - average gross hourly pay level of
female employees)
x 100
Average gross hourly pay of male employees
PTSB Group Holdings plc - Annual Report 2024
203
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The Median Gender Pay Gap is 11.6%
Formula:*
(Median gross hourly pay level of male employees – median gross hourly pay level of
female employees)
x 100
Median gross hourly pay of male employees
*Median is calculated as the median of the mean gross hourly rate per employee
The annual total remuneration ratio of the highest paid individual to the median annual total remuneration for all employees for the
Bank is currently 12:4.
Formula:
(Annual total remuneration for the undertaking' s highest paid individual)
Median employee annual total remuneration (excluding the highest-paid individual)
The Bank’s Gender Pay Gap has been reviewed by the Bank’s Internal Audit Team and has also received limited assurance from our
assurance provider.
S1-17 Incidents, complaints and severe human rights impacts
The total number of incidents of discrimination for 2024 was 2. The total number of complaints filed through channels designed for
PTSB employees to raise concerns in 2024 was 4. The total number of complaints filed externally to National Contact Points such as
the Workplace Relations Commission and Labour Court for OECD Multinational Enterprises in 2024 was 4 (this is not inclusive of the 2
recorded incidents noted above).
There were no severe human rights incidents connected to PTSB’s workforce in 2024. There were no severe human rights incidents
connected to PTSB’s workforce that do not respect the UN Guiding Principles and Organisation for Economic Cooperations and
Development (OECD) Guidelines for Multinational Enterprises in 2024. There were no fines, penalties, and compensation incidents
relating to human rights issues in 2024.
S1 Minimum Disclosure Requirements
As part of the development of the Bank’s IROs, we identified similar themes emerging, so the MDRs have been consolidated under
thematic headings. For S1 Own Workforce, we have consolidated all material IROs under the theme S1-MDR1-Working Conditions.
S1-MDR1 - Working Conditions
The IROs reflected in S1-MDR1 are outlined below:
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-3
Impact
The impact PTSB has
on its employees by
ensuring adequate
working conditions,
equal opportunities for
all, and protection of
worker’s rights.
PTSB understands that the impact it has on its
employees is far reaching and that it not only
impacts the employees themselves but the
Bank’s long-term success. As part of its analysis,
the Bank considered a wide range of actual and
potential, positive and negative, impacts on its
own workforce. The impacts focused on corporate
culture, workplace dynamics, employee wellbeing,
mental health, job satisfaction, quality of life,
burnout, conflict, employee experience, morale,
productivity and gender balance. The overall impact
of ensuring adequate working conditions, equal
opportunities and protection of worker’s rights is
a well-supported workforce leading to increased
engagement, improved performance, and a more
resilient organisation.
Both
Both
ESRS S1 – Own workforce (continued)
PTSB Group Holdings plc - Annual Report 2024
204
Sustainability Statement
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
O-3
Opportunity
A working environment
that has appropriate
working conditions,
protects worker’s
rights, promotes
inclusion and offers
adequate training
and innovation
opportunities may
lead to increased
productivity, reduce
costs and enhanced
brand and reputation.
PTSB understands it can unlock significant
opportunities by fostering a working environment
with appropriate working conditions. As part of
its analysis, the Bank considered a number of
different opportunities which centred on the themes
of appropriate working conditions, protection of
worker’s rights and inclusion of all in the workplace.
When employees feel respected, valued and
supported they will be motivated to perform
well and contribute to the business objectives.
Opportunities considered included fostering an
attractive corporate culture with stable working
conditions, where diversity in the workforce is
promoted, health and safety risks are effectively
managed, and employees feel comfortable to
raise concerns (including whistleblowing) and
are supported to innovate. PTSB views these
opportunities as collectively investing in the
wellbeing of its employees leading to increased
productivity, reduced operational costs, enhanced
reputation, better talent retention and the overall
strengthening its position in the marketplace.
n/a
n/a
R-7
Risk
People Risk: The
risk of financial,
operational or
reputational damage to
the Bank arising from
failure of the Bank to
meet its employment
obligations and duty
of care to staff or
the failure to ensure
adequate resources
and or skills are in
place, that succession
planning is not
effective or that the
operation of the Bank
may be impacted by
labour disputes.
People Risk is associated with the behaviours
and actions of the Bank’s workforce and has been
identified as a key risk by PTSB. Elements of this
risk have been mapped to the Own Workforce
topic. These relate to employee wellbeing and
mental health, including stress and burnout;
inadequate wages, remuneration and development
opportunities harming workforce retention; lack of
transparent work environment or equal opportunities
for all, reducing trust and communication; difficulties
in attracting talent; regulatory compliance including
health and safety; human rights and protections
against discrimination requirements; and lack of
engagement with unions and lack of effective
communication leading to strikes.
n/a
n/a
S1-MDR1-P Policies adopted to
manage Working Conditions
PTSB has adopted and integrated several
policies to mitigate against social and
people risk, ensure adequate working
conditions, equal opportunities and the
protection of worker’s rights. These
include:
• Individual Accountability Framework
Conduct Standards Policy
• Colleague Conduct Policy
• Code of Ethics
• Speak Freely (Whistleblowing)
Procedure and Protected Disclosure
Procedure;
• Dignity and Respect Code
• Equality through Diversity and Inclusion
Charter
• Conflict of Interest Policy
• Fitness and Probity Policy
• Grievance Procedure
• Disciplinary Procedure
• Financial Crime Compliance Framework
• Anti-Money Laundering/Terrorist
Financing
• Anti-Bribery and Corruption
• Data Protection
• Information Security Policy
• Learning and Development Policy
• Smart Working Framework
• Remuneration Policy
• Group Safety Statement
• Succession Planning Policy
Framework and Policy
Implementation Monitoring Process
The application of these Frameworks and
Policies is monitored by the Framework
or Policy Owner. The Policies referenced
above comply with best practice guidance
in line with the WRC and Employment Law
updates.
It is an employee’s responsibility to comply
with Policies made aware to them by
their Line Managers. Relevant training is
provided at least annually, and the Bank’s
Learning and Development team monitor
completion.
PTSB Group Holdings plc - Annual Report 2024
205
Strategic Report
Governance
Sustainability
Financial Statements
General Information
All Frameworks and Policies that the Bank
has in place to protect its workforce meet
the relevant regulatory requirements,
adhere to PTSB’s Document Management
Guidelines, and are reviewed and updated
as appropriate, on an annual basis. These
Frameworks and Policies apply to all of
the Bank’s Business Units. Accordingly,
every colleague should be familiar with
the policies and relevant processes,
procedures, codes and guidelines in
support of the protection of worker’s
rights.
The Board has overall governance
responsibility for the operations of
the Bank. While the Board retain
ultimate accountability for long-term
implementation of PTSB’s Strategy,
specific Policy Owners have been
designated for various Policies.
The Bank demonstrates a strong
commitment to transparency and
accountability by actively respecting
a range of third party standards and
initiatives through its Frameworks and
Policies. These include:
• In 2023, PTSB was awarded
the Investors in Diversity Gold
Accreditation. Supported by the
Irish Business and Employers
Confederation’s (IBEC), the Programme
recognises existing efforts, while
supporting the journey of continuous
improvement by providing a structured
framework to transform workplace
practices and culture. PTSB was the
12th company in Ireland to receive the
Gold Award. This Award recognises
PTSB’s progress in DEI, including 60:40
gender diversity at Board;
• Setting diversity objectives, through
NomCo and considering diversity
benchmarking results, census data and
the latest regulatory guidance published
by competent authorities, The
Economic and Social Research Institute
(ESRI), the European Banking Authority
(EBA), or other relevant international
bodies or organisations;
• Continuing membership of the 30%
Club, a group of c.200 Chairs and CEOs
committed to better gender balance at
all levels of their organisations;
• Supporting Balance for Better
Business, and playing an active role in
the development of the Banking and
Payments Federation Ireland (BPFI’s)
Women in Finance Charter;
• Partnering with Business in the
Community Ireland (BITCI) to track
and report on DEI progress through
the Elevate Pledge, which includes
submitting relevant data for an annual
report on diversity efforts;
• Attaining the IBEC’s KeepWell Mark
accreditation;
• Reporting on the Gender Pay Gap and
aligning with best practices for gender
equity in the workplace; and,
• Respecting The Employment Equality
Acts 1998-2015 and the Equal Status
Act 2000 to not treat anyone unfairly
because of any of the 9 Grounds of
Discrimination (as defined in law)
gender, marital status, family status,
sexual orientation, religion, age,
disability, race or membership of the
traveller community.
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 and
associated Policies. A key role of the
NomCo is to ensure effective engagement
with and participation from the Bank’s
key stakeholders. PTSB’s People Function
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 NomCo on a regular basis.
The Bank actively engages employees
across all levels, fostering a culture of
open communication, feedback, and
collaboration. This inclusive approach
allows us to gain diverse insights and
identify potential risks early, ensuring
that our strategies are both informed and
responsive.
Listening to Employees and Acting
on Feedback
The Every Voice Counts (EVC) Employee
Engagement Survey is conducted annually
and is designed to track progress across
our Culture, Engagement, Trust and Net
Promoter Score and to give our people an
opportunity to provide feedback on what
is working well across the organisation,
while identifying areas for improvement.
The Bank regularly conducts micro-pulse
surveys which cover a number of themes
including Flexible and Hybrid Working and
Speaking Freely. The findings enable us
to evolve our action plans, ensuring we
focus on the right things to support our
colleagues.
For more information relating to colleague
engagement, including the channels by
which engagement occurs, please refer
to S1-1.
S1-MDR1-A – Actions and
resources in relation to
Working Conditions
During 2024, the Bank made good
progress in the implementation of actions
to foster optimal working conditions,
promoting equitable opportunities for all
employees, and safeguarding worker’s
rights. Key actions taken in 2024 include:
• Enhancing our DEI Strategy with the
recommendations put forward by the
Irish Centre for Diversity following our
Gold Accreditation, as we continue
to drive improvements and target re-
accreditation in 2025. In 2024, PTSB
received a ‘Highly Commended’ in the
Irish Centre for Diversity Outstanding
Employee Resource Group Awards as a
result of this work;
• Continuing to embed its Smarter
Working Framework with c.68% of
our colleagues now availing of Hybrid
Working Options;
• Launching the newly established Adapt
ERG to focus on physical ability and
neurodiversity;
• Offering support for parents through 1:1
coaching and group sessions with our
parental support partners;
• Ongoing roll out of the DEI Awareness
mandatory annual eLearning for all
colleagues;
• Ongoing review of all internal training
material, ensuring consideration for
accessibility and representation;
Updates have included the addition
of closed captions and imagery
representing modern Ireland;
• Maintaining our Faith Room, Wellbeing
Room and All Gender Toilets facilities at
the Bank’s Head Office, which now form
part of our Property Strategy and will be
incorporated into refreshed premises;
and,
• Promoting a culture of psychological
safety through Speak Freely, our
channel for encouraging colleagues to
speak up and raise a concern.
ESRS S1 – Own workforce (continued)
PTSB Group Holdings plc - Annual Report 2024
206
Sustainability Statement
High Performance Culture
The Bank’s performance management applies to all employees across the organisation,
ensuring a consistent approach to employee performance, development, and evaluation.
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 Business Strategy
and Organisational Values. The competencies are an integral part of our Career
Development Framework, supporting colleagues’ development and on the job career
growth trajectory. PTSB has in place an online performance management system,
Performance COMPASS, to encourage quality conversations and to streamline the
completion of the performance management process.
Ways of Working (Hybrid Flexible Working)
Throughout 2024, the Bank has advanced it’s Flexible and Hybrid Workplace creating a
modern work environment that prioritises employee wellbeing as it fosters a supportive
and inclusive workplace culture.
Employee Wellbeing
The wellbeing of our employees throughout all stages of their career and personal
lives is of paramount importance to us. We are committed to ensuring a lasting positive
impact on our colleagues through the implementation of various initiatives. As part of
PTSB’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.
Financial
Physical/Emotional/Mental Health
Pension Plan
Health Screening
Income Protection Benefit
Eye Testing
Sick Pay Scheme
Employee Assistance Programme for Colleagues
and their Spouse, Adult Dependent Children and
Dependent Parents (Counselling Service)
Staff Banking
Parental Supports (1:1 Career Coaching for
Parents and People Managers And Supports For
Parents And Carers Of Toddlers To Teenagers)
Cycle To Work Scheme
Menopause Supports for Colleagues and People
Managers
Annual Travel Pass Scheme
Mental Health Training Addressing a Variety of
Themes
Employee Discount Scheme
A Range of Health and Wellbeing Related
Information Sessions
Holiday Fund
Lifestyle/Wellbeing Workshops
Work Station Assessments (Both In Office And At
Home)
Education Support
Paid Maternity and Paternity Leave Adoptive
Leave
Life Leave (5 Days)
MyLife App
Investing in Learning and
Development
PTSB recognises the importance of both
personal and professional development
when it comes to delivering on our
purpose and ambition. Our focus is on
our people and our mission to equip them
with the necessary skills and behaviours
to develop and thrive in an ever-changing
financial services landscape. We
support our colleagues with a diverse
catalogue of education and training
courses as well as other professional
development opportunities tailored to
their role, enabling them to learn and
adopt new skills that will be critical
to the future of banking. A dedicated
Learning and Development Team is in
place to coordinate activity and deliver
programming.
Diversity, Equity and Inclusion
PTSB 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.
PTSB acknowledges the significant role
that our colleagues play in ensuring
operational success and long-term
sustainability. We are committed to
addressing the material People Risk that
arise from impacts and dependencies on
our workforce, such as those related to
employee wellbeing, safety, engagement,
and productivity. To manage these risks,
we have implemented a range of strategic
actions, both planned and currently
underway, while ensuring that their
effectiveness is continuously monitored
and tracked.
The Bank monitors any incidents,
breaches, or complaints related to
working conditions, equal opportunities
and workers’ rights through channels
including:
PTSB Group Holdings plc - Annual Report 2024
207
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Employee Representative Bodies
(ERBs) / Trade Unions
• PTSB 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 established 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;
• Monthly engagements with the
formally recognised Trade Unions to
discuss business updates and to raise
and address areas of concern for
colleagues;
• Annual pay negotiations with the
Representative Bodies; and,
• Executive and Senior Leadership Team
members meet the ERBs on an as
needed basis depending on the agenda
and business requirements and have
scheduled bi-annual engagements
with the ERBs to update them on the
organisational trading position, the
Bank’s Purpose and Strategy, together
with the opportunities and challenges
being faced.
People Experience Council (PEC)
• As a group of leaders within the
organisation, across multiple levels
and functions, PEC members are
empowered and mandated by the ExCo
to work with teams in their area as
they seek to drive and support positive
cultural and behavioural change. The
PEC members listen to colleague
feedback and work to support the
culture in their respective functions to
address behavioural inconsistencies
across the Bank. PEC members also
lead the development of the Every
Voice Counts Action Plans to address
areas for improvement. The Company
Secretary (Board Nominee) attends
the PEC to support the Board and gain
a greater understanding of culture/
employee sentiment;
• As part of this group, the Board not
only gains a deeper understanding
of the drivers behind the employee
engagement survey results (PTSB Every
Voice Counts Survey, IBCB Éist Survey),
they also gain diverse perspectives on
what actions will address the areas for
development and also any emerging
areas of discontent from employees;
and,
• The Risk and Compliance 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.
Gender Pay Gap Reporting
The Gender Pay Gap is the difference
between the average gross hourly
earnings of all men and the gross hourly
earnings for all women in an organisation,
regardless of the nature, experience,
qualifications or working pattern of their
jobs.
Having reviewed the series of employee
engagements during 2024, the NomCo
was satisfied that this engagement was
effective and in compliance with the UK
Code.
Our progress in creating this culture is
measured through our EVC Survey and
our Micro-pulse Survey which asks the
question ‘where I work, people can share
their opinion without fear of negative
consequences’, which held the EVC
scoring at 74% from 2023 to 2024.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated to
the delivery of activity in place to support
the Bank’s Own Workforce. PTSB has not
disclosed these figures publicly.
S1-MDR1-M Metrics in relation
to Working Conditions
The Bank employs key metrics to evaluate
its performance and effectiveness
regarding its impact on employees,
particularly in relation to ensuring
adequate working conditions, equal
opportunities, and the protection of
workers' rights.
The following metrics and targets
provided, in addition to other metrics
already disclosed of PTSB’s commitment
to ensuring a positive work environment,
which is essential for productivity, People
Risk mitigation and enhancing brand
reputation and awareness within the
industry.
Gender Pay Gap (GPG)
The Bank reports the difference between
the average (mean) and the midpoint
(median) earnings of men and women,
expressed relative to men’s earnings.
PTSB report twenty different metrics,
based on a ‘snapshot’ of pay data on a
date of our choosing in June 2024,1 which
acts as a baseline for the reporting year.
• Mean Gender Pay Gap 2024 – 16.9%
• Median Gender Pay Gap 2024 – 11.6%
Culture Index Score
The Bank measures its Culture Index
Score through its annual EVC survey. It is
calculated from 20 specific questions with
themes such as Personal responsibility for
Risk, Feeling of Belonging and Managers
and Leadership behaviours.
In 2024, the Bank’s Culture Index was 76%
(+6% on target).
Board Diversity Metrics
PTSB recognises the benefits of having
a diverse Board whose members reflect
a wide range of knowledge, skills and
experience with differences in educational
and professional background, ethnicity,
gender, age, cognitive and personal
strengths, and other qualities, in order
for the Board to be able to discharge its
duties and responsibilities effectively,
in addition to having a diverse senior
leadership and executive management
succession pipeline.
1
There have been no material changes up to
31st December 2024.
ESRS S1 – Own workforce (continued)
PTSB Group Holdings plc - Annual Report 2024
208
Sustainability Statement
The Bank tracks the following metrics in
relation to Board diversity:
• Board members with core relevant
banking and/or financial services
knowledge and experience; and,
• Board Gender Balance.
Please refer to ESRS 2-GOV1 and S1-9 for
more information on Board Diversity.
Our Gender Pay Gap has been validated
by an independent external body. The
other metrics disclosed have not been
validated by an external body other than
the Bank’s assurance provider.
S1-MDR1-T Tracking
effectiveness of policies and
actions through targets
Our approach to setting targets for
improving working conditions is dynamic,
allowing us to adapt and respond to new
challenges and employee feedback as
it arises. We regularly review progress
toward our goals in collaboration with
workforce representatives and adjust our
strategies as necessary to ensure that
we continue to make meaningful progress
in creating a safer, healthier, and more
supportive work environment.
To ensure that the targets we set for
improving working conditions reflect the
needs and expectations of our workforce,
we actively involve employees in shaping
these objectives. Through a combination
of direct feedback mechanisms
and collaboration with employee
representatives, we ensure that our goals
are grounded in the real experiences and
concerns of those most affected, our
employees.
Culture Index Score
PTSB has a Culture Index score target of
70%.
Board Diversity Targets
The Board Diversity targets include:
• A majority of Non-Executive Directors,
the Board Chairperson together with
the Chairpersons 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).
• The Board exceeded its objective of
requiring a majority of Non-Executive
Directors, the Board Chairperson
together with the Chairpersons of
the Audit and Risk and Compliance
Committees to have relevant banking
and/or financial experience and is
satisfied that all Directors have attained
the required financial literacy threshold.
• The Board will be gender balanced
(50% between Directors identifying as
male or as female). Where the Board
(or Board Committee) has an uneven
number of Directors, a rounding down is
deemed still to have achieved balance
(for example, 6 out of 13 directors).
• At 31 December 2024 the Board female/
male stood at 60:40 (67:33 for Non-
Executive Directors) against a gender
diversity target of 50:50. This exceeds
the UK Listing Rules target to have at
least 40% female representation on the
Board.
• At least one of the Chairperson, Chief
Executive Officer, Senior Independent
Director or Chief Financial Officer
positions will be held by a female
(including those self-identifying as a
female).
• The Board has also met its diversity
target of having at least one senior
board position held by a female with
the Chairperson position held by a
female throughout the year and is also
in line with the role model ambitions of
the Board in increasing diversity and
inclusion across the rest of the Group.
• The metrics and targets disclosed
above are related to the Bank’s Own
Workforce and not directly pertain to
environmental matters.
PTSB Group Holdings plc - Annual Report 2024
209
Strategic Report
Governance
Sustainability
Financial Statements
General Information
PTSB is a credit institution licensed and
regulated by the Central Bank of Ireland.
The Bank operates in the Republic
of Ireland and is noted as an ‘Other
Systemically Important Institution’ (O-SII),
which are institutions that are systemically
important to the domestic economy or to
the economy of the European Union (EU).
The Bank has a presence in 98 branch
locations nationwide and is a leading
provider of Retail and Business Banking
in the Irish Market, serving c.1.3 million
customers.
The Bank considers the following
Consumers and End-Users as subject
to material impacts including its
Retail Customers, Small and Medium
Enterprise (SME) Customers, Asset
Finance Customers, Corporate Deposit
Customers and Other Customers,
including those who may be vulnerable
or underrepresented. In addition, PTSB
considers society as subject to material
impacts by our own operations or through
our value chain.
The findings from the Bank’s DMA, which
included the viewpoints of the Bank’s
Consumers and End-Users, will guide and
inform the development of a refreshed
Sustainability Strategy for the Bank during
2025.
The Bank defines vulnerable customers
as per Consumer Protection Code (CPC)
2012. ‘A vulnerable customer means a
natural person who:
• Has the capacity to make his or her
own decisions but who, because of
individual circumstances, may require
assistance to do so (for example,
hearing impaired or visually impaired
persons); and/or,
• Has limited capacity to make his or
her own decisions and who requires
assistance to do so (for example,
persons with intellectual disabilities or
mental health difficulties)’. (Consumer
Protection Code 2012, Chapter 3, S 3.1)
PTSB does not offer products that are
harmful to people and/or may increase the
risk of chronic disease.
When considering the Consumers
and End-Users that may be subject to
negative impacts regarding their rights to
privacy, personal data protection, freedom
ESRS S4 – Consumers and End-Users
of expression or non-discrimination, the
Bank includes the following customer
cohorts: Retail, Business Banking and
Asset Finance. This includes those who
may be vulnerable or underrepresented.
When considering the Consumers and
End-Users that may be dependent on
accurate and accessible product-or
service-related information, such as
manuals and product labels, to avoid
potentially damaging use of a product or
service, the Bank includes the following
customer cohorts: Retail; Business
Banking; Asset Finance; and Other. This
includes those who may be vulnerable or
underrepresented.
When considering the Consumers and
End-Users that may be particularly
vulnerable to health or privacy impacts,
or impacts from marketing and sales
strategies, the Bank includes those
customers categorised under the
Consumer Protection Code 2012’s
vulnerable customer definition outlined
above.
As part of the Bank’s DMA, we identified
the material IROs in relation to Consumers
and End-Users which have been outlined
in ESRS 2 SBM-3. Further detail can be
found in S4-MDR1 and S4-MDR2.
Vulnerable customers and their associated
risk of harm has been considered in
relation to the Bank’s activities.
We are 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.
In compliance with the Assisted Decision-
Making (Capacity) Act 2015, we have
enhanced our procedures for assisting
vulnerable customers, modernised our
internal systems and cultivated effective
relationships with external Government
bodies. In response to meeting the needs
of customers who require additional
assistance, the Bank has established a
dedicated Vulnerable Customer Support
Unit, whose role is to provide additional
support to vulnerable customers.
The Bank’s Enhanced Customer Support
Policy, Framework and Charter are
focussed on all customers who may
require additional assistance, including
those who may find themselves in
vulnerable circumstances.
There are currently no material Risks
or Opportunities associated with
dependencies on specific Consumers and
End-users.
S4-1 Policies related to
Consumers and End-Users
The Bank has policies, procedures and
codes in place to manage the material
IROs related to Consumers and End-Users
as outlined in ESRS 2-MDR-P. Further
detail can be found in S4 MDR1 and S4
MDR2.
Policies are reviewed and updated as
required as part of the Bank’s policy
review cycle.
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
Human Rights
PTSB recognise our responsibility to
respect the human rights of every
individual. The Bank has in place a 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 individuals
are treated with dignity and respect,
including our Consumers and End-Users.
To mitigate against human rights risk, or
violations that may occur, the Bank has
comprehensive due diligence procedures
in place to support the Bank in meeting
all relevant human rights legislation in
the Republic of Ireland in respect to
Consumers and End-Users. To support,
we also have in place a suite of reporting
mechanisms through our Speak Freely
channels that enables the timely reporting
of issues. For more on our Speak Freely
Procedure, please refer to ESRS 2-MDR-P.
Procedures are in place for dealing with
reported human rights allegations and
instances are addressed on a timely basis.
When preparing this disclosure, PTSB has
no severe human rights issues or incidents
connected to its Consumers or End-Users
to disclose.
PTSB Group Holdings plc - Annual Report 2024
210
Sustainability Statement
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.
At present, PTSB does not have Policies
which are fully aligned with the UN
Guiding Principles, International Bill of
Human Rights or the Organisation for the
Economic Co-operation and Development
(OECD) in respect to Consumers and End-
Users. The Bank does meet all relevant
human rights legislation in the Republic of
Ireland in respect to Consumers and End-
Users. We keep our policies under review
and update them as required as part of
our policy review cycle.
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. Please refer to ESRS 2-MDR-P
for more information.
S4-2 – Processes for engaging
with Consumers and End-
Users about impacts
In 2024, the Bank engaged with our
stakeholders as part of our Double
Materiality Assessment. This engagement
included our consumers and end-users,
regarding the Impacts outlined in ESRS
2-SBM-2 and ESRS 2-IRO-1.
A sample of our customers were engaged
with directly through a survey and no
proxies were used. The assessment was
undertaken by an independent third party
to ensure complete confidentiality and
impartiality. Views from the engagement
with our customers informed the Material
Impacts. This was overseen by the Bank’s
Sustainability Committee.
The Bank has in place a dedicated
Customer Team with responsibility
for overseeing engagement with our
customers. For the Double Materiality
Assessment process, the Chief
Sustainability and Corporate Affairs
Officer was the Executive Committee
member responsible for overseeing the
engagement with our Consumers and
End-Users.
Given the engagement with our customers
was designed to determine the material
IROs for the Bank, we did not evaluate
the effectiveness of the engagement or
agree any outcomes beyond helping to
understand the material IROs.
The Bank is committed to fostering
openness and inclusivity and to delivering
an exceptional experience to our
customers and communities, especially
those that may require additional support
or who may be vulnerable. By prioritising
the needs of vulnerable customers, we
not only enhance their financial wellbeing
but also strengthen our commitment to
building trust within our communities.
Through our stakeholder engagement
channels, the Bank has procedures in
place to enable our vulnerable customers
to feedback any issues that they may
experience.
S4-3 Processes to remediate
negative impacts and channels
for consumers and end-users
to raise concerns
The Bank has in place Frameworks,
Policies and Procedures applicable
to ensure that we can remedy
customer impacting errors (CIEs), in a
comprehensive, customer-focussed,
and timely manner whenever they occur.
These cover how the Bank defines the
issue identified, stops the harm, identifies
the population of customers, puts in
place a remediation and communication
approach, future proofs the issue and
completes any remediation that may be
required. This process is overseen by
a dedicated CIE Forum which includes
representation from key stakeholders from
around the business. The Forum meets
monthly. When CIEs are identified, the
Bank aims, where at all possible, to put
the customer back in the position had
they been in had the error not occurred.
In instances where there may be a
customer appeal, these appeals are
monitored, and the Bank remains
committed to reviewing outcomes to
ensure potential liabilities are addressed
effectively.
The Bank has a Customer Committee
in place to ensure 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.
Part of the role of the Customer
Committee is to review relevant customer
events, issues and complaints, when
escalated by relevant sub-committees
and forums, to provide guidance on
significant issues/events, and to delegate
appropriate action by relevant sub-
committees. The Customer Committee is
a sub-committee of ExCo and is chaired
by the Chief Retail Banking Officer.
In addition, the Bank has a dedicated
Complaints and FSPO Forum (CFF) which
is a sub-committee of the Customer
Committee. The CFF meets monthly to
review complaint operations and trends
and works with Business Units to develop
and implement improvement plans for
issues identified across the Bank. The
Forum also discusses individual cases,
with a view to ensuring lessons are
learned and issues identified are rectified.
The Bank has the following channels
in place to process concerns raised by
Consumers and/or End-Users:
• Voice of the Customer (VOC)
Programme, 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. The Customer
Experience Continuous Improvement
Forum meets weekly to review
customer feedback across business
areas and customer touchpoints, with
the aim of identifying, prioritising and
fixing customer pain points.
• Vulnerable Customer Support Unit,
aimed at providing support to both our
customers and our frontline employees;
and,
• Additional support channels through
the Bank’s branch network, customer
contact centres, online complaints
forms and social media are available for
our customers to raise their concerns.
In addition, the Bank engages third parties
in interactions with customers throughout
the lifetime of the relationship, including
when customers make complaints either
directly, through the FSPO, or where CIEs
occur.
PTSB Group Holdings plc - Annual Report 2024
211
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Formal complaints can be raised through
the channels outlined above. The process
for tracking and monitoring complaints is
outlined below:
• We aim to resolve all issues where
possible when a customer contacts us;
• If we are unable to resolve the
complaint within 5 business days, we
will write to formally acknowledge the
complaint and provide a complaint
reference number. Customers are also
informed of the name and contact
details of the person dealing with the
complaint;
• Some complaints are more complex
and cannot be resolved in the time we
would like, so while under investigation,
the customer is kept updated;
• Customers may be telephoned for
further details in relation to the
complaint and to keep them informed
on our investigations; and,
• Once all the details of the complaint
have been investigated, we will issue
the customer with a ’Final Response
Letter’.
If the customer is still not satisfied, the
Bank can be contacted to further discuss
the matter. Should this remain unresolved,
customers have the option to escalate
to the Financial Services and Pensions
Ombudsman (FSPO). Further details can
be found within the Bank’s Complaints
Charter, which is made available online.
Trends and issues identified through
complaints are discussed at the CFF.
Business Units use this information
to identify areas for improvement in
customer service, with the aim of
improving processes and reducing
complaints, where possible.
To ensure that consumers are aware
of the complaints structures that are in
place, and the channels that they can
raise their concerns, PTSB has in place a
Complaints Charter which is available to
all customers online.
The Bank is involved in High Court
appeals against two tracker mortgage
related Financial Services and Pensions
Ombudsman (FSPO) decisions and, while
the timing and outcome of these appeals
is uncertain, based on legal advice
received, no provision has been made for
these cases.
S4-4 Taking action on material
impacts on consumers and
end-users, and approaches
to managing material risks
and pursuing material
opportunities related to
consumers and end-users, and
effectiveness of those actions
The impacts, risk and opportunities
related to the Consumers and End-Users
topic have been grouped into two themes.
They cover S4-MDR1 Housing and S4-
MDR2 Customer Experience. The detailed
actions and effectiveness of those actions
relating to the IROs under each theme are
outlined in relevant sections below.
S4-5 Targets related to
managing material negative
impacts, advancing
positive impacts, and
managing material risks and
opportunities
Targets relevant to management for IRO
related Consumers and End-Users are
outlined in S4-MDR1-T and S4-MDR2-T.
S4 Minimum Disclosure
Requirements
As part of the development of the
Bank’s IROs, we identified similar themes
emerging, so the Minimum Disclosure
Requirements have been consolidated
under thematic headings. The two themes
under which we disclosed material IROs
related to Consumers and End Users are
S4-MDR1-Housing, S4-MDR2-Customer
Experience.
S4-MDR-1- Housing
The IROs reflected in S4-MDR1 are outlined below:
IRO-Ref
IRO
IRO
Details
Positive or
Negative
Potential or
Actual
O-5
Opportunity
Providing
adequate housing
via mortgage
financing for
customers across
Ireland can lead
to an enhanced
reputation and
increased market
share.
There are a number of reasons why PTSB considers
making home ownership more accessible a
significant opportunity. These include alleviating
the housing crisis, improving living conditions,
boosting the economy, broadening the customer
base, fostering community stability, and supporting
the Bank to position itself as a socially responsible
institution.
By enabling home ownership, supporting affordable
housing initiatives, and driving local economic
development, PTSB can contribute to improved
quality of life for its stakeholders, and economic
stability.
n/a
n/a
ESRS S4 – Consumers and end-users (continued)
PTSB Group Holdings plc - Annual Report 2024
212
Sustainability Statement
S4-MDR-P Policies adopted to
manage Housing
The Bank has the following Policies in
place to ensure adequate housing for
Consumers and End-Users through
mortgage financing:
• Credit Risk Management Framework
• Group Credit Policy
• Enhanced Customer Support Policy
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
S4-MDR1-A Actions and
resources in relation to
Housing
The Bank has multiple channels in place
to assist customers with mortgage
financing, ensuring access to adequate
housing. These include tailored mortgage
products, flexible payment options, and
personalised financial advice to meet
diverse needs. Additionally, we streamline
the application process and provide
ongoing support throughout the home-
buying journey.
The following are key actions we have
implemented to support our customers
with mortgage financing:
Online Mortgage Portal
During 2023, the Bank launched a Digital
Mortgage Journey to the market through
the introduction of its Online Mortgage
Portal. Through the Portal, customers
can now start their Mortgage application,
track their progress and talk to a PTSB
team member whenever they need to, at a
time and a place that suits them.
Extending our 2% & 2% Mortgage
The Bank has expanded its 2% cashback
on monthly mortgage repayments to
existing mortgage customers. This is
following the extension of the award
winning 2% & 2% Mortgage until 31 March
2025. 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.
Green Mortgage
PTSB has in place a Green Mortgage
offering, a 5-Year and 3-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.
The Bank’s Green Mortgage offers
competitive rates that encourages
sustainable home ownership, helping
customers invest in energy-efficient
properties while contributing to a greener
future.
Supporting Customers in Financial
Difficulty
The Bank 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. 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.
Types of forbearance arrangements
currently offered by PTSB are customer
specific and provide, temporary and
or term appropriate arrangements, as
necessary.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated to
the delivery of PTSB’s mortgage financing
activity. PTSB has not disclosed these
figures publicly.
Green Bonds
Green Bonds are financial instruments
designed to raise funds for projects with
environmental benefits. During 2024,
PTSB issued €500m Green Senior HoldCo
notes at a coupon of 4.25%. The issuance
was 4.5 times oversubscribed with a final
order book of €2.2bn, comprising of 120
investors. These bonds finance renewable
energy projects, energy-efficient housing,
and other environmentally sustainable
initiatives.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of activity. PTSB has not
disclosed these figures publicly.
S4-MDR1-M Metrics in relation
to Housing
The Bank uses the following metrics to
evaluate performance and effectiveness in
key areas such as Housing:
Mortgage Lending
• New Mortgage Lending for 2024 was
c.€2.1 billion. The Bank’s share of the
new business Mortgage market was
16.4%; and,
• Green Mortgage Lending in 2024
accounted for 43% of New Mortgage
Lending, +28% YoY.
S4-MDR1-T Tracking
effectiveness of policies and
actions through targets
PTSB has not disclosed these targets
publicly.
PTSB Group Holdings plc - Annual Report 2024
213
Strategic Report
Governance
Sustainability
Financial Statements
General Information
S4-MDR2-Customer Experience
IRO-
Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-4
Impact
The impact on society, and
Consumers and End- Users
from failing to implement
appropriate measures to
protect customer information
and ensure vulnerable
customers avail of PTSB’s
services.
Banks play a crucial role in shaping the
financial landscape and if it fails to protect
vulnerable customers or address key
societal issues the negative impact on
society and consumers can be significant.
PTSB considered a range of potential
negative impacts under this theme including
poor corporate culture, neglecting social
inequality, insufficient digital access, lack
of inclusion and failure to cater to those
effected by extreme weather events.
Negative
Potential
I-5
Impact
The impact PTSB has on
society and Consumers and
End-Users by promoting
financial wellbeing and
providing customer supports.
The Bank’s impact on society extends
beyond its role in financial transactions.
PTSB considered a longlist of positive and
negative, actual and potential impacts
which could be categorised under the
shared theme of customer experience. By
promoting financial wellbeing and offering
customer support, PTSB can contribute to
the broader good.
Effective corporate culture fosters engaged
employees who deliver better customer
service, ensuring accurate and transparent
financial advice and fair treatment, which
helps customers make informed financial
decisions. Thorough business conduct risk
assessments prevent harmful practices,
which otherwise cause financial stress
and hardship. Together, these measures
alleviate financial burdens, reduce stress,
and enhance mental wellbeing by fostering
trust and stability in customers' financial
lives.
Additionally, providing financial advice and
ensuring accessible, non-discriminatory
services promote financial literacy and
wellbeing. Together, these actions
demonstrate the bank's commitment to
positively impacting society by addressing
housing needs, supporting economic
growth, and empowering customers
financially.
Positive
Both
O-4
Opportunity
The opportunity for the
Bank to enhance its’ brand
and reputation by providing
exceptional customer
experience.
PTSB considers enhancing its brand
reputation a key driver of its long-
term success. Banks are increasingly
evaluated on their behaviour, corporate
culture, political engagement, supplier
relationships, due diligence processes
and partnerships with Non-Governmental
Organisations (NGOs), government
agencies, and community organisations.
These opportunities contribute to increasing
customer and employee trust and loyalty,
building a positive public image within
the community, and ultimately creating a
sustainable competitive advantage.
n/a
n/a
ESRS S4 – Consumers and end-users (continued)
PTSB Group Holdings plc - Annual Report 2024
214
Sustainability Statement
IRO-
Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-4
Risk
Cyber Security Risk: The
risk of unauthorised access,
modification, malicious
disruption or use of IT
systems and data from within
or outside the Bank (for
example, cyber-attacks).
Elements of this risk have been mapped
to the Information-related Impacts for
Consumers and End-users topic. These
relate to inadequate privacy protections,
misleading/incomplete information, and
inadequate GDPR compliance.
n/a
n/a
R-9
Risk
Regulatory Compliance
Risk: 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 change
to, official sector policy, laws,
regulations, major industry
standards, compliance
policies and procedures
or the expectations or
customers and stakeholders.
Elements of this risk have been mapped to
Information-related Impacts for Consumers
and End-Users subtopics. These relate
to ethics and conduct, data protection
measures and current and emerging
regulation.
n/a
n/a
S4-MDR2-P Policies adopted to
manage Customer Experience
The Bank is committed to ensuring
an exceptional customer experience
by enhancing our customer’s financial
wellbeing with various supports. In
addition, we are focused on ensuring
that the appropriate measures are in
place to protect customer information. To
support this commitment the Bank has
implemented the following policies.
• Regulatory Compliance Framework
• Data Protection Policy
• Information Security Policy
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS 2
MDR-P.
The Bank ensures transparent
communication of its policies with
consumers. All communications activity
(including contracts and terms and
conditions) within the Bank is guided
by regulation, including the Consumer
Protection Code 2012, the Advertising
Standards Association of Ireland Code
7th Edition, and the values and operating
principles set by the Association of Irish
Market Research.
All information on product contracts
and terms and conditions is written in
plain English and is highly governed
and approved by the Central Bank of
Ireland. The Bank adheres to all of its
regulatory requirements and meets
all of its commitments in relation to
contracts and Terms and Conditions
of products or services. As part of
the sales journey, detailed Terms and
Conditions are provided to customers.
These are available on our website and
are represented in our marketing material
in line with the guidance set out in
regulation.
S4-MDR2-A Actions and
resources in relation to
Customer Experience
The Bank is committed to delivering
enhanced customer support, data
protection, information security, and
colleague conduct to ensure high
standards of service, compliance, and
trust. An overview of the actions taken
can be found below.
Through our Sustainability Strategy,
PTSB is dedicated to championing our
customers and creating a Bank that is fit
for the future. This is achieved through:
• Understanding the needs of our
customers and ensuring that the
products and services we provide allow
all people, including those who may be
vulnerable or underrepresented, equal
opportunity to access them;
• Maintaining our branch presence in
communities across the country;
• Offering digital support to our
customers through our product
journeys, including introducing a Digital
Current Account and Digital Mortgage
Journey;
• Ongoing compliance with the Bank’s
regulatory requirements such as
General Data Protection Regulation
(GDPR), the Consumer Protection Code
(CPC) and Anti-Money Laundering and
Countering the Financing of Terrorism
Legislation etc; and,
• Ensuring Responsible Marketing and
Research.
PTSB Group Holdings plc - Annual Report 2024
215
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Actions related to managing
Cybersecurity risk and Data
Protection
The Irish banking landscape is evolving,
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 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.
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, PTSB has its own Data
Protection Policy in place which sets out
our approach.
Ensuring data protection is considered
as part of change programmes, raising
awareness and providing ongoing
education and training to our people are
critical ways in which we mitigate against
data protection risk.
Customer Supports to Deliver a
Superior Customer Experience
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.
Encouraging Financial Wellbeing
The following measures are in place to
support customer financial wellbeing:
• As part of our partnership with Irish
Life, all customers can avail of a free
financial review, focused on supporting
them in making informed financial
decisions. Through our partnership
with Irish Life, in 2024 we completed
c.12,000 financial reviews, both in-
person and through our digital channels,
to support customers in taking control
of their financial future; and,
• Through our partnership with Leading
Ireland’s Future Together (LIFT) Ireland
the Bank aims to build and strengthen
young people’s behaviours around their
futures through our support of the
delivery of a new ‘Minding Our Futures’
Pilot Programme, focused on the
themes of Sustainability and Financial
Wellbeing. The Pilot has been rolled out
in 10 schools across Ireland and will
be live through the 2024/25 academic
year.
Enabling Accessibility of Our Products
and Services
The following measures are in place to
provide appropriate access and support to
our customers including:
• A set of Vulnerable Customer Guiding
Principles and an Enhanced Customer
Support Policy and Framework to
enable us to meet the needs of
customers who may require additional
support and care and to provide
guidance and support to our colleagues;
• Vulnerable Customer Appointment
Booking Service. A dedicated webpage
for customers requiring enhanced
support, outlining the services available
and providing detail in relation to how
they can be accessed;
• Enhanced Customer Support Charter
for all colleagues;
• Support for the most vulnerable when
moving their banking relationship
as set out in ‘A Guide to Moving
Banks for Customers in Vulnerable
Circumstances’;
• Provision of an Enhanced Customer
Support Team;
• Creation of an internal digital hub
for staff with training and supports
including Assisted Decision-Making
(Capacity) Act 2015 Resources and
Supports, policies and procedures,
internal communications and links to
external supports for all colleagues
across the Bank;
• In our Retail Network, our branches are
designed with accessibility in mind;
• A Sign Language Interpreting Service
(SLIS) for customers to interact with us
via interpreter services in our branch
and over the phone;
• Working with Inclusion and Accessibility
Labs (IA Labs) and the National Council
for the Blind (NCBI) towards Web
Content Accessibility Guidelines 2.1
level AA certification in order to provide
a website that is accessible to the
widest possible audience, regardless of
technology or ability;
• Web Accessibility Advice Guidelines
offering customers simple ways to
make it easier to view content on our
web pages including changing font size,
colours and browser zoom options;
• A webchat service providing alternative
ways to access the help and support of
our Customer Support Team;
• In a global banking first, we introduced
'PTSB Protect' in October, a new feature
to our banking app which will help
prevent customers falling victim to
fraudulent scams;
• PTSB 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 that they need ‘Just
a Minute’ discreetly and easily when
in public settings like shops, public
transport or their local PTSB branch;
and,
• PTSB has become the first financial
institution in Ireland to be accredited
with Autism-Friendly branches in
four locations across the country
and announcing a wider multi-year
partnership with AsIAm, Ireland's Autism
Charity, that will enable the charity
to further support autistic customers
and families and to promote and drive
greater inclusivity in Irish society.
ESRS S4 – Consumers and end-users (continued)
PTSB Group Holdings plc - Annual Report 2024
216
Sustainability Statement
Digital Transformation
Personal service will remain at the heart
of our service offering for customers. .
However, as customer needs continue
to evolve, digitalisation is playing an ever
increasing role in our service offering.
Throughout 2024, we continued to
invest in improved customer experiences
through our technology and digital
channels Actions taken include:
• Modernising our technology
architecture;
• Renovating our core banking platforms;
• Ensuring continuous improvement in
our Digital Current Account and Digital
Mortgage Journeys;
• Adopting customer-led research
and prototyping practices, ensuring
our digital propositions are validated
directly with our customers; and,
• Creating in-app feedback mechanisms
allowing customers to share their
experiences in real time, enabling us
to iterate and improve in response to
customer needs.
Vulnerable Customers
Please refer to S4-MDR2-A for an
overview of the Bank’s approach to
mitigate against negative impacts to
vulnerable customers.
Enhancing Brand and Reputation
In October 2023, the Bank launched a
major overhaul of brand and customer
positioning for the first time in over
20 years. Key elements of the change
included:
• A complete rebranding of the Bank as
PTSB, an acronym of the Bank’s full
name and previous brand permanent
tsb;
• The introduction of a new customer
promise – ‘Altogether More Human’; and,
• The new brand name and visual identity
is being phased in across the Bank’s
operations and will feature across
primary branch locations, customer
touchpoints and digital platforms,
communications and advertising.
The new brand positioning emphasises
PTSB’s intentions as a full-service
Personal and Business Bank, bringing
technology and people together to solve
real customer needs and deliver a better
banking experience. The continued
investment into our branches has allowed
us to better serve our customers via
our in-person channels. Our refurbished
branches now have enhanced digital
capabilities including, digital marketing
screens that reduce our reliance on print
marketing, new Open 24 kiosks with
enhanced capabilities, 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.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of PTSB’s customer
experience activity. PTSB has not
disclosed these figures publicly.
S4-MDR2-M Metrics in relation
to Customer Experience
The Bank uses the following metrics to
evaluate performance and effectiveness
in key areas such as enhanced customer
support, data protection, information
security, and conduct.
Metrics specific to Cybersecurity and
Data Protection
• All colleagues engage in compulsory
Data Protection training each year. In
2024, c.100% of colleagues completed
the training with an 80% pass rate
requirement.
Metrics specific to Superior Customer
Experience
• There is a Customer Experience
Objective recorded in all colleagues
Performance Management Objectives;
• A Relationship Net Promoter Score
(RNPS) measures the willingness of
customers to recommend a company’s
products or services to others.
• A customer brand tracking survey
carried out in 2024 indicated that the
Bank’s RNPS Score increased +10%
in 2024. Customer Experience RNPS
targets are set annually and allocated
quarterly. Benchmarking of targets is
provided by Medallia, the Bank's ‘Voice
of the Customer’ Programme platform.
The Bank has a zero tolerance for
deliberate and/or repeated poor or
unfair customer outcomes (financial or
nonfinancial), 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.
S4-MDR2-T Tracking
effectiveness of policies and
actions through targets
The Bank uses the following targets to
evaluate performance and effectiveness
in key areas such as Enhanced Customer
Support, Data Protection, Information
Security, and Conduct.
Targets specific to Cybersecurity
and Data Protection
• The Bank’s target is that 100%
of colleagues will complete Data
Protection training each year.
Targets specific to Superior
Customer Experience
The Bank has Targets in place for the
following:
• A target for Customer Experience is
set annually as part of our colleagues’
Performance Management Objectives. It
is monitored at regular intervals through
the Bank’s Performance Management
Process;
• The Bank has targets in place for
RNPS and TNPS across all customer
channels. These targets are tracked
and reported quarterly to the Customer
Committee, Executive Committee and
Board via the Customer Strategy and
Experience Report, which travels to
Customer Committee, the Executive
Committee and the Board on a regular
basis. PTSB has not disclosed these
targets publicly; and,
• The Bank has a zero tolerance for
deliberate and/or repeated poor or
unfair customer outcomes (financial
or nonfinancial), or any market impact
which arises through inappropriate
actions, or inactions in the execution of
our business.
PTSB has not disclosed these targets
publicly.
PTSB Group Holdings plc - Annual Report 2024
217
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Governance
GOV-1 The role of the
administrative, supervisory
and management bodies
PTSB defines its administrative,
management, and supervisory (AMS)
bodies as the Board, the Executive
Committee, and their respective Sub-
Committees. The Board's Sub-Committees
include the Audit Committee, Risk and
Compliance Committee, Remuneration
Committee, and the Nomination, Culture,
and Ethics Committee.
The Executive Committee's Sub-
Committees include a number of
committees, including the Sustainability
Committee, which is responsible for
oversight of the delivery of PTSB’s
Sustainability Strategy.
PTSB is committed to operating
responsibly and conducting our business
to the highest ethical and professional
standards. We are focused on upholding
the highest standard of conduct and
behavior among our people.
The Individual Accountability Framework
(IAF), introduced by the Central Bank of
Ireland (CBI) in 2023, aims to enhance
accountability in financial services
through three key components: the
Senior Executive Accountability Regime
(SEAR), the IAF Conduct Standards, and
enhancements to the Fitness and Probity
(F&P) Regime.
• SEAR is designed to improve
governance, performance and
accountability in Financial Services
firms by obliging firms and colleagues
in Pre-Approved Controlled Function
(PCF) roles to clearly document where
responsibility and decision making lie in
the firm. This includes the roles within
the Bank that are sustainability-related
and promotes a culture of accountability
within the organisation. The PTSB SEAR
Handbook outlines how SEAR operates
within the Bank and sets out the steps
that PCFs, their teams and all relevant
stakeholders must take to manage the
obligations under the SEAR.
• The core function of the F&P Regime
is to ensure that individuals in key and
customer facing positions (referred
ESRS G1 – Business conduct
to in the legislation as Controlled
Functions (CFs) and PCFs within a
Regulated Financial Service Provider are
competent and capable, honest, ethical
and of integrity and financially sound.
The objective of the PTSB F&P Policy
is to clearly define the specific roles,
responsibilities and accountabilities
across the Bank in relation to the
implementation of F&P requirements.
• The IAF Conduct Standards require CF
role holders to take reasonable steps
to adhere to the standards of conduct
that the Bank (and by extension,
our customers and the CBI) expect
from each of us. PTSB is obligated to
establish, maintain, and give effect
to policies on how the IAF Conduct
Standards are integrated into the
culture and conduct of the affairs of
the Bank, as well as notify and train
in-scope colleagues on how the IAF
Conduct Standards apply to them. The
IAF Conduct Standards Policy sets
out the requirements across PTSB for
the embedding of the IAF Conduct
Standards. An IAF Conduct Standards
Handbook has been prepared by the
Bank which provides practical support
to colleagues in understanding the
concept of reasonable steps and
guiding them in understanding the
steps that are reasonable for them to
take to uphold the relevant IAF Conduct
Standards. This includes consideration
for sustainability, where required.
The following groups or individuals form
part of PTSB’s AMS bodies and support
the Bank in adhering to its Business
Conduct commitments.
The Board of Directors (Board)
The Board is collectively responsible
for the governance of the Bank and is
responsible for:
• Setting and overseeing performance
against strategy;
• Ensuring business activity aligns with
the Bank’s stated Purpose, Ambition,
Values and Culture;
• Setting and overseeing all risk,
financial, compliance and performance
standards; and,
• Demonstrating leadership, setting the
tone from the top.
For more on the roles and responsibilities
of the Board, please refer to ESRS 2,
Section 22.
Board Risk and Compliance
Committee (BRCC)
The BRCC oversees the company’s
risk management, ensuring risks are
identified, monitored, and managed within
the company’s Risk Appetite Statement
(RAS). It monitors compliance with laws,
regulations, and ethical standards,
overseeing policies on fraud prevention,
anti-money laundering, and regulatory
compliance. The BRCC supports the
Board on risk management and that the
Bank’s Strategy is consistent with the
Bank’s Risk Appetite. The Committee
focuses on operational resilience, the
incidence and management of material
risk events. It also reviews the company’s
engagement with regulators and the
effectiveness of risk management
controls.
Board Audit Committee (BAC)
The BAC monitors the effectiveness
and adequacy of financial controls,
risk management, and internal audit
processes. It reviews financial statements
to confirm they are accurate and fairly
represent the company’s financial
health. The BAC also oversees the
work of internal and external auditors
and considers the external auditor’s
independence and objectivity and the
effectiveness of the audit process. The
Committee reviews discoveries of fraud
and legal violations reported by the
internal audit team. Additionally, the BAC
review the company’s governance and
approval processes as they related to
financial statements, and internal controls
to ensure compliance with laws and
regulations, making recommendations to
the Board on approving financial reports
and maintaining transparency.
Nomination, Culture and Ethics
Committee (NomCo)
The NomCo is a dedicated Board
Committee with accountability for
culture, behaviour, ethics and reputation
management oversight in the Bank.
Directors must 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,
PTSB Group Holdings plc - Annual Report 2024
218
Sustainability Statement
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.
The NomCo receives regular updates on
key themes and issues reported through
the Bank’s Speak Freely process.
The Chief Executive Officer (CEO)
The Board delegates executive
responsibility to the CEO for PTSB’s
operations, compliance and performance.
The role of the CEO is to select and lead
an effective team to manage the Bank.
The CEO is required to provide information
and insight 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.
Executive Management Oversight
The Executive Committee (ExCo) is the
Senior Management Committee of PTSB
established by the CEO with authority
to operate and make decisions within
limits set by the Board. The 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 colleagues and other functional issues
and ensuring that a robust and resilient
operating framework exists within which
the Group’s activities are undertaken.
Senior Leadership Team
The ExCo is supported by the
Senior Leadership Team (SLT) in the
implementation of high standards of
operational and Business Conduct.
Members of the Bank’s SLT include
the heads of key business divisions
and functions, such as Retail Banking,
Risk, Compliance, Sustainability and
Corporate Affairs, Finance, Operations,
Technology, Human Resources, Product
and Marketing, Legal and Governance and
Secretariat. Together, the SLT ensures the
effective execution of the Bank’s strategic
objectives, adherence to regulatory
requirements, and alignment with the
principles of sound governance and
sustainability.
The ExCo’s Sub-Committees include the
Sustainability Committee. The SusCo is
responsible for the delivery of the Bank’s
Sustainability Strategy by ensuring that
there is sufficient oversight, alignment,
governance and challenge of activity
across key areas of focus for the Bank’s
overall sustainability programming.
Board
For an overview of the expertise of the
Board, please refer to ESRS 2-GOV-1.
Executive Committee
The relevant experience of each of the ExCo members is outlined below.
Name
Role
Relevant Experience
Eamonn Crowley
Chief Executive
Officer
• Please refer to ESRS 2-GOV-1.
Barry D’Arcy
Chief Financial
Officer
• Please refer to ESRS 2-GOV-1.
Ger Mitchell
Chief Customer
and People Officer
• Member of the Executive Committee since 2012.
• Held a number of roles at Executive level including HR, Products, Corporate Affairs,
Sustainability and Marketing.
• Role expanded to include the Bank’s Product and Pricing Strategy, which brings the
Colleague and Customer Experience together alongside the Marketing and Product
Strategy.
• Extensive experience in Acquisitions, Responsible and Sustainable Business,
Brand Positioning, Retail Banking, Product Marketing and Management, Consumer
Marketing, Business Transformation, Customer Remediation and Human Resources.
Andrew Walsh
Legal Council
• Member of the Executive Committee since 2015.
• Extensive legal advisory experience, in both private practice and in-house roles.
• Former partner in a leading corporate Irish law firm, advising a number of Irish and
international banks and financial services institutions.
Claire Heeley
Head of Internal
Audit
• Chartered Accountant with over 20 years’ experience, joined the Bank in 2021 as the
Bank’s Head of Group Internal Audit.
• Former Managing Director, Risk and Regulatory Consulting in KPMG, leading major
risk transformation projects and the delivery of internal audit services to a portfolio
of financial services clients for over six years.
• Former Retail Division Audit Partner in the Group Internal Audit division of Bank of
Ireland and Deputy Group Secretary of Bank of Ireland.
PTSB Group Holdings plc - Annual Report 2024
219
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Name
Role
Relevant Experience
Tom Hayes
Chief Technology
Officer
• Former AIB Head of Digital Transformation Delivery.
• Former AIB Head of Customer Engagement Technology.
• Former AIB Digital and Group Head of IT Infrastructure and Operations.
Patrick Farrell
Chief Retail
Banking Officer
• Over 25 years’ experience across the banking industry.
• Former PTSB Retail Banking Director.
• Previously held senior management roles in Strategy, Product and Proposition
Development, Marketing, Private Banking and Retail Sales and Service Distribution.
Peter Vance
Chief Operations
Officer
• 25 years’ experience in Financial Services.
• Held senior positions as Head of Group Operations and Executive Head of Direct
Sales and Service Channels in AIB.
• Responsible for leading multiple activities in both Ireland and the UK including
Payments, Treasury services, Financial Crime, SME Lending and the Customer
Service Centre.
Leontia Fannin
Chief
Sustainability and
Corporate Affairs
Officer
• 20 years' experience in Corporate Affairs, Reputation Management, Colleague
Communications, Sponsorships, Corporate Social Responsibility and Sustainability.
• Joined the Bank in 2018 as Head of Corporate Affairs and Communications and
has led out on a number of the Bank’s key strategic initiatives, including PTSB’s
Reputation Management, Sponsorship and Sustainability Programmes.
• Appointed to the Bank’s Executive Committee in August 2024 and is responsible for
leading the Bank’s Sustainability and Corporate Affairs Strategies.
• The role of Chief Sustainability and Corporate Affairs Officer was created to reflect
the Bank’s commitment to sustainability as a key driver of its corporate strategy
and the value it places on corporate affairs as enabler of internal and external
stakeholder engagement.
Impact, risk and opportunity
management
IRO-1 Description of the
processes to identify and
assess material impacts, risks
and opportunities
Please see ESRS 2-IRO-1 for an outline
of the process to identify material IROs in
relation to Business Conduct matters.
G1-1 Business conduct policies
and corporate culture
The Bank’s Frameworks and Policies on
Business Conduct are integral to operating
our business in a responsible way and are
aligned with our corporate culture and
values. Relevant Frameworks and Policies
include:
• Conduct Management Framework
• IAF Conduct Standards Policy
• SEAR Handbook
• PTSB Fitness and Probity Policy
• Colleague Conduct Policy
• Code of Ethics
• Speak Freely
• Human Rights associated Codes and
Charters
• Conflict of Interest
• Financial Crime Compliance Framework
• Anti-Money Laundering/ Terrorist
Financing Policy
• Anti-Bribery and Corruption Policy
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
PTSB is committed to, and actively
involved in, improving culture across the
banking industry as a member of the Irish
Banking Culture Board (IBCB), since it was
established in 2018. The purpose of the
IBCB, which operates as an independent
body that is chaired by Justice John
Hedigan, is to work with member banks
to build trustworthiness in the sector to
develop a sustainable banking industry.
The IBCB are focussed on promoting
and measuring an environment of
ethical behaviour, ensuring fair customer
outcomes are achieved, and supporting
employees of the Banks across the Irish
Financial Services Sector. The Board
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
220
Sustainability Statement
includes representation from the three
Irish Retail Banks.
Throughout 2024, we continued our
contribution to, and support of, the IBCB
and its programme of work, including:
• Playing an active role in IBCB
workshops focussed on addressing key
challenges across the sector;
• Participating in the IBCB’s ‘Proud to
Work in Banking’ Awards, which were
established in 2024 to recognise
staff across member banks whose
behaviours align with the IBCB’s values;
and,
• Embedding the industry wide DECiDE
(Ethical Decision Making) Framework as
part of our Code of Ethics.
At PTSB, we describe our culture as the
way we do things: We are Open. We are
Inclusive. We build Trust. We are One
PTSB.
Our cultural evolution is a strategic priority
as it influences how people experience
our Bank; what it’s like for customers to
engage with us, for our colleagues to work
with us and for our communities to live
with us.
Over the last number of years, we have
been on a journey to improve the culture
of our organisation. Progress includes:
• The development of the Our Culture
Charter and 12 Culture Enablers, which
ensure that all colleagues have a
consistent understanding of our culture
and the expectations of them. It sets
out our purpose, values, ambition and
brand promise, as well as the beliefs
that guide colleague interactions to
support the delivery of our ambition
and the service of our customers. Our
12 Culture Enablers help to nurture and
improve our culture;
• The creation of a psychologically safe
environment through Speak Freely.
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;
• The establishment of our People
Experience Council (PEC). As a group
of leaders within the organisation,
across multiple levels and functions,
PEC members are empowered and
mandated by their ExCo member to
work with teams in their area as they
seek to drive and support positive
cultural and behavioural change. The
PEC members listen to colleague
feedback, work to support the culture
evolution in their function to address
behavioural inconsistencies across the
Bank, and to improve trust with our
customers;
• The launch of the ‘Our Customer Yes
Checks’, which are designed to improve
decision-making by helping colleagues
weigh up the impact and consider the
consequences of decisions before they
are made;
• As a key strategic pillar since 2017,
our commitment to Diversity, Equity
and Inclusion is evidenced through
our Gold Accreditation for Investors in
Diversity awarded by the Irish Centre
for Diversity;
• The achievement of the IBEC KeepWell
Accreditation, to support our Wellbeing
Strategy and our commitment to
colleague wellbeing; and
• To support colleagues in role-modelling
our values through their behaviours,
our Living as Leaders Programme,
utilises a self-reflective roundtable table
approach with our behaviour articles
that can be found in the Bank’s Living as
Leaders booklet. Through completing
the Programme colleagues become
more self-aware of their own actions
and behaviours.
Speak Freely
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.
As part of our Speak Freely Procedure we
have several different channels through
which a concern can be raised.
To continue to deliver on our Speak Freely
Strategy, in 2024 the Bank delivered
several initiatives to further educate, track
and highlight examples of speaking up,
including:
• Celebrating its first Speak Freely Week,
which saw significant engagement from
colleagues across the business on the
various initiatives taking place. The
activities included launching new Speak
Freely videos with our Board, Exco and
colleagues from across the business
and the provision of physical and digital
Speak Freely materials (brochures,
posters, pins etc.) to all locations.
Training, information sessions and a
guest speaker session were also held;
• Ensuring a stronger customer focus.
This year saw a greater link with the
customer and ensuring that colleagues
are raising process improvements for
customers through dedicated Customer
Speak Freely Champions;
• Training People Managers and Speak
Freely Champions on Speak Freely and
protected disclosure procedures and
colleague conduct;
• Delivering mandatory conduct training
to all colleagues, which included further
awareness and focus on Speak Freely;
• Embedding of the Irish Banking Culture
Boards’ DECiDE Framework on ethical
decision making and the Bank’s Culture
Charter; and,
• Half yearly reporting on Speak Freely
concerns to the Exco and Board.
The Bank has in place procedures to deal
with any protected disclosures that may
arise, including associated investigation
practices. Where potential incidents arise
in the investigation process, requirements
are outlined within the Speak Freely
Procedure and managed independently
and objectively by Bank’s People
Experience Team. The Bank seeks to
identify, thoroughly investigate, remediate
and report any incidents of corruption and
bribery in a prompt manner.
The Bank has in place additional Policy
documents that help to encourage the
right behavior, including Conflict of
Interest, Anti-Money Laundering/Terrorist
Financing, Sanctions and, Anti-Bribery and
Corruption. For more information on policy
contents please visit ESRS 2-MDR-P.
PTSB Group Holdings plc - Annual Report 2024
221
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The requirement for high standards of Business Conduct is reinforced through annual training which is delivered to all colleagues
annually. The training modules covered are outlined in the following tables:
Mandatory e-Learning
Mandatory E-Learning Course Title
Completion Rate1 %
Audience2
Operational and IT Risk Awareness
100%
All
Operational Resilience
100%
All
Mortgages
100%
Cohort 1
Term Lending
100%
Cohort 1
Data Protection
100%
All
Savings and Investments
100%
Cohort 1
Transactional Banking
100%
Cohort 1
Security at PTSB
100%
All
Asset Finance
99%
Cohort 1
Business Banking
95%
Cohort 1
Fraud Awareness
99%
All
Bibby Invoice Finance
100%
Cohort 2
Anti-Money Laundering, Countering the Financing of Terrorism and Sanctions
97%
All
Code of Conduct on Mortgage Arrears
100%
Cohort 3
Advertising Compliantly
100%
Cohort 4
Customer Complaints
92%
All
Individual Accountability Framework
99%
All (except CF2 to
CF11 colleagues)
IAF Common Conduct Standards
100%
CF2 to CF11
colleagues
Colleague Integrity and Ethics
89%
All
Diversity, Equity and Inclusion Awareness
89%
All
Conduct Risk – The Risk of Unfair Customer Outcomes
78%
All
Notes:
1
The completion rate can be over 100%; when course allocations are assigned at the beginning of the course and new joiners then are allocated this training as
mandatory and complete it but were not present in the original assignment list.
2
PTSB’s colleagues are classified into appropriate cohorts based on their roles and responsibilities within the organisation. Additionally, where relevant, the
Bank’s colleague roles are aligned to the 11 Controlled Functions (CF) as outlined by the Central Bank of Ireland.
3
The Institute of Bankers (IOB) is a professional network of over 32,900 members who work in banking and the international financial services sector. The IOB is
a recognised college of University College Dublin and is a centre of excellence in the provision of specialist education to the financial services sector.
The above table outlines all mandatory online training. In addition, additional training to colleagues which is deemed relevant to their
roles and responsibilities. This includes training provided in-house and using external training providers. This training is not currently
centrally logged.
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
222
Sustainability Statement
Additional Training Courses
Course Title
Completion Rate %
Audience
IAF Common Conduct Standards and Additional Conduct Standards
100
PCF & CF1 role
holders
Board and ExCo Training
Training and Content
Completion Date
Training Session Briefing
• ECB Policy Statement
• Digital Operational Resilience Act (DORA) Regulation
• Cyber Security Awareness Training
Q1 2024
Training Session
• Digital Operational Resilience Act (DORA)
Q1 2024
Training Session
• IRB Capital Model Programme
• Understanding Modelling Part I
Q2 2024
Training Session
• IRB Capital Model Programme
• Update Part II
Q2 2024
Training Session
• IAF Conduct Standards
• Annual Legal and Regulatory Update: Market Abuse Training and UK Corporate
Governance Code.
Q3 2024
Training Session
• ICAAP/ILAAP: ‘The implications of an effective ICAAP / ILAAP (‘So What’) to
the Strategic Planning Process, Decision Making, Risk Management and Risk
Appetite'.
Q4 2024
Integration with
Board Strategy
Day
• Anti-Money Laundering (AML)
• Counter Terrorist Financing (CTF)
• Anti-Bribery and Anti-Corruption
Q4 2024
Training Session
• Sustainability: Science Based Targets Briefing
Q4 2024
Training Session
As a Retail Bank, PTSB manages risk
in respect of corruption and bribery
where employees are processing loan
applications, particularly those that may
be deemed as high risk. This presents
a risk to the Bank from a regulatory,
reputational, credit and operational
perspective. The Bank actively promotes
a culture of integrity throughout our
operations, providing regular training
to mitigate any risks associated with
corruption and bribery. You can read more
about associated Compliance policies,
actions, targets and metrics in G1-MDR1.
G1-2 Management of
relationships with suppliers
Sustainable Sourcing and Procurement is
at the heart of the Bank’s Sustainability
Strategy and ensuring that we purchase
goods and services and engage with
our suppliers in a sustainable way is
fundamental to its delivery.
Our Procurement Policy sets out a
Framework for engaging with our
suppliers, including a commitment
to procure goods and services from
those who can support the needs of
our business in a sustainable manner.
The Framework is supported by our
Sustainable Supplier Charter, which sets
out our expectations of suppliers and acts
as a ‘Code of Conduct’ detailing what is
expected from all suppliers with regard to
business practice and responsibilities as a
supplier to PTSB.
We have categorised our Sustainable
Supplier Charter into the following 7 core
areas, in line with ISO20400 which outline
our expectations of suppliers of PTSB.
They include:
• Environmental;
• Human Rights;
• Operating Practices;
• Labour practices;
• Supply Chain;
• Social; and,
• Health, Safety and Wellbeing.
PTSB Group Holdings plc - Annual Report 2024
223
Strategic Report
Governance
Sustainability
Financial Statements
General Information
You can view the Bank’s Sustainable
Supplier Charter online.
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 and facilitating due diligence
activities to ensure they meet our
minimum standards.
Through our business practices and
continuous supplier engagement, we seek
to implement strategies and procurement
practices that create mutually beneficial
relationships. We set objectives and
action plans that support sustainable
procurement and look to continuously
improve the impacts of our supply chain.
The Procurement team has participated
in a number of sustainability-related
training courses that have been delivered
internally within the Bank and have also
engaged in training activity that has been
delivered by our third party procurement
partners.
We do not utilise any business incentives
throughout the sourcing or procurement
journey and all onboarding activity
is subject to evaluation, with bidder
submissions being scored from a
capability, commercial and environmental,
social and governance (ESG) perspective.
We conduct assessments of potential
suppliers through mandatory questions
that are included in our tendering
processes and through on-boarding to
our FSQS (Hellios). The Bank’s FSQS, is an
external third party system that contains a
number of questions related to ESG where
suppliers provide specific compliance data
and additional organisation information
to facilitate due diligence activities.
This initiative ensures that we have a
consistent view of relevant suppliers
and their adherence to the minimum
standards that we require, allowing the us
to manage supplier compliance. Questions
relate to Sustainability policies and plans,
energy and water consumption, employee
training, modern slavery, business
continuity, amongst others.
Completion of the FSQS Questionnaire is
mandatory for all suppliers working with
PTSB. The Bank encourages Suppliers
and third parties to put in place their own
Sustainable Procurement Framework
in line with ISO20400 and be certified
(or working towards certification) to
ISO45001, the internationally recognised
Occupational Health and Safety
Management Standard.
The Bank prefers to work with suppliers
within the European Economic Area
(EEA), but at present, do not have an
official Policy in place that sets out this
expectation.
G1-3 Prevention and detection
of corruption and bribery
Within its Risk Register, PTSB has
identified that there is a Regulatory Risk
and a Reputational Risk of failing to ensure
adequate procedures against corruption
and bribery. Business Units across the
Bank are tasked with preventing and
detecting incidents of corruption and
bribery.
The Bank has a Financial Crime
Compliance Framework designed to cover
Anti-money Laundering/Counter Financing
of Terrorism (AML/CFT), Sanctions and
Anti-bribery and Corruption (ABC) risk
management, with formal roles assigned
to our Regulatory Compliance Team, as
well as to all colleagues and contractors
within the Bank. This Framework
incorporates a dedicated ABC Policy
which outlines how the Bank’s various
ethical processes and procedures operate
to address corruption and bribery risk.
PTSB operates Three Lines of Defence
Model against all risks, including
corruption and bribery. Please refer to
ESRS 2-GOV-1 for further details.
The Bank applies several processes
to identify and reduce the potential
corruption and bribery risk within its
business. This includes previously
mentioned Policies and Frameworks
including, Financial Crime Compliance
(including Anti-Money Laundering/
Terrorist Financing; Sanctions and Anti-
Bribery and Corruption), the Individual
Accountability Framework Conduct
Standards Policy, SEAR Handbook,
Colleague Conduct Policy, Code of
Ethics, Conflict of Interest, and Speak
Freely, aimed at supporting our teams to
prevent, detect and address allegations
or incidents of corruption and bribery.
For more information on policy contents
please visit ESRS 2-MDR-P.
Allegations or incidents of corruption and
bribery are thoroughly investigated by the
Bank.
This investigation may include those
stakeholders with expertise from
legal, compliance, and HR. While it is
recommended that reporting be made
to line management, where possible, the
Bank also maintains reporting channels
where this is not possible through the
Speak Freely Procedure. This process
outlines that reports can also be directly
made to the Head of Financial Crime
Compliance via dedicated channels.
This approach ensures appropriate
segregation, should employees feel that
this is required.
The Bank maintains mandatory reporting
lines for all financial crime compliance
matters. All anti-bribery and corruption
events are assessed and escalated in the
same manner as other risk issues and
include supervisory engagement where
appropriate.
The Bank would deem that 100% of
functions would be at risk of corruption
and bribery. The Bank actively promotes
a culture of integrity throughout our
operations, providing regular training
to mitigate any risks associated with
corruption and bribery. The training
includes details that are relevant to the
policies that are in place. Associated
policies, actions, targets and metrics are
outlined in G1-MDR1.
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
224
Sustainability Statement
Metrics and Targets
G1-4 Incidents of corruption or
bribery
Please refer to G1-MDR1 for actions
and resources implemented to manage
material IROs.
The Bank has not been convicted of any
violations related to anti-corruption and
anti-bribery laws during the reporting
period. As such, there were no fines for
violation of anti-corruption and anti-
bribery law and no actions were required.
G1-5 Political influence and
lobbying activities
PTSB is registered as a lobbyist and, as
such in accordance with its obligations
under the Regulation of Lobbying Act
2015 and the Lobbying Amendment Act
2023 (the ‘Acts’), the Bank must publish
material details of its lobbying activities
with certain categories of Designated
Public Officials (DPOs) on the ‘Register
of Lobbying’ (the Register). The Register
is publicly available on the Lobbying.
ie website and is maintained by the
Standards in Public Office Commission
(SIPO).
PTSB has in place a Lobbying Policy
which outlines the Bank’s obligations
regarding lobbying activities as related
to the Acts. The Policy Sponsor is the
Chief Sustainability and Corporate Affairs
Officer, and the Policy Owner is the
Senior Manager, Corporate Affairs and
Communications.
The Directors have satisfied themselves
that there were no financial or in-kind
political contributions during the year,
which require disclosure under the
Electoral Act, 1997.
PTSB is not registered on the EU
Transparency Register. However, as a
publicly listed plc, PTSB Group Holdings
(PTSBGH) is subject to disclosure and
transparency requirements in Ireland
and the EU which includes submission of
information to the Companies Registration
Office Ireland, Beneficial Owners Register,
Stock Exchanges in Dublin and London,
and associated Regulatory Authorities
(competent authorities).
No members of the Bank’s AMS body
held a comparable position in public
administration (including regulators) in the
2 years preceding such appointment in
the current reporting period.
G1-6 – Payment practices
The Bank’s Payment Policies are aligned
to the Prompt Payment of Accounts
Act, 1997 as amended by the Statutory
Instrument 580 of 2012, which took effect
on 16 March 2013 and transposes EU
Directive 2011/7/EU on Combating Late
Payment in Commercial Transactions.
This provides for a payment period of 30
calendar days following the date of receipt
of the invoice or an equivalent request for
payment.
The Bank performed an analysis of its
supplier payments which identified that
of the 41 contracts that make up 70% of
total spend on suppliers, 33 (80%) have a
standard payment time of 30 days.
There are currently no identified legal
proceedings in relation to outstanding late
payments during the reporting period.
G1 Minimum Disclosure
Requirements
As part of the development of the
Bank’s IROs, we identified similar themes
emerging, and the MDRs have been
consolidated under thematic headings.
The three themes under which we
disclosed our material Governance
IROs are: G1-MDR1 Compliance; G1-
MDR2 Managing Suppliers; and, G1-
MDR3 Sponsorships and Community
Partnerships.
G1-MDR-1 - Compliance
The IROs reflected in G1 MDR1 are outlined below.
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-6
Impact
The impact on society and the
environment due to the financing of
criminal activity.
A bank financing criminal activity
has significant and far-reaching
consequences on the bank and
society through the financing of
illegal and unethical organisations
that may engage in criminal activity or
environmental degradation.
Negative
Potential
R-4
Risk
Cyber Security Risk: The risk of
unauthorised access, modification,
malicious disruption or use of IT
systems and data from within or
outside the Bank (for example, cyber-
attacks).
Elements of this risk have been
mapped to the corporate culture and
Business Conduct subtopics. These
relate to failure to implement robust
data protection and information
management systems and employees
not following procedures leading
to non-compliance with regulatory
requirements, reputational damage
and financial loss.
n/a
n/a
PTSB Group Holdings plc - Annual Report 2024
225
Strategic Report
Governance
Sustainability
Financial Statements
General Information
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-5
Risk
Fraud Risk: The risk of losses or
unplanned gains arising from acts
intended to defraud, misappropriate
property, circumvent regulations, the
law or company Policy by either an
internal party or external parties or a
combination of both.
Elements of this risk have been
mapped to the protection of
whistleblowers and corruption and
bribery subtopics. These relate to a
failure to have adequate procedures
against corruption and bribery as well
as a lack of whistleblower protection,
potentially resulting in reputational
damage and issues with regulatory
compliance.
n/a
n/a
R-7
Risk
People Risk: The risk of financial,
operational or reputational damage
to the Bank arising from failure of
the Bank to meet its employment
obligations and duty of care to staff
or the failure to ensure adequate
resources and or skills are in place,
that succession planning is not
effective or that the operation of the
Bank may be impacted by labour
disputes.
People Risk has been identified as a
key risk by PTSB. Elements of this risk
have been mapped to the Corporate
Culture and Business Conduct
subtopics. These relate to poor
culture; inadequate remuneration
harming workforce retention; lack
of transparent work environment,
reducing trust and communication;
regulatory compliance including
health and safety; human rights and
protections against discrimination
requirements; and lack of
engagement with unions.
n/a
n/a
R-8
Risk
Process and Ability to Execute
Risk: process and execution risk
can significantly impact PTSB’s
operational risk, leading to higher
loss risk, impacting operational
resilience, customer dissatisfaction,
a loss of trust and limits the ability
to realise stated ambition (especially
against the risk of optimistic bias
in forecasting). Risk is linked with
internal complexity, a high volume
of change, increasing collaboration
with third parties and outsourcing
providers, people risk and transition
speed. Making end to end processes
more digitally straight forward is
necessary to reduce complexity and
embed / automate controls, and
consistent customer service quality.
Elements of this risk have been
mapped to the Corporate Culture
and Business Conduct sub-topics.
These relate to adequate resources;
effective processes and controls;
well managed IT systems to meet
its wide range of demands including
regulatory requirements; customer
demands; failing to consider needs
of the communities; operational
risks; and, people management risks
including third parties.
n/a
n/a
R-9
Risk
Regulatory Compliance Risk: 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
change to, official sector policy, laws,
regulations, major industry standards,
compliance policies and procedures
or the expectations of customers and
stakeholders.
Regulatory Compliance has been
identified as a key risk by the
Bank. Elements of this risk have
been mapped to Protection of
Whistleblowers/ Corruption and
Bribery/Political Engagement sub-
topics. These relate to ethics and
conduct, political contributions,
protection of whistleblowers, political
contributions, data protection
measures (for example, GDPR).
n/a
n/a
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
226
Sustainability Statement
G1-MDR1-P Policies adopted to
manage Compliance
The Frameworks and Policies that support
PTSB in addressing the IROs under the
theme of compliance are outlined below,
with the exception of the policies relating
to corporate conduct which have been
discussed in G1-1-1. For more information
on policy contents and objectives, as
well as the most senior level role in PTSB
accountable for the implementation,
please refer to ESRS 2-MDR-P.
The Bank has in place Frameworks and
Policies to support PTSB in mitigating
against the financing of criminal activity,
ensuring effective Business Conduct and
maintaining compliance including:
• Conduct Management Framework
• Colleague Conduct Policy
• Financial Crime Compliance (FCC)
Framework
• Anti-Money Laundering/ Terrorist
Financing Policy
• Anti-Bribery and Corruption Policy
Framework and Policies are applicable
to all Business Units across the Bank. It
applies to all persons who work directly
for the Bank or who provide third party
services to PTSB.
The following Stakeholders are affected:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees (as defined in S1 Own
Workforce);
• Shareholders and Investors;
• Customers;
• Third party service providers;
• External stakeholders, including
Regulators and Supervisors who
require an overview of the regulatory
compliance management principles,
process, and governance arrangements;
and,
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
The Board is ultimately responsible for
ensuring that PTSB has a Framework
in place to prevent and detect money
laundering/terrorist financing and that
the Bank maintains an effective internal
control structure for compliance and
risk management. The Board delegates
oversight of the Bank’s Money Laundering/
Terrorist Financing, Sanctions and Bribery
and Corruption risk management (FCC
risk management) to the BRCC.
In line with the Board approved Internal
Control Framework, responsibility for
the review and onward recommendation
of the Anti-money Laundering/Counter
Financing of Terrorism-related policies
underpinning the FCC Framework
has been delegated to the GRC. The
GRC is responsible for end-to-end
execution, operation and testing of the
Group’s Internal Control Framework and
embedding internal controls to mitigate
identified risks.
The ExCo is the Senior Management
Executive Committee of the Bank as
outlined in G1-GOV-1.
PTSB is regulated and supervised by the
Central Bank of Ireland (CBI).
The Bank complies with relevant legal
requirements and CBI regulation,
including:
• The Criminal Justice (Money Laundering
and Terrorist Financing) 2010 (as
Amended);
• Criminal Justice (Corruption Offences)
Act 2018;
• Corporate Governance Requirements
for Credit Institutions 2015;
• UK Corporate Governance Code;
• Relationship Framework with Irish State;
• The Consumer Protection Code (CPC);
• Individual Accountability Framework
(IAF) Requirements;
• Senior Executive Accountability Regime
(SEAR);
• Common Conduct Standards and
Additional Conduct Standards; and,
• Fitness & Probity (F&P) Regime.
The Bank has in place Frameworks and
Policies to support PTSB in mitigating
against data breaches including:
• Data Protection Policy
• Regulatory Compliance Framework
• Information Security Policy
The Board delegates oversight of data
protection to the Data Protection Officer.
G1-MDR1-A Actions and
resources in relation to
Compliance
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 and
members of the ExCo.
PTSB 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, thereafter, conducting
enhanced due diligence reviews and
undertaking Politically Exposed Persons
(PEPs) and Sanctions screening in
accordance with our Policies.
To meet its obligations, PTSB implements
relevant Anti-money Laundering/Counter
Financing of Terrorism and Anti-bribery
and Corruption and maintains robust
oversight measures, with all elements of
the Framework operating as intended
throughout 2024.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated to
the delivery of compliance activity. PTSB
has not disclosed these figures publicly.
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
PTSB Group Holdings plc - Annual Report 2024
227
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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, PTSB 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
colleagues.
The Bank has in place procedures
to deal with data security breaches
and reports regularly to the Executive
Committee and Board. Ensuring data
protection is considered as part of change
programmes, raising awareness and
providing ongoing education and training
to our people are critical ways in which we
mitigate against data protection risk.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of data protection activity.
PTSB has not disclosed these figures
publicly.
G1-MDR1-M Metrics in relation
to Compliance
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions
towards the prevention of the financing of
criminal activity, ensuring data protection,
and enhancing the corporate culture
ensuring effective Business Conduct and
maintaining compliance:
• All colleagues engage in compulsory
Anti-Money Laundering, Countering the
Financing of Terrorism, and Sanctions
training each year. In 2024, c.97% of
colleagues completed the training with
an 80% pass rate requirement.
• All colleagues engage in compulsory
Data Protection training each year. In
2024, c.100% of colleagues completed
the training with an 80% pass rate
requirement.
• 76% Culture Index Score during 2024.
The Bank measures its Culture Index
Score through its annual Every Voice
Counts Survey. It is calculated from 20
specific questions with themes such
as Personal responsibility for Risk,
Feeling of Belonging and Managers and
Leadership behaviours.
There are no methodologies or
assumptions in deriving the above
metrics. The metrics are validated by the
Bank’s assurance provider.
In addition, the Bank monitors the usage
of our Speak Freely Procedure and
include this in our Key Risk Indicator
reporting, which particularly focuses on
a key indicator of trust – that colleagues
feel confident to raise concerns in a
confidential manner which is measured
through our EVC and Micro-pulse Surveys.
G1-MDR1-T Tracking
effectiveness of policies and
actions through targets
The following targets are utilised to assess
progress of the Bank’s actions towards the
prevention of financing of criminal activity,
ensuring data protection, and enhancing
the corporate culture ensuring effective
Business Conduct and maintaining
compliance:
• The Bank’s target is that 100% of
colleagues will complete Anti-Money
Laundering, Countering the Financing of
Terrorism, and Sanctions training each
year.
• The Bank’s target is that 100%
of colleagues will complete Data
Protection training each year.
• 70% Culture Index Score Target.
G1-MDR2 Managing Suppliers
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-7
Impact
The impact on society and the
environment by ensuring suppliers
are appropriately managed.
In its analysis, PTSB considered
impacts on society and the
environment related to supplier
management including supplier
due diligence and screening. These
sustainable procurement efforts have
been considered collectively as they
are all linked to ensuring suppliers are
appropriately managed.
Positive
Both
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
228
Sustainability Statement
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
R-6
Risk
Outsourcing and Third-Party Risk:
The risk of current or prospective
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 and
Communication (ICT) systems),
including lack of third party
diversification, inadequate business
continuity plans or insufficient
monitoring and oversight of the
engagement.
Elements of this risk have been
mapped to the managing supplier
relationships subtopic. These
relate to the impact of inadequate
due diligence, supply chain
dependency, poor management and
payment practices, and poor data
management.
n/a
n/a
R-11
Risk
Service Availability Risk: The risk that
the performance and availability of
IT systems and data are adversely
impacted (for example, customer
experience or business processes),
including the inability to recover the
Bank's services in a timely manner,
due to a failure or IT hardware or
software components; weaknesses in
IT system management; or any other
event.
Elements of this risk have been
mapped to Managing Supplier
Relationships subtopic. These relate
to poor management of third parties,
including payment practices, as
potentially contributing to the Service
Availability Risk associated with IT
hardware, software and system
management.
n/a
n/a
G1-MDR2-P Policies adopted to
manage Managing Suppliers
The Bank has in place Frameworks and
Policies to ensure our suppliers are
appropriately managed and to mitigate
the risk associated with outsourcing and
use of third parties, including:
• Third Party Management Framework
• Third Party Risk Management Policy
• Third Party Outsourcing Strategy
• Supplier Relationship Standards
• Sourcing and Procurement Policy
• Sustainable Supplier Charter
• Supplier Contracts
• Stakeholder Engagement Policy
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
The following stakeholders are affected:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees (as defined in S1 Own
Workforce);
• Shareholders and Investors
• Customers;
• Third party service providers;
• External stakeholders, including
Regulators and Supervisors who
require an overview of the regulatory
compliance management principles,
process, and governance arrangements;
and,
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
The Board is collectively responsible
for the governance of the Bank and has
delegated responsibility for supplier
management to the following committees.
Operational Risk Management
Committee (ORMC)
The ORMC is a sub-committee of the
Group Risk Committee (GRC) established
with delegated authority to operate
and make decisions in accordance with
the Terms of Reference approved by
the Bank’s Group Risk Committee. The
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, highlighting any risks
where required.
Third Party Management Committee
(TPMC)
The Bank’s TPMC is the governance body
accountable for formalising the Third
Party Management arrangements with
Third Party service providers. Their role
is to approve on-boarding of new Third
Parties over a certain risk threshold,
oversee the performance of existing
service providers, monitor Third Party
breaches, escalations and remediation
plans, and review material changes to
existing Third Party arrangements.
PTSB Group Holdings plc - Annual Report 2024
229
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The Bank demonstrates a strong
commitment to transparency and
accountability by actively respecting
a range of Third Party standards and
initiatives through its Policies, Standards
and Charters. For more information
regarding the Bank’s Sustainable Supplier
Charter and its use of a FSQS for supplier
due diligence, please refer to G1-2.
G1-MDR2-A Actions and
resources in relation to
Managing Suppliers
The Bank is focused on working alongside
its suppliers to find opportunities to
procure goods in a sustainable way. Key
progress during 2024 includes:
• Continuing to engage with all suppliers
through the expectations that we set
out in the Bank’s Sustainable Supplier
Charter;
• Including consideration for ESG within
our tendering processes through the
implementation of dedicated ESG
questions that are part of supplier
onboarding;
• Working alongside our procurement
partners, to continue to develop the
Carbon Cube; which takes spend
data and combines it with a category-
specific emission factor in order to
calculate supplier emissions in line with
the Greenhouse Gas (GHG) Protocol
methodology;
• Provision of a quarterly ESG dashboard
to the Chief Financial Officer and
Senior Management team within Group
Finance;
• Working with EcoVadis, a third party
sustainability rating company, regarding
procurement and supplier management
best practice; and,
• Delivering sustainable procurement
training to the Bank’s Sourcing and
Procurement Team.
During 2024, the Bank introduced a
Third Party Management Programme,
with the objective of providing a clear
and consistent approach to managing
Third Party providers through a redesign
of the Bank’s Third Party Framework.
The approach was focused on driving
value and empowering the organisation,
while minimising any potential adverse
outcomes for our customers, key
stakeholders or the Bank. A key part of
this Programme was the introduction of
a centralised Third Party Management
Team to support delivery of third party
management across the Bank.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated to
the delivery of managing suppliers. PTSB
has not disclosed these figures publicly.
G1-MDR2-M Metrics in relation
to Managing Suppliers
The following metrics are utilised
to evaluate the performance and
effectiveness of the Bank’s actions
towards ensuring that suppliers are
appropriately managed and to mitigate
risks associated with outsourcing and use
of Third Parties:
• Service Level Agreements and Key
Performance Indicators (relevant to
each supplier relationship) form part of
outsourced and Third Party Contracts;
and,
• Balanced scorecards are completed
each month by business owners
evaluating the performance of Third
Parties.
• A dedicated Third Party Management
Committee sits monthly to review Third
Party performance.
There has been no formal methodology
employed when designing the Bank's
supplier management governance metrics.
There are no significant assumptions
behind the metric. Supplier Management
metrics are not validated by an external
body other than the assurance provider.
These metrics are set and monitored
internally by the Bank.
G1-MDR2-T Tracking
effectiveness of policies and
actions through targets
At present, the Bank does not have any
targets assigned to evaluate performance
and effectiveness in relation to Managing
Suppliers in the context of Governance.
G1-MDR 3 Sponsorships and Community Partners
The IROs reflected in G1-MDR3 are outlined below.
IRO-Ref
IRO
Description
Details
Positive or
Negative
Potential or
Actual
I-8
Impact
The impact PTSB has
on society and local
communities through
engaging in community
partnerships, providing
charitable donations and
delivering the Bank’s
sponsorship rights activity.
PTSB recognises it’s potential for community
impact by providing financial support to
community organisations through the PTSB
Community Fund, building strong community
partnerships, engaging in employee
volunteering initiatives and delivering on the
Bank’s sponsorship rights commitments.
Positive
Both
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
230
Sustainability Statement
G1-MDR3-P Policies adopted
to manage Sponsorships and
Community Partners
The Bank has Frameworks and Policies
in place that help to ensure that our
community and sponsorship activity is
appropriately assessed and managed.
The application of these Frameworks and
Policies is monitored by their respective
Framework and Policy owners. Please see
below:
• Code of Ethics
• Speak Freely
• Conflict of Interest
• Third Party Management Framework
• Third Party Risk Management Policy
• Third Party Outsourcing Strategy
• Supplier Relationship Standards
• Sourcing and Procurement Policy
• Sustainable Supplier Charter
• Supplier Contracts
• Stakeholder Engagement Policy
• Community Policy
• Community Fund Constitution
• Employee Volunteering Policy
• Financial Crime Compliance Framework
For more information on policy contents
and objectives, as well as the most senior
level role in PTSB accountable for the
implementation, please refer to ESRS
2-MDR-P.
These Frameworks and Policies apply to
all the Bank’s community engagement
activity, including Community Fund
activity, Employee Volunteering and
Sponsorship initiatives. The following
Stakeholders have been considered in
their development and are affected:
• Members of the Board and its
Committees, Management Committees
and Risk Committees;
• All employees (as defined in S1 Own
Workforce);
• Customers;
• Sponsorship Rights Holders;
• Community Partners;
• External stakeholders who require
an overview of community and
sponsorship compliance management
principles, process, and governance
arrangements; and,
• Owners of interlinked Frameworks
and Policies who are responsible for
aligning their Frameworks, Policies, and
Procedures.
The Board is collectively responsible
for the governance of the Bank and has
delegated responsibility for Community
Partnerships and Sponsorships to the
following committees.
Executive Committee (ExCo)
The Executive Committee (ExCo) is the
Senior Management Executive Committee
of the Bank. It is chaired by the CEO and
has a primary role in providing assurance
to the Board of Directors and its
Committees on the financial performance
and integrity of the Bank’s businesses,
that the systems of internal control,
internal audit, financial reporting and IT
operate effectively, that process/systems
are in place to ensure all risks have been
correctly identified, that appropriate
controls are in place, and escalating
matters to the Board and its Committees,
where appropriate.
Sustainability Committee (SusCo)
The Bank’s Sustainability Committee acts
on delegated authority from the ExCo
to provide oversight on execution of the
Bank’s Sustainability Strategy, including a
focus on community engagement under
the ‘Elevating our Social Impact and
Connecting with Local Communities’ pillar.
Chief Sustainability and Corporate
Affairs Officer (CSCAO)
The CSCAO is responsible for leading the
development and implementation of the
Bank’s Sustainability Strategy in line with
regulation and supervisory expectation,
while ensuring all activity is aligned with
the Bank’s overarching Business Strategy
and purpose. The CSCAO chairs the
Bank’s Sustainability Committee and is
supported by a Head of Sustainability
and associated team who oversee the
implementation of the Bank’s community
activity.
For more on Governance, please refer to
ESRS 2-GOV-1.
As a regulated financial institution, the
Bank abides by the following:
• The Individual Accountability
Framework (IAF),
• Central Bank of Ireland (CBI) Consumer
Protection Act;
• Advertising Standards Authority of
Ireland (ASAI) Code; and,
• Broadcasting Authority of Ireland (BAI)
General Commercial Communications
Code (GCC).
G1-MDR3-A Actions and
resources in relation to
Sponsorships and Community
Partners
In 2024, PTSB continued to deepen its
community impact by providing financial
support to community organisations
through the PTSB Community Fund,
building strong community partnerships,
engaging in employee volunteering
initiatives and delivering on the Bank’s
sponsorship rights commitments. Key
highlights include:
• €19.4 million in social finance has been
made available to the SFF since 2009;
• Providing €360,000 in funding
during 2024 through the work of the
PTSB Community Fund. Since its
establishment, the Community Fund has
contributed c.€2.1 million in funding to
Irish community organisations working
to address social issues across the
country;
PTSB Group Holdings plc - Annual Report 2024
231
Strategic Report
Governance
Sustainability
Financial Statements
General Information
• Working alongside Community Partners
like LIFT Ireland, introducing a ‘Minding
My Future’ Module into their school
roundtable programme focused on
developing leadership capability across
the key themes of Sustainability and
Financial Wellbeing. ‘Minding my Future’
is new to LIFT Ireland’s programme and
is proudly supported by PTSB;
• A partnership with Dublin City University
Access Scholarship Programme and
Access to the Workplace Programme, to
support those from socioeconomically
disadvantaged backgrounds;
• Announcing our new 3-year partnership
with AsIAm, Ireland’s Autism Charity,
that will enable the charity to further
support autistic customers and families
and to promote and drive greater
inclusivity in Irish society. The Bank
has also become the first financial
institution in Ireland to be accredited
with Autism-Friendly branches in key
locations across the country;
• Encouraging employee volunteering
with registered charities across
Ireland through the PTSB Volunteering
Programme. More than 2,000
volunteering hours were provided
on the ground last year, equating to
c.€67,000 of in-kind giving; and,
• Delivering on our sponsorship portfolio
commitments, including the Bank’s Title
Sponsorship of the Irish Olympic Team
and Irish Paralympic Team for the 2024
Olympic Games in Paris.
All activity took place in the Republic of
Ireland, except for the activation of our
Title Sponsorship of Team Ireland which
took place in Ireland and in Paris, France.
The time horizon is January-December
2024.
As part of the development of the Bank’s
Integrated Strategic Plan, financial
investment and resources are allocated
to the delivery of community and
sponsorship activity. The budget allocated
considers resourcing that needs to be in
place to deliver on activity, as well as the
associated community programme and
sponsorship rights and activation fees
that are required as part of the contractual
rights. PTSB has not disclosed these
figures publicly.
G1-MDR3-M Metrics in
relation to Sponsorships and
Community Partners
The following metrics are utilised to
evaluate the performance:
• Total contributions through the PTSB
Community Fund, including the Bank’s
matched funding;
• Number of hours contributed through
employee volunteering;
• In-kind giving figures associated with
Employee Volunteering Programme
hours;
• Sponsorship Awareness figures;
• Sponsorship Consideration figures;
• Sponsorship Goodwill figures;
• PR and Earned Media Value; and,
• Social Media Performance where a paid
for social media campaign is part of the
Activation Strategy.
Methodologies used have been
introduced in line with industry best
practice and have been developed
internally by the Bank through
engagement with internal stakeholders.
No significant assumptions exist behind
the metrics.
Community metrics are not validated by
an external body other than the assurance
provider. These metrics are set and
monitored internally by the Bank.
Sponsorship metrics are validated by the
Bank’s Third Party brand measurement
and media buying agencies, who monitor
performance of KPIs and produce regular
performance reports in order to keep
the Bank updated on progress against
objectives.
G1-MDR3-T Tracking
effectiveness of policies and
actions through targets
PTSB is committed to managing the
material impact associated with our
community and sponsorship activity in
a proactive and measurable way. The
following targets have been established in
this regard:
• €200,000 in financial giving through the
PTSB Community Fund per year, which
includes matched funding by the Bank;
• 1,000 volunteer hours on the ground
in local communities through the
Employee Volunteering Programme per
year; and,
The Bank observed no compliance
breaches in relation to sponsorship or
community initiatives during 2024. All
activity took place in the Republic of
Ireland, except for the activation of our
Title Sponsorship of Team Ireland which
took place in Ireland and in Paris, France.
The targets are set annually and as such,
the baseline year is January-December
2024. The starting value is 0. There are
no interim targets. There are no defined
methodologies in place or significant
assumptions used when defining the
Bank’s targets. External stakeholders have
not been involved in the target setting. All
targets have been set internally within the
Bank by the respective teams responsible
for delivering on activity.
Progress against targets is monitored on
a quarterly basis and reported upwards to
the Bank’s Sustainability Committee, ExCo
and Board, as appropriate.
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
232
Sustainability Statement
Appendix A - List of datapoints in cross-cutting and topical standards that derive from other EU
Legislation
Disclosure Requirement and related
datapoint
Pillar 3 reference
Benchmark Regulation
reference
EU
Climate Law reference
Page Number
ESRS 2 GOV-1
Board’s gender diversity
paragraph 21 (d)
Commission
Delegated Regulation
(EU) 2020/1816 ( 27 ) ,
Annex II
144
ESRS 2 GOV-1
Percentage of board members
who are independent
paragraph 21 (e)
Delegated Regulation
(EU) 2020/1816,
Annex II
144
ESRS 2 SBM-1
Involvement in activities
related to fossil fuel activities
paragraph 40 (d) i
Pillar 3 Template 3
(Not disclosed Mid-
Year)
Delegated Regulation
(EU) 2020/1816,
Annex II
150
ESRS 2 SBM-1
Involvement in activities
related to chemical production
paragraph 40 (d) ii
Delegated Regulation
(EU) 2020/1816,
Annex II
150
ESRS 2 SBM-1
Involvement in activities
related to controversial
weapons paragraph 40 (d) iii
Delegated Regulation
(EU) 2020/1818 ( 29 ) ,
Article 12(1)
Delegated Regulation
(EU) 2020/1816,
Annex II
150
ESRS 2 SBM-1
Involvement in activities
related to cultivation and
production of tobacco
paragraph 40 (d) iv
Delegated Regulation
(EU) 2020/1818,
Article 12(1)
Delegated Regulation
(EU) 2020/1816,
Annex II
150
ESRS E1-1
Transition plan to reach climate
neutrality by 2050 paragraph
14
Regulation
(EU) 2021/1119,
Article 2(1)
174
ESRS E1-1
Undertakings excluded from
Paris-aligned Benchmarks
paragraph 16 (g)
Pillar 3 Template 1
Delegated Regulation
(EU) 2020/1818,
Article12.1 (d) to (g),
and Article 12.2
174
ESRS E1-4
GHG emission reduction
targets paragraph 34
Pillar 3 Template 3
(target validation in
progress)
Delegated Regulation
(EU) 2020/1818,
Article 6
180
ESRS E1-5
Energy consumption from
fossil sources disaggregated
by sources (only high climate
impact sectors) paragraph 38
184
ESRS E1-5 Energy
consumption and mix
paragraph 37
183
PTSB Group Holdings plc - Annual Report 2024
233
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Disclosure Requirement and related
datapoint
Pillar 3 reference
Benchmark Regulation
reference
EU
Climate Law reference
Page Number
ESRS E1-5
Energy intensity associated
with activities in high climate
impact sectors paragraphs 40
to 43
184
ESRS E1-6
Gross Scope 1, 2, 3 and Total
GHG emissions paragraph 44
Pillar 3 Template 1
Delegated Regulation
(EU) 2020/1818,
Article 5(1), 6 and 8(1)
181
ESRS E1-6
Gross GHG emissions intensity
paragraphs 53 to 55
Pillar 3 Template 1
Delegated Regulation
(EU) 2020/1818,
Article 8(1)
186
ESRS E1-7
GHG removals and carbon
credits paragraph 56
Regulation
(EU) 2021/1119,
Article 2(1)
186
ESRS E1-9
Exposure of the benchmark
portfolio to climate-related
physical risks paragraph 66
Delegated Regulation
(EU) 2020/1818,
Annex II Delegated
Regulation
(EU) 2020/1816,
Annex II
-
ESRS E1-9
Disaggregation of monetary
amounts by acute and chronic
physical risk paragraph 66 (a)
ESRS E1-9
Location of significant assets
at material physical risk
paragraph 66 (c).
Pillar 3 Template 5
-
ESRS E1-9 Breakdown of the
carrying value of its real estate
assets by energy-efficiency
classes paragraph 67 (c).
Pillar 3 Template 2
-
ESRS E1-9
Degree of exposure of the
portfolio to climate- related
opportunities paragraph 69
Delegated Regulation
(EU) 2020/1818,
Annex II
-
ESRS E2-4
Amount of each pollutant
listed in Annex II of the E-PRTR
Regulation (European Pollutant
Release and Transfer Register)
emitted to air, water and soil,
paragraph 28
Not material
ESRS E3-1
Water and marine resources
paragraph 9
Not material
ESRS E3-1
Dedicated policy paragraph 13
Not material
ESRS E3-1
Sustainable oceans and seas
paragraph 14
Not material
ESRS G1 – Business conduct (continued)
PTSB Group Holdings plc - Annual Report 2024
234
Sustainability Statement
Disclosure Requirement and related
datapoint
Pillar 3 reference
Benchmark Regulation
reference
EU
Climate Law reference
Page Number
ESRS E3-4
Total water recycled and
reused paragraph 28 (c)
Not material
ESRS E3-4
Total water consumption in
m 3 per net revenue on own
operations paragraph 29
Not material
ESRS 2- SBM 3 - E4 paragraph
16 (a) i
Not material
ESRS 2- SBM 3 - E4 paragraph
16 (b)
Not material
ESRS 2- SBM 3 - E4 paragraph
16 (c)
Not material
ESRS E4-2
Sustainable land / agriculture
practices or policies paragraph
24 (b)
Not material
ESRS E4-2
Sustainable oceans / seas
practices or policies paragraph
24 (c)
Not material
ESRS E4-2
Policies to address
deforestation paragraph 24 (d)
Not material
ESRS E5-5
Non-recycled waste paragraph
37 (d)
Not material
ESRS E5-5
Hazardous waste and
radioactive waste paragraph
39
Not material
ESRS 2- SBM3 - S1
Risk of incidents of forced
labour paragraph 14 (f)
199
ESRS 2- SBM3 - S1
Risk of incidents of child labour
paragraph 14 (g)
199
ESRS S1-1
Human rights policy
commitments paragraph 20
199
ESRS S1-1
Due diligence policies on
issues addressed by the
fundamental International
Labor Organisation
Conventions 1 to 8, paragraph
21
Delegated Regulation
(EU) 2020/1816,
Annex II
199
ESRS S1-1
processes and measures for
preventing trafficking in human
beings paragraph 22
199
PTSB Group Holdings plc - Annual Report 2024
235
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Disclosure Requirement and related
datapoint
Pillar 3 reference
Benchmark Regulation
reference
EU
Climate Law reference
Page Number
SRS S1-1
workplace accident prevention
policy or management system
paragraph 23
204
ESRS S1-3
grievance/complaints handling
mechanisms paragraph 32 (c)
201
ESRS S1-14
Number of fatalities and
number and rate of work-
related accidents paragraph 88
(b) and (c)
Delegated Regulation
(EU) 2020/1816,
Annex II
203
ESRS S1-14
Number of days lost to injuries,
accidents, fatalities or illness
paragraph 88 (e)
203
ESRS S1-16
Unadjusted gender pay gap
paragraph 97 (a)
Delegated Regulation
(EU) 2020/1816,
Annex II
204
ESRS S1-16
Excessive CEO pay ratio
paragraph 97 (b)
204
ESRS S1-17
Incidents of discrimination
paragraph 103 (a)
204
ESRS S1-17 Non-respect
of UNGPs on Business and
Human Rights and OECD
Guidelines paragraph 104 (a)
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation
(EU) 2020/1818 Art
12 (1)
204
ESRS 2- SBM3 – S2
Significant risk of child labour
or forced labour in the value
chain paragraph 11 (b)
Not material
ESRS S2-1
Human rights policy
commitments paragraph 17
Not material
ESRS S2-1 Policies related to
value chain workers paragraph
18
Not material
ESRS S2-1Non-respect of
UNGPs on Business and
Human Rights principles and
OECD guidelines paragraph 19
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation
(EU) 2020/1818, Art
12 (1)
Not material
PTSB Group Holdings plc - Annual Report 2024
236
Sustainability Statement
Disclosure Requirement and related
datapoint
Pillar 3 reference
Benchmark Regulation
reference
EU
Climate Law reference
Page Number
ESRS S2-1
Due diligence policies on
issues addressed by the
fundamental International
Labor Organisation
Conventions 1 to 8, paragraph
19
Delegated Regulation
(EU) 2020/1816,
Annex II
Not material
ESRS S2-4
Human rights issues and
incidents connected to its
upstream and downstream
value chain paragraph 36
Not material
ESRS S3-1
Human rights policy
commitments paragraph 16
Not material
ESRS S3-1
non-respect of UNGPs on
Business and Human Rights,
ILO principles or OECD
guidelines paragraph 17
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation
(EU) 2020/1818, Art
12 (1)
Not material
ESRS S3-4
Human rights issues and
incidents paragraph 36
Not material
ESRS S4-1 Policies related
to consumers and end-users
paragraph 16
159
ESRS S4-1
Non-respect of UNGPs
on Business and Human
Rights and OECD guidelines
paragraph 17
Delegated Regulation
(EU) 2020/1816,
Annex II Delegated
Regulation
(EU) 2020/1818, Art
12 (1)
210
ESRS S4-4
Human rights issues and
incidents paragraph 35
210
ESRS G1-1
United Nations Convention
against Corruption paragraph
10 (b)
227
ESRS G1-1
Protection of whistle-blowers
paragraph 10 (d)
221
ESRS G1-4
Fines for violation of anti-
corruption and anti-bribery
laws paragraph 24 (a)
Delegated Regulation
(EU) 2020/1816,
Annex II)
225
ESRS G1-4
Standards of anti- corruption
and anti- bribery paragraph
24 (b)
227
PTSB Group Holdings plc - Annual Report 2024
237
Strategic Report
Governance
Sustainability
Financial Statements
General Information
0. Summary of KPIs to be disclosed by credit institutions under Article 8 Taxonomy Regulation
This template requires credit institutions to disclose relevant KPIs on the basis of the scope of their prudential consolidation
determined in accordance with regulation (EU) No 575/2013, Title II, Chapter 2, Section 2.
In accordance with the Disclosure Delegated Act, PTSB is required to calculate the green asset ratio (GAR) for on-balance sheet
exposures covering the following accounting categories of financial assets, including loans and advances, debt securities, equity
holdings and repossessed collaterals:
(a) financial assets at amortised cost;
(b) financial assets at fair value through other comprehensive income;
(c) investments in subsidiaries;
(d) joint ventures and associates;
(e) financial assets designated at fair value through profit or loss and non-trading financial assets mandatorily at fair value through
profit or loss; and
(f) real estate collaterals obtained by credit institutions by taking possession in exchange for the cancellation of debts.
The following assets shall be excluded from the numerator of the GAR:
(a) financial assets held for trading;
(b) on-demand interbank loans; and
(c) exposures to undertakings that are not obliged to publish non-financial information pursuant to Article 19a or 29a of Directive
2013/34/EU.
PTSB is required to calculate the KPIs for off-balance sheet exposures considering financial guarantees granted by the credit
institution and assets under management for guarantee and investee non-financial undertakings. Other off-balance sheet exposures
such as commitments are be excluded from that calculation.
For details on the Bank’s approach to determining taxonomy alignment, and calculation of these summary KPIs, please see notes in
Template 1.
Annex VI - Template for the KPIs of credit institutions
Index:
Page
0. Summary of KPIs
238
1. Assets for the calculation of GAR
240
2. GAR sector information
256
3. GAR KPI stock
258
4. GAR KPI flow
266
5. KPI off-balance sheet exposures
274
PTSB Group Holdings plc - Annual Report 2024
238
2024
Total environmentally
sustainable assets
KPI**
KPI***
% coverage (over total
assets)*
% of assets excluded from
the numerator of the GAR
(Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded
from the denominator of
the GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Main KPI
Green asset ratio (GAR) stock
1854
7.98%
7.98%
6.32%
6.45%
20.82%
Total environmentally
sustainable activities
KPI
KPI
% coverage (over total
assets)
% of assets excluded from
the numerator of the GAR
(Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded
from the denominator of
the GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Additional KPIs
GAR (flow)
360
14.80%
14.80%
9.61%
7.48%
35.07%
Trading book
-
-
-
Financial guarantees
-
-
-
Assets under management
-
-
-
Fees and commissions income
-
-
-
* % of assets covered by the KPI over banks´ total assets
** based on the Turnover KPI of the counterparty
*** based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
2023
Total environmentally
sustainable assets
KPI**
KPI***
% coverage (over total
assets)*
% of assets excluded from
the numerator of the GAR
(Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded
from the denominator of
the GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Main KPI
Green asset ratio (GAR) stock
475
2.03%
2.03%
1.68%
6.51%
17.45%
Total environmentally
sustainable activities
KPI
KPI
% coverage (over total
assets)
% of assets excluded from
the numerator of the GAR
(Article 7(2) and (3) and
Section 1.1.2. of Annex V)
% of assets excluded
from the denominator of
the GAR (Article 7(1) and
Section 1.2.4 of Annex V)
Additional KPIs
GAR (flow)
110
2.82%
2.82%
2.32%
8.44%
17.49%
Trading book
-
-
-
Financial guarantees
-
-
-
Assets under management
-
-
-
Fees and commissions income
-
-
-
* % of assets covered by the KPI over banks´ total assets
** based on the Turnover KPI of the counterparty
*** based on the CapEx KPI of the counterparty, except for lending activities where for general lending Turnover KPI is used
PTSB Group Holdings plc - Annual Report 2024
239
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Annex VI - Template for the KPIs of credit institutions
(continued)
1. Assets for the calculation of GAR
Template 1 discloses the Bank’s assets used in the calculation of the Green Asset Ratio (GAR). Exposures are reported for 31st
December 2024. EU Taxonomy balances are presented gross of ECL and deferred fess, discounts and business combination related
fair value adjustments,
For this disclosure, given the residential mortgage book represents the bank's most significant portion of on-balance sheet exposures
in terms of value, we have prioritised analysis of alignment with the EU Taxonomy within households, secured against residential
immovable property.
The criteria to determine alignment for residential mortgage loans to households vary based on the year of construction, and
alignment is determined based on EPC rating criteria, and exposure to physical risk.
Taxonomy aligned properties built before 31st December 2020, must have an EPC rating in the top 15% of the national or regional
building stock. To identify the top 15% of most energy efficient buildings of the national or regional building stock, as per the EU
Taxonomy and associated technical screening criteria, we used analysing energy ratings data from the Central Statistics Office (CSO)
representing approximately 63.5% of Ireland's housing stock. Based on this weighted national dataset, the Bank estimated the top
2024 Turnover Based
Million EUR
Total [gross]
carrying amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances,
debt securities and equity
instruments not HfT eligible for
GAR calculation
21,319.99
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
293.64
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
291.19
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
181.74
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
109.45
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
2.45
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
0
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
0
-
-
-
-
-
-
-
-
-
-
24
Households
21,026.35
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
20,298.61
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
26
of which building renovation
loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
240
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15% threshold corresponded to a BER rating of B3 or higher. The Group has adopted this B3 threshold to identify the properties with a
valid EPC certificate within the residential mortgage portfolio that meet this technical screening criteria.
Taxonomy aligned properties built after 31st December 2020, must have an EPC rating and be at least 10 % lower than the threshold
set for the nearly zero-energy building (NZEB) requirements in national measures implementing Directive 2010/31/EU of the European
Parliament and of the Council. The Bank has developed a robust, transparent methodology to assess the extent of alignment between
post-2020 building assets and construction standards stipulated under the Climate Change Mitigation objective under EU Taxonomy.
In addition to energy efficient criteria, exposure to physical risk must also be considered. Only those properties assessed as not
vulnerable to physical risk are reported.
Data availability and quality constraints mean the assessment of alignment with EU Taxonomy has not been possible at this time
for all required exposure classes specified by Article 8 Disclosures Delegated Act within Template 1 of Annex VI of same. Initiatives
are underway to enhance the Group’s data collection capabilities going forward, with a view to enhancing the ability to determine
taxonomy alignment.
PTSB Group Holdings plc - Annual Report 2024
241
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Million EUR
Total [gross]
carrying amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
7.32
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
1,891.71
-
-
-
-
-
-
-
-
-
-
-
-
-
33
Financial and Non-financial
undertakings
796.29
34
SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
786.58
35
Loans and advances
786.58
36
of which loans collateralised by
commercial immovable property
-
37
of which building renovation
loans
-
38
Debt securities
-
39
Equity instruments
-
40
Non-EU country counterparties
not subject to NFRD disclosure
obligations
9.71
41
Loans and advances
0.28
42
Debt securities
43
Equity instruments
9.43
44
Derivatives
58.52
45
On demand interbank loans
132.91
46
Cash and cash-related assets
72.07
47
Other categories of assets (e.g.
Goodwill, commodities etc.)
831.93
48
Total GAR assets
23,219.02
19,996.73
1,853.58
1,853.58
-
-
49
Assets not covered for GAR
calculation
6,105.36
50
Central governments and
Supranational issuers
4,217.80
51
Central banks’ exposure
1,887.23
52
Trading book
0.33
53
Total assets
29,324.39
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures -
Undertakings subject to NFRD
disclosure obligations
54
Financial guarantees
1.53
-
-
-
-
-
-
-
-
-
-
-
-
-
55
Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
-
-
-
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
242
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
243
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2023 Turnover Based
Million EUR
Total [gross]
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances,
debt securities and equity
instruments not HfT eligible for
GAR calculation
21,537.72
19,322,.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
219.25
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
217.20
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
217.20
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
2.06
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
12
of which management
companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance
undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Households
21,307.44
19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
20,608.21
19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
26
of which building renovation
loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government
financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking
possession: residential and
commercial immovable
properties
11.03
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Assets excluded from the
numerator for GAR calculation
(covered in the denominator)
1844.44
-
-
-
-
-
-
-
-
-
-
-
-
-
33
Financial and Non-financial
undertakings
692.06
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
244
Disclosure reference date T-1
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
245
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Million EUR
Total [gross]
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
34
SMEs and NFCs (other than
SMEs) not subject to NFRD
disclosure obligations
687.02
35
Loans and advances
687.02
36
of which loans collateralised
by commercial immovable
property
-
37
of which building renovation
loans
-
38
Debt securities
-
39
Equity instruments
-
40
Non-EU country counterparties
not subject to NFRD disclosure
obligations
5.04
41
Loans and advances
-
42
Debt securities
-
43
Equity instruments
5.04
44
Derivatives
35.65
45
On demand interbank loans
146.12
46
Cash and cash-related assets
71.14
47
Other categories of assets (e.g.
Goodwill, commodities etc.)
899.48
48
Total GAR assets
23,382.17
19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
49
Assets not covered for GAR
calculation
4,943.54
50
Central governments and
Supranational issuers
3,256.30
51
Central banks’ exposure
1,687.24
52
Trading book
-
53
Total assets
28,325.71
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures -
Undertakings subject to NFRD
disclosure obligations
54
Financial guarantees
1.53
-
-
-
-
-
-
-
-
-
-
-
-
-
55
Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
246
Disclosure reference date T-1
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
247
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 CapEx Based
Million EUR
Total [gross]
carrying amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of
which
enabling
Of which
Use of
Proceeds
Of
which
enabling
Of which
Use of
Proceeds
Of
which
enabling
GAR - Covered assets in both numerator
and denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
21,319.99
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
293.64
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
291.19
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
181.74
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
109.45
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
2.45
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12 of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15 Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16 of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19 Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
21 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22 Debt securities, including UoP
0
-
-
-
-
-
-
-
-
-
-
-
-
-
23 Equity instruments
0
-
-
-
-
-
-
-
-
-
-
24 Households
21,026.35
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
20,298.61
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
26 of which building renovation loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27 of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29 Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30 Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
7.32
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Assets excluded from the numerator
for GAR calculation (covered in the
denominator)
1,891.71
-
-
-
-
-
-
-
-
-
-
-
-
-
33 Financial and Non-financial undertakings
796.29
34
SMEs and NFCs (other than SMEs) not
subject to NFRD disclosure obligations
786.58
35 Loans and advances
786.58
36
of which loans collateralised by commercial
immovable property
-
37 of which building renovation loans
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
248
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of
which
enabling
Of which
Use of
Proceeds
Of
which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
- 19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
- 19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
- 19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
249
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Million EUR
Total [gross]
carrying amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant
sectors (Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which Use
of Proceeds
Of which
transitional
Of
which
enabling
Of which
Use of
Proceeds
Of
which
enabling
Of which
Use of
Proceeds
Of
which
enabling
38 Debt securities
-
39 Equity instruments
-
40 Non-EU country counterparties not subject
to NFRD disclosure obligations
9.71
41 Loans and advances
0.28
42 Debt securities
43 Equity instruments
9.43
44 Derivatives
58.52
45 On demand interbank loans
132.91
46 Cash and cash-related assets
72.07
47
Other categories of assets (e.g. Goodwill,
commodities etc.)
831.93
48 Total GAR assets
23,219.02
19,996.73
1,853.58
1,853.58
-
-
49 Assets not covered for GAR calculation
6,105.36
50
Central governments and Supranational
issuers
4,217.80
51 Central banks’ exposure
1,887.23
52 Trading book
0.33
53 Total assets
29,324.39
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings
subject to NFRD disclosure obligations
54 Financial guarantees
1.53
-
-
-
-
-
-
-
-
-
-
-
-
-
55 Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56 Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57 Of which equity instruments
-
-
-
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
250
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-
eligible)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of
which
enabling
Of which
Use of
Proceeds
Of
which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
19,996.73
1,853.58
1,853.58
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
251
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2023 CapEx Based
Million EUR
Total [gross]
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
1
Loans and advances, debt securities
and equity instruments not HfT
eligible for GAR calculation
21,537.72
19,322,.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
219.25
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
217.20
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
217.20
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
2.06
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
-
-
-
24
Households
21,307.44
19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
20,608.21
19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
-
-
-
-
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
11.03
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Assets excluded from the numerator
for GAR calculation (covered in the
denominator)
1844.44
-
-
-
-
-
-
-
-
-
-
-
-
-
33
Financial and Non-financial
undertakings
692.06
34
SMEs and NFCs (other than SMEs)
not subject to NFRD disclosure
obligations
687.02
35
Loans and advances
687.02
36
of which loans collateralised by
commercial immovable property
-
37
of which building renovation loans
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
252
Disclosure reference date T-1
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
253
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Million EUR
Total [gross]
carrying
amount
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which environmentally
sustainable (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
38
Debt securities
-
39
Equity instruments
-
40
Non-EU country counterparties
not subject to NFRD disclosure
obligations
5.04
41
Loans and advances
-
42
Debt securities
-
43
Equity instruments
5.04
44
Derivatives
35.65
45
On demand interbank loans
146.12
46
Cash and cash-related assets
71.14
47
Other categories of assets (e.g.
Goodwill, commodities etc.)
899.48
48
Total GAR assets
23,382.17
19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
49
Assets not covered for GAR
calculation
4,943.54
50
Central governments and
Supranational issuers
3,256.30
51
Central banks’ exposure
1,687.24
52
Trading book
-
53
Total assets
28,325.71
-
-
-
-
-
-
-
-
-
-
-
-
-
Off-balance sheet exposures - Undertakings
subject to NFRD disclosure obligations
54
Financial guarantees
1.53
-
-
-
-
-
-
-
-
-
-
-
-
-
55
Assets under management
-
-
-
-
-
-
-
-
-
-
-
-
-
-
56
Of which debt securities
-
-
-
-
-
-
-
-
-
-
-
-
-
-
57
Of which equity instruments
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
254
Disclosure reference date T-1
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors
(Taxonomy-eligible)
Of which towards taxonomy relevant sectors (Taxonomy-eligible)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable
(Taxonomy-aligned)
Of which environmentally sustainable (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
- 19,322.96
474.75
474.75
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
255
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2. GAR sector information
The purpose of this template is to provide information on exposures in the banking book toward those sectors (NFCs subject to
NFRD) covered by the Taxonomy (NACE sector 4 levels of detail), using the relevant NACE Codes on the basis of the principal activity
of the counterparty.
For the 31st December 2024 disclosure, bank reviewed the book for exposure to NFC’s subject to NFRD. Nil return for both Turnover
and CapEx in this instance.
This assessment resulted in a nil return.
Breakdown by sector - NACE 4 digits level (code
and label)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Mn EUR
Of which
environmentally
sustainable
(CCM)
Mn EUR
Of which
environmentally
sustainable
(CCM)
Mn EUR
Of which
environmentally
sustainable
(CCA)
Mn EUR
Of which
environmentally
sustainable
(CCA)
Mn EUR
Of which
environmentally
sustainable
(WTR)
Mn EUR
Of which
environmentally
sustainable
(WTR)
1
-
-
-
-
-
-
2
-
-
-
-
-
-
3
-
-
-
-
-
-
4
-
-
-
-
-
-
…
-
-
-
-
-
-
Nil return for 2023.
Breakdown by sector - NACE 4 digits level (code
and label)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Mn EUR
Of which
environmentally
sustainable
(CCM)
Mn EUR
Of which
environmentally
sustainable
(CCM)
Mn EUR
Of which
environmentally
sustainable
(CCA)
Mn EUR
Of which
environmentally
sustainable
(CCA)
Mn EUR
Of which
environmentally
sustainable
(WTR)
Mn EUR
Of which
environmentally
sustainable
(WTR)
1
-
-
-
-
-
-
2
-
-
-
-
-
-
3
-
-
-
-
-
-
4
-
-
-
-
-
-
…
-
-
-
-
-
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
256
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Mn EUR
Of which
environmentally
sustainable (CE)
Mn EUR
Of which
environmentally
sustainable (CE)
Mn EUR
Of which
environmentally
sustainable
(PPC)
Mn EUR
Of which
environmentally
sustainable
(PPC)
Mn EUR
Of which
environmentally
sustainable
(BIO)
Mn EUR
Of which
environmentally
sustainable
(BIO)
Mn EUR
Of which
environmentally
sustainable
(CCM + CCA +
WTR + CE + PPC
+ BIO)
Mn EUR
Of which
environmentally
sustainable
(CCM + CCA +
WTR + CE + PPC
+ BIO)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
Non-Financial corporates
(Subject to NFRD)
SMEs and other NFC not
subject to NFRD
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
[Gross] carrying amount
Mn EUR
Of which
environmentally
sustainable (CE)
Mn EUR
Of which
environmentally
sustainable (CE)
Mn EUR
Of which
environmentally
sustainable
(PPC)
Mn EUR
Of which
environmentally
sustainable
(PPC)
Mn EUR
Of which
environmentally
sustainable
(BIO)
Mn EUR
Of which
environmentally
sustainable
(BIO)
Mn EUR
Of which
environmentally
sustainable
(CCM + CCA +
WTR + CE + PPC
+ BIO)
Mn EUR
Of which
environmentally
sustainable
(CCM + CCA +
WTR + CE + PPC
+ BIO)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
257
Strategic Report
Governance
Sustainability
Financial Statements
General Information
3. GAR KPI stock
The purpose of this template is to disclose GAR KPIs on stock of loans calculated based on data disclosed in template 1, by applying
the formulas proposed in this template.
For the 31st December 2024 disclosure, bank reviewed the book and expressed as a percentage the proportion of the stock of
assets funding activities referred to in Regulation (EU) 2020/852 (i.e. eligible assets) in total stock of covered assets.
This assessment resulted in 7.98%.
The bank’s green assets relate to residential mortgage lending which predominately involves financing existing home purchases.
2024 Turnover Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
93.79%
8.69%
8.69%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24
Households
95.10%
8.82%
8.82%
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
98.51%
9.13%
9.13%
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
86.12%
7.98%
7.98%
-
-
-
-
-
-
-
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
258
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
93.79%
8.69%
8.69%
-
-
72.70%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
95.10%
8.82%
8.82%
-
-
71.70%
-
-
-
-
98.51%
9.13%
9.13%
-
-
69.22%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
86.12%
7.98%
7.98%
-
-
79.18%
PTSB Group Holdings plc - Annual Report 2024
259
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2023 Turnover Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
89.72%
2.20%
2.20%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including Up
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24
Households
90.69%
2.23%
2.23%
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
93.76%
2.30%
2.30%
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
82.64%
2.03%
2.03%
-
-
-
-
-
-
-
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
260
Disclosure reference date T-1
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
89.72%
2.20%
2.20%
-
-
76.04%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
90.69%
2.23%
2.23%
-
-
75.22%
-
-
-
-
93.76%
2.30%
2.30%
-
-
72.75%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
82.64%
2.03%
2.03%
-
-
82.55%
PTSB Group Holdings plc - Annual Report 2024
261
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 CapEx Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
93.79%
8.69%
8.69%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24
Households
95.10%
8.82%
8.82%
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
98.51%
9.13%
9.13%
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
86.12%
7.98%
7.98%
-
-
-
-
-
-
-
-
-
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
262
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
93.79%
8.69%
8.69%
-
-
72.70%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
95.10%
8.82%
8.82%
-
-
71.70%
-
-
-
-
98.51%
9.13%
9.13%
-
-
69.22%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
86.12%
7.98%
7.98%
-
-
79.18%
PTSB Group Holdings plc - Annual Report 2024
263
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2023 CapEx Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
specialised
lending
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
89.72%
2.20%
2.20%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including Up
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24
Households
90.69%
2.23%
2.23%
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
93.76%
2.30%
2.30%
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
82.64%
2.03%
2.03%
-
-
-
-
-
-
-
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
264
Disclosure reference date T-1
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
assets
covered
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
89.72%
2.20%
2.20%
-
-
76.04%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
90.69%
2.23%
2.23%
-
-
75.22%
-
-
-
-
93.76%
2.30%
2.30%
-
-
72.75%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
82.64%
2.03%
2.03%
-
-
82.55%
PTSB Group Holdings plc - Annual Report 2024
265
Strategic Report
Governance
Sustainability
Financial Statements
General Information
4. GAR KPI flow
The purpose of this template is to disclose GAR KPIs on flow of loans calculated (new loans on a net basis) based on data disclosed
in template 1, by applying the formulas proposed in this template.
For the 31st December 2024 disclosure, bank reviewed the book and expressed as a percentage the proportion of new assets (i.e.
assets originated and acquired within the current disclosure period) funding taxonomy-relevant activities (i.e. eligible assets) for
the objective of climate change mitigation in total new eligible assets (i.e. eligible assets originated and acquired within the current
disclosure period).
This assessment resulted in 14.80%.
The bank’s green assets relate to residential mortgage lending which predominately involves financing existing home purchases
rather than new capital expenditures.
2024 Turnover Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and equity
instruments not HfT eligible for GAR calculation
79.58%
14.80%
14.80%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24
Households
89.98%
16.73%
16.73%
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
100%
18.59%
18.59%
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
79.58%
14.80%
14.80%
-
-
-
-
-
-
-
-
-
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
266
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
new assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
79.58%
14.80%
14.80%
-
-
57.45%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
89.98%
16.73%
16.73%
-
-
57.43%
-
-
-
-
100%-
18.59%
18.59%
-
- 51.67%-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
79.58%
14.80%
14.80%
-
-
64.93%
PTSB Group Holdings plc - Annual Report 2024
267
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2023 Turnover Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant
sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator and
denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for GAR
calculation
76.14%
3.14%
3.14%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12 of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15 Equity instruments
-
-
-
-
-
-
-
-
-
-
16 of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19 Equity instruments
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23 Equity instruments
-
-
-
-
-
-
-
-
-
-
24 Households
76.15%
3.14%
3.14%
-
-
-
-
-
-
25
of which loans collateralised by residential
immovable property
-
-
-
-
-
-
-
-
-
26 of which building renovation loans
-
-
-
-
-
-
-
-
-
27 of which motor vehicle loans
-
-
-
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29 Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30 Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Total GAR assets
68.35%
2.82%
2.82%
-
-
-
-
-
-
-
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
268
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
new assets
covered
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-
aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
76.14%
3.14%
3.14%
-
-
76.14%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
76.15%
3.14%
3.14%
-
-
76.15%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
68.35%
2.82%
2.82%
-
-
68.35%
PTSB Group Holdings plc - Annual Report 2024
269
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2024 CapEx Based
% (compared to total covered assets in the denominator)
Total (Million EUR)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both
numerator and denominator
-
1
Loans and advances, debt securities
and equity instruments not HfT
eligible for GAR calculation
79.58%
14.80%
14.80%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
10
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12
of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
-
13
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15
Equity instruments
-
-
-
-
-
-
-
-
-
-
16
of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
17
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
-
18
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19
Equity instruments
-
-
-
-
-
-
-
-
-
-
20
Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
-
21
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23
Equity instruments
-
-
-
-
-
-
-
-
-
-
24
Households
89.98%
16.73%
16.73%
-
-
-
-
-
-
25
of which loans collateralised by
residential immovable property
100.00%
18.59%
18.59%
-
-
-
-
-
-
26
of which building renovation loans
-
-
-
-
-
-
-
-
-
27
of which motor vehicle loans
-
-
-
-
-
28
Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29
Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30
Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking
possession: residential and
commercial immovable properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32
Total GAR assets
79.58%
14.80%
14.80%
-
-
-
-
-
-
-
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
270
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
new assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
79.58%
14.80%
14.80%
-
-
57.45%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
89.98%
16.73%
16.73%
-
-
57.43%
-
-
-
-
100.00%
18.59%
18.59%
-
- 51.67%-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
79.58%
14.80%
14.80%
-
-
64.93%
PTSB Group Holdings plc - Annual Report 2024
271
Strategic Report
Governance
Sustainability
Financial Statements
General Information
2023 CapEx Based
% (compared to total covered assets in the denominator)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
GAR - Covered assets in both numerator
and denominator
1
Loans and advances, debt securities and
equity instruments not HfT eligible for
GAR calculation
76.14%
3.14%
3.14%
-
-
-
-
-
-
-
-
-
-
2
Financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
3
Credit institutions
-
-
-
-
-
-
-
-
-
-
-
-
-
4
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
5
Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
6
Equity instruments
-
-
-
-
-
-
-
-
-
-
7
Other financial corporations
-
-
-
-
-
-
-
-
-
-
-
-
-
8
of which investment firms
-
-
-
-
-
-
-
-
-
-
-
-
-
9
Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
10 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
11
Equity instruments
-
-
-
-
-
-
-
-
-
-
12 of which management companies
-
-
-
-
-
-
-
-
-
-
-
-
-
13 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
14 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
15 Equity instruments
-
-
-
-
-
-
-
-
-
-
16 of which insurance undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
17 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
18 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
19 Equity instruments
-
-
-
-
-
-
-
-
-
-
20 Non-financial undertakings
-
-
-
-
-
-
-
-
-
-
-
-
-
21 Loans and advances
-
-
-
-
-
-
-
-
-
-
-
-
-
22 Debt securities, including UoP
-
-
-
-
-
-
-
-
-
-
-
-
-
23 Equity instruments
-
-
-
-
-
-
-
-
-
-
24 Households
76.15%
3.14%
3.14%
-
-
-
-
-
-
25 of which loans collateralised by residential
immovable property
-
-
-
-
-
-
-
-
-
26 of which building renovation loans
-
-
-
-
-
-
-
-
-
27 of which motor vehicle loans
-
-
-
-
-
28 Local governments financing
-
-
-
-
-
-
-
-
-
-
-
-
-
29 Housing financing
-
-
-
-
-
-
-
-
-
-
-
-
-
30 Other local government financing
-
-
-
-
-
-
-
-
-
-
-
-
-
31
Collateral obtained by taking possession:
residential and commercial immovable
properties
-
-
-
-
-
-
-
-
-
-
-
-
-
32 Total GAR assets
68.35%
2.82%
2.82%
-
-
-
-
-
-
-
-
-
-
Note: % coverage (over total assets) has been restated to align to 2024 approach
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
272
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding
taxonomy relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion
of total
new assets
covered
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
76.14%
3.14%
3.14%
-
-
76.14%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
76.15%
3.14%
3.14%
-
-
76.15%
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
68.35%
2.82%
2.82%
-
-
68.35%
PTSB Group Holdings plc - Annual Report 2024
273
Strategic Report
Governance
Sustainability
Financial Statements
General Information
5. KPI off-balance sheet exposures
The purpose of this template is to disclose information for off-balance sheet exposures calculated based on the data disclosed in
template 1, on covered assets, and by applying the formulas proposed in this template.
For the 31st December 2024 disclosure, owing to bank’s prioritised analysis of alignment with the EU Taxonomy within households,
secured against residential immovable property this template hasn’t been populated. Nil return for Turnover and Capex for 2024 and
2023.
% (compared to total eligible off-balance sheet assets)
Climate Change Mitigation (CCM)
Climate Change Adaptation (CCA)
Water and marine resources (WTR)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
1
Financial guarantees (FinGuar KPI)
-
-
-
-
-
-
-
-
-
-
-
-
-
2
Assets under management (AuM KPI)
-
-
-
-
-
-
-
-
-
-
-
-
-
Annex VI - Template for the KPIs of credit institutions
(continued)
PTSB Group Holdings plc - Annual Report 2024
274
Disclosure reference date T
Circular economy (CE)
Pollution (PPC)
Biodiversity and Ecosystems (BIO)
TOTAL (CCM + CCA + WTR + CE + PPC + BIO)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-eligible)
Proportion of total covered assets funding taxonomy relevant sectors
(Taxonomy-eligible)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets
funding taxonomy relevant sectors
(Taxonomy-aligned)
Proportion of total covered assets funding taxonomy
relevant sectors (Taxonomy-aligned)
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
enabling
Of which
Use of
Proceeds
Of which
transitional
Of which
enabling
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
PTSB Group Holdings plc - Annual Report 2024
275
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Task Force on Climate-related Financial Disclosures
Governance
The Bank’s risk governance structure
establishes the authority, responsibility,
and accountability for risk management
across the Group and enables effective
identification, measurement, monitoring,
management and oversight with respect
to risks by appropriate Board and
management-level governing bodies.
TCFD Recommendation:
PTSB’s governance around
climate-related and
environmental risks and
opportunities
A. Board and Management oversight
of climate-related risks and
opportunities.
Board and Management Oversight
The PTSB Board of Directors (Board) is
accountable for the success of the Bank
over the long-term and is collectively
responsible for the governance of the
Bank. The Board is responsible for
overseeing and approving the Bank’s
strategic plan and monitoring its
implementation and effectiveness within
its Risk Appetite. In addition, the Board is
accountable for formulating, approving
and supervising the implementation
of the Bank’s Sustainability Strategy,
including the Environmental, Social and
Governance (ESG) Risk Strategy (including
Climate-related and Environmental (CR&E)
matters), to realise its long-term financial
interests and maintain its solvency.
PTSB’s Risk Governance Structure
Various Committees with delegated
responsibilities assist the Board and
Executive Committee in managing and
monitoring the risks and opportunities
that climate change and the transition to
a sustainable economy present. Within
the Bank, CR&E risk is coordinated at an
enterprise-level, with the functions and
business segments sharing responsibility
for addressing CR&E risks and
opportunities.
Throughout 2024, the Board met at
regular intervals to receive updates in
relation to sustainability and CR&E risk
integration. Meetings took place at least
once per quarter, and more often as
required. Key topics included:
• Refreshing the approach to
Sustainability Programme governance;
• Appointing a Chief Sustainability and
Corporate Affairs Officer, a Head of
Sustainability and supporting team;
• Horizon scanning of the CR&E risk
regulatory landscape;
• Closing of the Bank’s 2022 CR&E Risk
Implementation Plan;
• Ongoing integration of CR&E risk
into the Bank’s wider Sustainability
Programme, through an ESG Risk
Management Workstream;
• Identifying market opportunities for
further development of the Bank’s
Product and Propositions, including
Green Products and Propositions;
• Delivering PTSB’s regulatory and
voluntary CR&E risk disclosures,
including the EU Taxonomy, Pillar 3 ESG
Templates, the Corporate Sustainability
Reporting Directive (CSRD) and the
TCFD;
• Developing the Bank’s planned science-
based targets (SBTs) in line with the
Science Based Target Initiative’s (SBTi)
V2 Guidance and a corresponding
Carbon Reduction Plan; and,
• Receiving training on the CSRD, SBTs
and carbon reduction activity.
Board Level Committees
Management Level Committees
Board of Directors
Board Nominations, Culture
and Ethics Committee
(NOMCO)
Board Risk and Compliance
Committee
(BRCC)
Board Audit
Committee
(BAC)
Board Remuneration
Committee
(REMCO)
Group Executive
Committee (ExCo)
Assets and Liability
Committee (ALCo)
Group Risk
Committee (GRC)
Sustainability
Committee (SusCo)
Customer
Committee (CustCo)
Operational Risk Management
Committee (ORMC)
Group Credit
Committee (GCC)
PTSB Group Holdings plc - Annual Report 2024
276
Board Audit Committee (BAC)
The BAC is responsible for overseeing the
process of disclosure and communication
with external stakeholders and competent
authorities, which includes climate-related
disclosures.
Board Risk and Compliance Committee
(BRCC)
The BRCC has delegated responsibility
from the Board to assess the impact
of CR&E risk on the Bank’s overall Risk
Profile. The BRCC has approved and
provides oversight on the execution of an
enterprise wide CR&E Risk Implementation
Plan.
Nomination, Culture and Ethics
Committee (NomCo)
The NomCo is the overarching Board
advisory committee responsible for the
review, design, implementation, and
effectiveness of the Bank’s Sustainability
Strategy. A key pillar within the Bank’s
Sustainability Strategy is ‘Addressing
Climate Change and Supporting the
Transition to a Low Carbon Economy’,
which includes a focus on CR&E risk.
B. Board and Management’s role in
assessing and managing climate-
related and environmental risks and
opportunities.
Executive Management Oversight
The Executive Committee (ExCo) is the
Senior Management Committee of PTSB
with authority to operate and make
decisions within limits set by the Board.
The ExCo is the custodian of the Bank’s
collective Strategic Portfolio, Medium
Term Plan (MTP) and Risk Management,
as developed through the annual
Strategic Planning Process (SPP). The
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 bank-wide colleagues and other
functional issues and ensuring that a
robust and resilient operating framework
exists within which the Bank’s activities
are undertaken. The ExCo is the ultimate
management committee responsible for
the development and implementation of
the Bank’s Sustainability Strategy and the
management of CR&E risk.
PTSB continues to make good progress
integrating consideration for CR&E risk
into the Bank’s management structure
and business model. The ExCo meets
frequently to discuss Business Strategy,
planning, change management, financial
planning, risk management, operations
and performance. These discussions
also include CR&E risk matters, when
applicable.
Throughout 2024, the ExCo met at regular
intervals to receive updates in relation to
sustainability and CR&E risk integration.
Meetings took place at least once per
quarter, and more often as required. Key
topics included:
• Refreshing the approach to
Sustainability Programme governance;
• Development of a Sustainability
Programme Target Operating Model;
• Approach to Sustainability Learning and
Development for colleagues, including
CR&E risk;
• Horizon scanning of the CR&E risk
regulatory landscape;
• Closing of the Bank’s 2022 CR&E Risk
Implementation Plan;
• Ongoing integration of CR&E risk
into the Bank’s wider Sustainability
Programme, through an ESG Risk
Management Workstream;
• Identifying market opportunities for
further development of the Bank’s
Product and Propositions, including
Green Products and Propositions;
• Evolving the Bank’s approach to ESG
Data integration;
• Delivering PTSB’s regulatory and
voluntary CR&E risk disclosures,
including the EU Taxonomy, Pillar 3 ESG
Templates, the Corporate Sustainability
Reporting Directive (CSRD) and the
TCFD;
• Developing the Bank’s planned science-
based targets (SBTs) in line with the
Science Based Target Initiative’s (SBTi)
V2 Guidance and a corresponding
Carbon Reduction Plan;
Board
CEO
GRC
ExCo
BAC
BRCC
NomCo
ALCo
CustCo
SusCo
GCC
Sustainability Programme
Steering Group
The PTSB Group Governance Structure
The Board Committees with CR&E risk oversight responsibility can be found below.
PTSB Group Holdings plc - Annual Report 2024
277
Strategic Report
Governance
Sustainability
Financial Statements
General Information
• Evolving the Bank’s approach to ESG
Data integration; and,
• Receiving training on the CSRD, SBTs
and carbon reduction activity.
The management level roles and
responsibilities are outlined below, as is
the detail on the management committees
with sustainability and CR&E risk
responsibility.
The Chief Executive Officer (CEO)
is responsible for overseeing PTSB’s
Sustainability Strategy and climate action
agenda. The CEO sits on the Board,
is Chair of the ExCo and attends the
NomCo as requested - the overarching
Board advisory committee responsible
for Sustainability. The CEO is responsible
for assessing and managing CR&E risks
and opportunities and is a member of the
Sustainability Committee (SusCo).
The Chief Financial Officer (CFO) is
responsible for the Bank’s financial
planning including capital management
and all external reporting and disclosures
for PTSB. The CFO is responsible for
oversight and reporting of climate-related
disclosures. The CFO reports directly to
the CEO and sits on the Board of PTSB.
The CFO is also an attendee of the BAC,
the Committee who oversee material
climate-related disclosures. The CFO is
also a member of the SusCo.
The Chief Risk Officer (CRO) is
responsible for assessing the impact of
CR&E risk on the Bank’s overall Risk Profile
and supports the CEO in overseeing
PTSB’s Sustainability Strategy and
climate action agenda. The CRO attends
the Board to present their monthly CRO
Report, which includes an update on
CR&E risk, is a member of the ExCo and
attends the BRCC, which has delegated
responsibility from the Board to assess
the impact of CR&E risk on the Bank’s
overall Risk Profile. The CRO is also a
member of the SusCo.
Under the Individual Accountability
Framework (IAF), the CRO has been
assigned Prescribed Responsibility 24
(PR 24), ‘the responsibility for managing
financial risks from climate change’.
Progress has been made to identify
and address the capability and delivery
requirements for CR&E risk across the
Bank through implementation of the
following:
• Establishing a Responsible,
Accountable, Consulted and Informed
(RACI) Matrix which defines the
accountable owners, roles and
responsibilities required to deliver on
PR 24 with prescribed responsibility
allocated to the CRO;
• Mobilising a dedicated team within the
Risk function for CR&E risk management
and integration;
• Building internal capability through
training, including to the members of
the Senior Leadership Team, the ExCo
and Board in relation to CR&E risk; and,
• Partnering with a third-party
professional services firm to provide
strategic guidance and advisory
support.
The Chief Sustainability and Corporate
Affairs Officer (CSCAO) is responsible
for leading the development and
implementation of the Bank’s Sustainability
Strategy in line with regulation and
supervisory expectation, while ensuring
all activity is aligned with the Bank’s
overarching Business Strategy and
Purpose. The CSCAO sits on the ExCo of
the Bank and reports directly to the CEO.
The CSCAO chairs the Bank’s SusCo.
The Chief Customer and People Officer
(CCPO) is responsible for developing and
implementing key elements outlined in the
Bank’s Sustainability Strategy, for example
the delivery of sustainable finance
products and propositions that support
our customers in transition. The CCPO is
a regular attendee of the NomCo and is a
member of the Bank’s ExCo.
Management Committees with CR&E
Risk Oversight Responsibility
PTSB has Executive Level Committees
that oversee and deliver the Bank’s ESG
Risk Management Strategy (including
CR&E risk) and associated external
commitments under the Sustainability
Programme. These Committees
take an enterprise-wide approach to
overseeing our climate strategy, targets,
commitments, goals and disclosures,
working with a broad set of leaders
across PTSB to encourage alignment and
coordination.
Group Risk Committee (GRC)
The GRC is a sub-committee of ExCo and
assesses bank wide risk management
issues and ensures that fair customer
outcomes are delivered. A key role within
GRC is the assessment of the impact
of CR&E risk on the Bank’s overall Risk
Profile. The GRC meets monthly, with an
update on CR&E risk consideration coming
into the Committee as required.
Group Credit Committee (GCC)
The GCC oversees and manages credit
related CR&E risk for the Bank via both
monitoring and providing regular updates
on the related Risk Appetite Statements
which are kept aligned with the Bank’s
Strategy, as well as the Bank’s Credit
Policies which are formulated considering
the Bank’s appetite as well as external
factors such as regulation, emerging risks
and market dynamics. The GCC meets
monthly, with an update on CR&E risk
consideration coming into the Committee
as required.
Customer Committee (CustCo)
The CustCo is a sub-committee of the
ExCo and is chaired by the Chief Retail
Banking Officer. The Committee approves
new, and changes to current, products
and services that are aligned to the Bank’s
Sustainability Strategy which includes
consideration for climate-related (Green
) sustainable finance Products and
Propositions. The CustCo meets monthly,
with an update on CR&E risk integration
into the Bank’s Products and Propositions
provided as required.
Assets and Liabilities Committee (ALCo)
The ALCo reviews, and is responsible for
overseeing, all activity relating to Asset
and Liability Management (ALM), Treasury
and Market Risks, including Liquidity Risk,
Interest Rate Risk, Treasury Counterparty
Risk and Foreign Exchange (FX) Risk, and
Capital Management. Oversight includes
the integration of CR&E risk into Internal
Liquidity Adequacy Assessment Process
(ILAAP) and Internal Capital Adequacy
Assessment Process (ICAAP).
The 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. The ALCo is a sub-committee of the
ExCo and is responsible for overseeing
pricing decisions. As such, the Bank’s
Green Mortgage products are approved
through this forum.
Task Force on Climate-related Financial Disclosures
(continued)
PTSB Group Holdings plc - Annual Report 2024
278
Disclosures Committee (DC)
The Bank’s Disclosures Committee is a
governance body that provides oversight
of material disclosures, including: the
Annual Report; Interim Report; TCFD
Report; Pillar 3 Report; the CSRD
Sustainability Statement; and, selected
ESG disclosures. The Bank’s disclosures
include updates relating to CR&E risk
programming and associated KPIs and the
Committee meets as required as part of
its annual reporting cycles.
Sustainability Committee (SusCo)
The SusCo acts on delegated authority
from the ExCo to provide oversight in
line with supervisory expectations on
the execution of the Bank’s Sustainability
Strategy, including a focus on CR&E risk
implementation under the ‘Addressing
Climate Change and Supporting the
Transition to a Low Carbon Economy’
pillar.
The SusCo is chaired by the CSCAO and
Executive membership includes the CEO,
CFO, CRO, Chief Operations Officer, Chief
Technology Officer and the Chief Retail
Banking Officer. The Committee operates
on delegated authority from the ExCo.
The SusCo is responsible for the delivery
of the Bank’s Sustainability Strategy by
ensuring that there is sufficient oversight,
alignment, governance and challenge of
activity across key areas of focus for the
Bank’s overall sustainability programming.
In addition, the Committee also provides
oversight of all activities relating to
ESG factors such as climate change,
that are core to operating our business
in a responsible and sustainable way,
including: Regulatory Compliance Risk,
international framework alignment,
sustainable finance (Green1) products
and propositions, business operations
and carbon impact, sourcing responsibly,
community impact and partnerships and
sustainability communications.
At a high level, the Committee is
responsible for:
• Leading on the implementation and
embedding of the Bank’s Board
approved Sustainability Strategy
(which includes a focus on CR&E risk),
ensuring that all activity is embedded
in the Bank’s ambition, purpose, culture,
1
Green Products and Propositions are those
which address the Bank’s climate change
objectives.
corporate strategy and strategic
priorities;
• Overseeing Sustainability-related
programming and providing guidance
and support to sustainability activities
across the key areas of focus set out
within the Sustainability Strategy,
including CR&E risk management as
part of the ESG Risk Management
Workstream;
• Overseeing the development of the
Bank’s SBTs and preparation of the
associated Carbon Reduction Plan;
• Engaging stakeholders as needed to
ensure organisational alignment on
key Sustainability-related risks and
opportunities (including CR&E risk), and
maintaining awareness and linkages to
other strategic programmes;
• Developing Sustainability Key
Performance Indicators (KPIs) and
processes that enable the Bank to
effectively measure, monitor and
manage them; and,
• Monitoring and reporting progress to
the Board and Executive Committee at
regular intervals throughout the year.
The SusCo meets monthly and an update
on CR&E risk is provided as part of the
ESG Risk Workstream Update. Deep
dives on CR&E risk key areas of focus
and associated progress against KPIs are
provided to the Committee outside of the
monthly update, as required.
Sustainability Steering Committee
(SteerCo)
Supporting the SusCo, the SteerCo is
made up of members from the Bank’s
Senior Leadership Team. It includes
enterprise-wide representation to ensure
a holistic and integrated approach
to support execution of the Bank’s
Sustainability Strategy. During 2024,
the SteerCo was made up of eight
workstreams, including: Governance,
Strategy and Communications;
Science Based Targets (SBTs); ESG
Data Infrastructure and Models; ESG
Risk Management; Opportunities and
Enablement; External Reporting; Social
Impact; and, Business as Usual (BAU)
delivery.
Strategy
TCFD recommendation:
Actual and potential impacts
of climate-related and
environmental risks and
opportunities on business,
strategy and financial planning,
where such information is
material.
A. Climate-related and environmental
risk and opportunities over the short,
medium and long term
Central banks and financial regulators
widely acknowledge that climate change is
a source of financial stability risk. Managing
CR&E risks and opportunities is a key area
of focus for the Bank under the ‘Addressing
Climate Change and Supporting the
Transition to a Low Carbon Economy’ Pillar
of our Sustainability Strategy.
The Bank made further progress on the
integration of CR&E risk across the Bank’s
activities during 2024, including:
• Closing the Bank’s 2022 CR&E Risk
Implementation Plan;
• Completing a Quantitative CR&E Risk
Materiality Assessment;
• Ongoing integration and remediation
of CR&E risk data to inform CR&E risk
analysis and Strategy;
• Reviewing the Risk Appetite Statement
and monitoring CR&E Key Risk Indicators
(KRIs);
• Launching an enhanced Environmental,
Social and Governance Questionnaire
(ESGQ) to support due diligence of our
Business Banking customers;
• Disclosing on CR&E risk under the
recommendations of the TCFD as
part of our annual reporting cycle and
contributing to CDP (formerly the Carbon
Disclosure Project);
• Measuring and disclosing our carbon
impact across Scope 1, 2 and 3 (including
our financed emissions); and,
• Developing science-based targets (SBTs)
in line with the Science Based Target
Initiative’s (SBTi) Version 2 Guidance for
Financial institutions. The work included
the development of a corresponding
Carbon Reduction Plan to support us
in achieving our Targets once set. The
Targets and Plan will be submitted to the
SBTi during Q1 2025 for validation. We
will communicate our Targets once the
validation process reaches completion.
PTSB Group Holdings plc - Annual Report 2024
279
Strategic Report
Governance
Sustainability
Financial Statements
General Information
In addition, the Bank continued to offer
its customers green and sustainability-
related Products and Propositions,
enabling us to support our customers in
transition, while also mitigating against
CR&E risk. Activities included:
• Continuing to build CR&E risk
considerations into the Product and
Proposition development process
and delivering c.€875 million in green
lending through the Bank’s Green
Mortgage during 2024, accounting for
43% of new Mortgage lending, +28%
YoY;
• Becoming the first lender to participate
in the Strategic Banking Corporation of
Ireland’s (SBCI’s) Home Energy Upgrade
Loan Scheme, aimed at supporting
eligible applicants who wish to invest
and improve in the energy efficiency of
a residential property. The Bank has the
ability to provide €100m in funding;
• Participating in the SBCI’s Growth and
Sustainability Loan Scheme, offering
€70m in loans; and,
• Issuing the Bank’s inaugural €500m
Green Bond.
PTSB continues to invest in resources
to deliver on its Sustainability
Programme objectives, which includes
the appointment of a CSCAO, Head of
Sustainability and a supporting team.
A professional services firm is also in
place to provide strategic guidance and
advisory support, where required.
CR&E risk is a Key Risk Category
defined within the Bank’s Enterprise Risk
Management Framework (ERMF) of which
there are two sub-risk categories, Physical
Risk and Transition Risk. Both sub-risk
types may act as a driver that impacts
the financial services sector to varying
degrees over a range of plausible climate
scenarios, across 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 organisation’s business
model, customer base, geographical
location as well as the transition process
to a low-carbon economy.
The Physical and Transition Risk
definitions outlined within the Bank’s
Task Force on Climate-related Financial Disclosures
(continued)
ERMF, for reference by all Business Units,
are as follows:
Physical Risk
Physical Risk, the risk of economic cost
and financial losses resulting from the
increasing severity and frequency of:
• Acute Physical Risk - arises from
extreme weather events, such
as floods, storms, droughts, and
heatwaves; and,
• Chronic Physical Risk - arises
from longer-term gradual shifts in
climate patterns, such as increasing
temperatures, sea-level rises, water
stress, biodiversity loss, land use
change, habitat destruction and
resource scarcity.
Transition Risk
The risk of economic cost, financial
loss or an adverse outcome related to
the process of adjustment towards a
low-carbon and more environmentally
sustainable economy. Transition to a low-
carbon economy may require substantial
policy, legal, technology and market
changes. These changes may result in
a financial loss and reputational risk to
organisations, with the severity of this
depending on the scope and speed of
change required.
Transition Risk may include:
• Policy Risks that come with the
evolution of policies and regulations
that promote the adaptation to a less
carbon intensive and more sustainable
economy, and those that constrain
actions that lead to climate change and
harm the environment;
• Legal Risks that relate to litigation
claims against institutions and their
representatives who fail to mitigate
and adapt to climate change, and who
fail to disclose material climate and
environmental information;
• Market Risks that arise through
changing demand and supply for
commodities, products and services;
and,
• Reputation Risk that relates to the
changing stakeholder perception
of institutions’ commitments to, or
detraction from, the transition to a
lower-carbon economy.
There is a level of uncertainty regarding
the timing of both climate-related
Physical and Transition Risk. CR&E risk
may materialise in the short, medium and
long-term and as such, it is important for
organisations to take a forward-looking
approach and consider a longer than usual
time horizon when assessing CR&E risk.
The impacts of climate change are
predicted to occur over longer time
horizons then the typical cycle of financial
institutions’ analysis and forecasting.
Therefore, to ensure the meaningful
assessment of the far-reaching impacts
of CR&E risk, time horizons must reflect
this long-term nature. A review of existing
defined time horizons within PTSB was
conducted, considering European Central
Bank (ECB) good practice, industry
peers and internal processes, resulting
in the below time horizons being applied
within the Bank’s CR&E Risk Materiality
Assessment.
At a Group level, Physical and Transition
(CR&E) risk are considered through the
following time horizons.2
From
(years)
To
(years)
Short-Term
0
3
Medium-Term
3
5
Long-Term
>5
The Bank completed a qualitative CR&E
Risk Materiality Assessment in 2023
that served as a key exercise in the
assessment of CR&E risk and how it may
impact upon other Risk Categories of the
Bank.
In 2024, a quantitative CR&E Risk
Materiality Assessment was completed
which contains a detailed review of the
potential impacts of CR&E risk upon the
Gross Risk Profile of the Bank across the
Key Risk Categories defined in the ERMF.
This assessment included a granular
review and identification of the relevant
and material CR&E risk drivers (across
Physical and Transition sub-risks) and
corresponding transmission channels that
could manifest for PTSB.
2
These Time Horizons were updated in 2024, in
line with the methodology applied to the CR&E
Materiality Assessment. Previously used Time
Horizons were Short-Term 0-1, Medium Term
1-5 and Long Term 5-30.
PTSB Group Holdings plc - Annual Report 2024
280
The assessment included a detailed description of the relevant transmission channels between Physical and Transition Risk drivers
and conventional Risk Categories as defined in the ERMF. It built upon the 2023 assessment by leveraging plausible climate futures as
developed by the Network for Greening the Financial System (NGFS) scenarios and applying quantitative analysis where appropriate.
The below table provides a description of defined CR&E risk drivers used to structure the identification and attribution of CR&E risk
transmission channels. For the purposes of this exercise, the following definition of CR&E risk transmission channels was used: ‘the
causal impact chains that explain how CR&E risk drivers give rise to the financial risks faced by PTSB (directly or indirectly)’.3-4
ERMF Sub-risk
Driver
Description
Physical Risk
Acute
Extreme weather events and their impacts such as flooding.
Chronic
Long-term gradual shifts to climate patterns, sea-level rise, temperature rises, and
coastal erosion.
Transition Risk
Policy &
Regulation
Changes to external policy and regulation to support the transition towards a low
carbon economy and other climate impacts.
Technology
Technological advancements that require businesses to adapt to remain competitive
or may improve resilience to climate change.
Behaviour &
Sentiment
Changes to behaviour and sentiment (consumers, investors, suppliers, third parties,
and wider market) that may impact demand for certain sustainable or green
products, services, and performance.
The CR&E Risk Materiality Assessment considered the transmission channels through a forward-looking perspective across short (0-
3), medium (3-5) and long (>5) term horizons, as well as across four plausible climate future scenarios. These scenarios were based
on NGFS scenarios namely: ‘Orderly’, ‘Disorderly’, ‘Hot House World’ and ‘Too Little Too Late’. These scenarios were used to provide
a structured narrative regarding the potential impacts of climate-related risk as applicable to the financial sector.3 Given the cross-
cutting nature of CR&E risk, the diverse forms through which it may manifest across other Risk Categories (as defined in the ERMF)
was comprehensively assessed.
The process for identifying potential transmission channels for CR&E risk impacts was led by subject matter expertise from across
the Bank (including 1LOD and 2LOD), Group Risk documentation and internal resources. In addition, industry good practice further
supported the assessment, including the ECB’s Thematic Review on Climate and Environmental Risk (2022)4.
The outputs from the 2024 CR&E Risk Materiality Assessment demonstrated the cross-cutting nature of CR&E risk as a driver of
Risk across the Bank’s Key Risk Categories. The assessment identified CR&E risk as a relevant consideration and driver of Risk for all
Categories assessed at an enterprise-level. Furthermore, the impact of CR&E risk was assessed as material for four Risk Categories
(Credit, Business, Compliance and Reputational and Conduct Risks) based on how CR&E drivers and associated transmission
channels could potentially manifest as potential financial loss for the Bank.
Differing risk profiles and time horizons were assessed across the relevant NGFS scenarios. For example, the ‘Orderly’ Scenario
included a range of Transition Risks in the short and medium time horizon due to global Net Zero ambitions and associated actions.
The ‘Disorderly’ Scenario, premised on a delayed transition after 2030, included a range of Transition Risk drivers materialising in
the long-term horizon, whereas Physical Risk was the primary driver under the ‘Hot House World’ Scenario, whereby inaction to limit
atmospheric warming would lead to both acute and chronic risk impacts becoming more severe over time.
Among the most significant transmission channels identified for Physical Risk, particularly driven by the risk of extreme storms and
flood events, were the potential financial impacts upon Collateral Valuations and Customer repayment capacity (Credit Risk), and
Facilities and Business Continuity impacts (Operational and IT Risk). For Transition Risk, significant transmission channels identified
included potential impacts upon market share and competitiveness (Business Risk), potential brand image and other reputational
impacts (Reputational and Conduct Risk) and increasing CR&E Risk-related policy and regulatory obligations and expectations
(Compliance Risk).
The table below summarises the potential impacts that are driven by CR&E risk in the short (S), medium (M) and long (L) term. In
the following summaries, the impact of CR&E risk was determined as Material (suspected that it may manifest as material risk under
prescribed conditions) or Relevant (may manifest as increased risk under prescribed conditions, but at a low or minor level).
3
Network for Greening the Financial System (NGFS), Scenarios Portal, 5th vintage, 2024 (https://www.ngfs.net/ngfs-scenarios-portal/)
4
Walking the talk Banks gearing up to manage risks from climate change and environmental degradation Results of the 2022 thematic review on climate-related
and environmental risks. https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.thematicreviewcerreport112022~2eb322a79c.en.pdf
PTSB Group Holdings plc - Annual Report 2024
281
Strategic Report
Governance
Sustainability
Financial Statements
General Information
ERMF Risk Category
Summary
Time Horizon
Credit Risk
The potential impact is Material as both Physical and Transition Risk may impact collateral
valuations and customer ability to service repayments, becoming increasingly material over
time.
S/M/L
Compliance Risk
The potential impact is Material as the regulatory environment already includes CR&E Risk-
related expectations for PTSB that will increase over time.
S/M/L
Reputational &
Conduct
The potential impact is Material Transition Risk drivers are already present and actin upon
PTSB, its customers and the wider operating model.
S/M/L
Business Risk
The potential impact is Relevant in particular with regards to acute Physical Risk applicable
in the short term, albeit not expected to be material at an enterprise level until the long-
term.
S/L
Op & IT Risk
The potential impact is Relevant but limited in the long term due to PTSB’s limited exposure
to market factors (for example, Credit Risk Spread).
S/M/L
Capital Adequacy
Risk
The potential impact is Relevant with CR&E factors already in place as part of existing
ECB expectations, which are not anticipated to be material in the short term but could
strengthen over time.
S/M/L
Liquidity & Funding
Risk
The potential impact is Relevant with most impacts identified in the long term with the
exception of the Orderly scenario due to macroeconomic disruption in the near-term.
M/L
Model Risk
The potential impact is Relevant but limited in the short-term, although may increase over
time as CR&E-related model use becomes desirable or necessary within processes and
procedures.
M/L
Climate-related and Environmental Risks and Opportunities
B. Impact of climate-related risks and opportunities on business, strategy, and financial planning.
At present, the Bank does not yet formally assess how identified climate-related issues have affected or will affect the business,
strategy, and its financial planning.
PTSB has in place an overarching three-year strategic and financial plan for the Bank - The Integrated Strategic Plan.
The Plan sets out the core priorities of the Bank and considers the needs of our stakeholders. PTSB channels its investment and
efforts into the activity required to deliver on the strategic initiatives that have been agreed within the Plan.
Sustainability is at the heart of the Plan, enabling us to put it at the centre of how we run and grow our business. Key commitments
include:
• Embedding consideration for sustainability (and CR&E risk) into all areas of our business;
• Meeting sustainability-related regulation and mitigating against ESG risk (including CR&E risk);
• Ensuring that our workforce have the right knowledge and capability to deliver our sustainability and CR&E risk objectives;
• Enhancing mortgage and retrofit propositions for personal customers; and,
• Introducing sustainability propositions for our Business Banking customers.
Task Force on Climate-related Financial Disclosures
(continued)
PTSB Group Holdings plc - Annual Report 2024
282
Key areas considered during the Bank’s 2024 SPP included:
Pillar
Activity/Focus
CR&E Risk
CR&E
Opportunity
Strategy:
• Evolving the Bank’s approach to Sustainability Programme governance with
the appointment of a CSCAO, Head of Sustainability and supporting team;
and,
• Refreshing SusCo membership, the establishment of a Sustainability
Steering Committee and ongoing individual workstreams of activity led by
Accountable Executives and Senior Leaders from all areas of the business.
CR&E Risk
Management
• Introducing a CR&E Risk Management Framework (CR&E RMF) under
the overarching ERMF. This supports an enterprise-wide integration and
understanding of the cross-cutting relevance of CR&E risk, including a
definition of CR&E risk with sub-risk categories (Physical and Transition) for
reference by all Business Units; and,
• Further building consideration of climate-related risk into the Bank’s ICAAP
and ILAAP.
Data
• Completing time horizon mapping of the Bank’s backbook assets based on
Physical Risk (coastal, fluvial and pluvial) data;
• Incorporating address matching with GeoDirectory data to remediate
geolocation details;
• Validating Transition Risk via both collection of the Building Energy Rating
(BER) certificates and BER estimates using the Sustainable Energy Authority
of Ireland (SEAI) data;
• Leveraging enhanced data sets to populate External Reporting Disclosures
(including, CSRD Sustainability Statement, EU Taxonomy and Pillar 3 ESG
Templates);
• Ongoing data enhancements to obtain projected flood depths and
frequency to support advanced analysis related to collateral valuations,
modelling and stress testing;
• Introducing an ESGQ for the Bank’s Business Banking Customers to assist in
gathering Due Diligence information; and,
• Ongoing supplier engagement as part of due diligence within the onboarding
process. As part of the process, new suppliers are encouraged to submit
information relating to their organisation including ESG topics such as
emissions targets, carbon emissions, and renewable energy use.
Products and
Propositions:
• Reviewing sustainable finance product and proposition development, with
particular emphasis on the Bank’s most material Mortgage Portfolio which
accounts for 93% of the book (as of 31 December 2024);
• Launching a €100m in funding through the Strategic Banking Corporation of
Ireland’s Home Energy Upgrade Loan Scheme; and,
• Supporting our Business Banking customers in transition through our
partnership with the Teagasc Signpost Programme.
Disclosures:
• Increasing transparency relating to CR&E risk through disclosures such
as the TCFD, CDP (formerly the Carbon Disclosure Project), Pillar 3 ESG
Templates, EU Taxonomy and the Corporate Sustainability Reporting
Directive (CSRD).
Metrics and
Targets:
• Measuring and disclosing our carbon emissions across Scope 1, 2 and 3
(including the financed emissions associated with our Mortgage, Business
Banking and Asset Finance Portfolios);
• Receiving limited assurance on the Bank’s carbon emissions data by an
independent third party; and,
• Developing SBTs and a corresponding Carbon Reduction Plan. The Targets
and Plan will be submitted to the SBTi for validation during Q1 2025.
PTSB Group Holdings plc - Annual Report 2024
283
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Pillar
Activity/Focus
CR&E Risk
CR&E
Opportunity
Adaptation
and Mitigation
Activities/
Operations
(including
types of
operations
and location of
facilities):
• Purchasing 100% energy certified as renewable;
• Continuing the roll out of energy smart metres across our branch locations
to get information relating to consumption in real time;
• Completing the data centre migration to new and more efficient buildings;
• Installing EV chargers at our most populated administration sites; and,
• Introducing hybrid vehicles into the PTSB fleet which now make up 56% of
the overall fleet.
Supply Chain:
• Ensuring responsible procurement practices and continuing to embed a
Sustainable Supplier Charter, in line with ISO20400.
Investment in
Research and
Development:
• Continuing to contribute to sustainable finance thought leadership through
our founding membership to the International Sustainable Finance Centre of
Excellence.
Resources
and Capacity
Building:
• Appointing a CSCAO, a Head of Sustainability and supporting team.
• Provisioning adequate funding for the delivery of the Bank’s Sustainability
Strategy and integration of CR&E risk into all areas of the business.
• Developing a Learning and Development Strategy focussed on upskilling the
Bank’s colleagues across the Sustainability agenda (including CR&E risk);
and,
• Delivering training and supports to the Board, Executive Committee and the
Senior Leadership Team.
Products and Propositions - An opportunity to support our customers in the transition to a low carbon future
Notwithstanding the fact that climate change presents risk to financial institutions, it also brings with it a significant opportunity to
meet new customer needs and drive the commercial agenda.
The Irish Government has committed to achieving a 51% reduction in overall greenhouse gas emissions by 2030, from a 2018
baseline, and setting the country on a path to reach net zero emissions by no later than 20505,6
PTSB 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. Sustainable finance 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.
PTSB’s Portfolio is residential in nature with c.93% of the book (as of 31 December 2024) being secured on residential property. As
such, it is deemed a material Portfolio for the Bank and a priority area of focus when it comes to both managing and mitigating against
CR&E risk.
Green Mortgage
PTSB has in place a Green Mortgage offering, a 5-Year and 3-Year Fixed Rate Product available to all new and existing home loan
customers, where their homes have a confirmed or proposed BER of A1 to B3. The Bank built on the success of its 5-Year Fixed Rate
product, by introducing a 3-Year Fixed Rate option for customers during 2024. During 2024, c.€875m in green lending was drawn
down, accounting for 43% of new Mortgage lending, +28% YoY.
The Bank has in place a set of Green Product and Proposition Design Principles that help to guide, inform and prioritise the
development of end-to-end green product offering(s) over the short to medium-term.
Strategic Banking Corporation of Ireland’s (SBCI) Home Energy Upgrade Loan Scheme
PTSB was accepted as a participating lender on the SBCI’s Home Energy Upgrade Loan Scheme. The Scheme is aimed at supporting
eligible applicants who wish to invest and improve in the energy efficiency of a residential property. PTSB was successful in obtaining
€100m in funding and was the first Bank to launch the Scheme to the market in April 2024.
5
These national targets align with Ireland’s obligations under EU and international treaties, most notably the Paris Agreement (2015) and the European Green Deal
(2020) (https://www.gov.ie/en/publication/79659-climate-action-plan-2024/)
6
Ireland’s Climate Action Plan (2024) (https://www.gov.ie/en/publication/79659-climate-action-plan-2024/)
Task Force on Climate-related Financial Disclosures
(continued)
PTSB Group Holdings plc - Annual Report 2024
284
Supporting the Bank’s Business Banking
Customers
PTSB is focused on supporting its
Business Banking customers, with an
added layer of focus on customers who
need additional support to establish
infrastructure for climate friendly, resilient
business models.
We are committed to:
• Developing lending products for
Business Banking customers that
support sustainability goals and
objectives as part of the Bank’s focus
on future green product and proposition
development;
• Securing €70m of new funding through
the SBCI’s Growth and Sustainability
Loan Scheme which launched during
2024;
• Embedding the Teagasc Signpost
Programme into our lending processes
for Agri customers; and,
• Introducing specialised training to
support the Agri sector with the help of
Teagasc.
C. Description of the resilience of
the organisation’s strategy, taking
into consideration different climate-
related scenarios, including a 2°C or
lower scenario.
Use of Climate Change Scenarios to
Assess Strategic Resilience
At present, the Bank does not yet formally
use climate-related scenario analysis to
assess Business Strategy resilience.
An updated CR&E Risk Materiality
Assessment was completed in 2024 that
adopted a forward-looking perspective
using CR&E risk transmission channels
to identify how CR&E risk drivers may
manifest risk across other Risk Categories
as defined in the ERMF. This assessment
leveraged four plausible climate futures
based on the NGFS scenarios designed
for use in the financial sector and applied
quantitative analysis to material CR&E risk
transmission channels.
During 2024, CR&E risk was measured
as part of the Bank’s Operational and IT
Risks Pillar 2 Internal Capital Adequacy
Assessment (ICAAP). A CR&E Physical
Risk standalone sub-scenario was
assessed through a business disruption
scenario, in respect of non-financial
risk impacts. In addition, the impact of
CR&E risk on the Bank’s Retail Mortgage
Portfolio has been completed by way of
sensitivity analysis based on data as of
31st December 2023.
CR&E risk will continue to be considered
as part of future ICAAP and Internal
Liquidity Adequacy Assessment (ILAAP),
with scenarios to be enhanced as
appropriate, and as data availability to
support scenario development continues
to evolve.
Insights gained from the Bank’s Risk
Materiality Assessment, which ensures
that all material risks are identified,
monitored and effectively managed, will
further increase the Bank’s understanding
of CR&E risk, strengthen the Bank’s
ICAAP and ILAAP scenario development
processes and inform the Bank’s Strategy
into the future.
Risk Management
TCFD recommendation:
Disclose how the organisation
identifies, assesses and
manages climate-related risks.
A. Processes for identifying and
assessing climate-related and
environmental risks
Please visit the Strategy section on page
279 for more information on activities
conducted by the Bank to identify and
assess CR&E risk, including the CR&E
Risk Materiality Assessment that was
completed during 2024.
CR&E risk management is integrated
within the existing ERMF through the
inclusion of the CR&E RMF and adopted
across the 3LOD Model.
Through the embedding of CR&E risk
within the established ERMF structure
and conventional risk categories,
CR&E risk can now be considered as
integrated across the 3LOD model of
risk management. Each line of defence
performs its duties by identifying and
assessing CR&E risks, analysing the
relevance of risks, evaluating the impact
on the Bank’s operations and business
and formulating control measures and
response strategies.
The First Line of Defence (1LOD Business
Units and Functions), undertake frontline
commercial and operational activities and
their support function is responsible for
identifying, owning, managing, monitoring,
and mitigating against CR&E risk.
The Second Line of Defence (2LOD Risk
and Compliance Function), ensure that
all CR&E risks are identified, assessed,
measured, monitored, managed, and
properly reported on by the relevant
Business Units from across the Bank.
As the Third Line of Defence (3LOD),
Group Internal Audit provide independent
assurance to the Board over the
adequacy, effectiveness and sustainability
of the Bank’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
Bank, in relation to CR&E risk.
Regulatory Compliance Framework
The Regulatory Compliance Framework
supports the Bank in achieving its
strategic priorities while managing
regulatory compliance risks within the
Board-approved Regulatory Compliance
Risk Appetite. In addition, it sets out
how the Bank manages current and
emerging Regulatory Compliance Risk
(including CR&E risk) and details the
key principles, objectives, and primary
components of PTSB’s approach to
Regulatory Compliance Risk Management
and sets out Regulatory Compliance Risk
Management responsibilities across the
3LOD Model.
To ensure the effective implementation of
the Regulatory Compliance Framework,
the Bank continues to engage with
external information sharing forums,
including the Banking and Payments
Federation of Ireland (BPFI), through
which it shares and receives information
related to Regulatory Compliance Risk
trends and threats and evolving industry
best practice.
Risk and Control Self-Assessment
(RCSA)
The RCSA is one type of formal
assessment of the risks and the
effectiveness of the controls to manage
these risks, including those aligned to the
CR&E Risk Categories.
PTSB Group Holdings plc - Annual Report 2024
285
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The RCSA process supports the
monitoring of CR&E risk within selected
Business Units. Business Units are
required to review the accuracy and
completeness of these risks and
mitigating controls on an on-going basis
and report their test results periodically.
Climate-related Stress Testing
The Bank previously conducted a high-
level climate stress test and sensitivity
analysis leveraging the macroeconomic
and Climate Scenarios Framework used
as part of the ECB Climate Stress Test
(2022), with a primary focus on the Bank’s
most material Portfolio (Retail Mortgages).
Capital and Liquidity
The Bank integrates consideration for
CR&E risk into its ICAAP and ILAAP, with
a focus on iteratively improving through
each risk cycle.
During 2024, CR&E risk was measured
as part of the Bank’s Operational and IT
Risks Pillar 2 Internal Capital Adequacy
Assessment (ICAAP). A CR&E Physical
Risk Scenario was developed consisting
of two sub-scenarios: a typical disruption
due to a red weather warning, and a
severe disruption due to severe flooding
at multiple locations. The output indicated
significant disruption of the Bank’s
business as usual activities, due to an
external event caused by climate changes,
resulting in financial loss, customer
detriment, reputational damage and
regulatory sanctions.
In addition, a credit sensitivity analysis
was conducted on the Bank’s Retail
Mortgage Portfolio based on segmenting
the Portfolio in respect to Transition and
Physical Risk rating. At this time, this has
not resulted in a material adjustment to
the Bank’s financial position.
CR&E risk will continue to be embedded
and matured as part of future ICAAP
iterations.
Furthermore, a CR&E Risk Qualitative
Assessment on ILAAP risks was produced
for ILAAP 2024. The purpose of this
exercise was to identify what the impacts
of Physical and Transition Risk could be on
the Liquidity and Funding Risk. This serves
as a fundamental first step for future
integration of CR&E risk into the Bank’s
ILAAP process and will be developed
further in future iterations.
Horizon Scanning and Information
Sharing
As part of the Bank’s ongoing assessment
of CR&E risk, the Bank is a member of
information sharing forums, including
the BPFI, Central Bank of Ireland’s (CBI’s)
Climate Risk Forum, the Sustainable and
Responsible Investment Forum and the
National Climate Stakeholder Forum,
through which it shares and receives
information related to the latest Climate
Risk trends and threats and gets insight
into evolving industry best practices.
The Bank monitors regulatory changes
and guidance, including from the CBI and
ECB.
B. Processes for managing climate-
related and environmental risks.
The management of CR&E Risk is aligned
to key processes and components set
out in the Bank’s ERMF, which identifies
core risk management stages which
collectively ensure that the Bank
appropriately identifies and manages
current and emerging risks the Bank is
exposed to.
CR&E Risk Integration
The management of CR&E risk within
each of the individual ERMF Key Risk
Categories is a key area of focus for the
Bank.
The CBI requested individual Lesser
Significant Institutions (LSIs) to submit
a Board approved comprehensive plan
by June 2022 on how the Bank plans
to address supervisory expectations
in relation to CR&E risk. In line with this
request, the Bank submitted its CR&E Risk
Implementation Plan within the required
timeline, and throughout 2022 and
2023 deployed resources to ensure its
implementation.
During the first half of 2024, the Plan
was formally closed in line with agreed
timelines marking the formalisation of
CR&E risk integration across the Bank
in line with regulatory expectations.
Following closure of the Plan, an ESG
Risk Strategy was developed as part of
the work of the ESG Risk Management
Workstream under the Sustainability
Programme. The Strategy builds upon
the progress made integrating CR&E risk
across the Bank through the CR&E Risk
Implementation Plan and is aligned to
regulatory expectations.
The Bank has established strong
governance of CR&E risk through the
creation of SusCo, which operates as
a sub-committee of the ExCo; updated
BRCC Terms of Reference (ToR) to include
CR&E Risk considerations, formalisation
of a CR&E risk definitions and the
introduction of a CR&E RMF.
While the Bank is focused on delivery
and stepping up the pace in embedding
CR&E risk over the short-term, it is
mindful of creating capacity and building
a robust long-term strategic approach
to CR&E risk management, which aligns
to best practice. This will ensure there
is comprehensive integration within
Strategy, Data, Risk Management and
Product Strategy, supported by enabling
activities such as capacity building,
training and decision useful disclosures.
Policies & Frameworks
The Bank considers ESG factors per
loan origination guidance in Credit Risk
assessments on the Business Banking
Portfolio. For the Retail Portfolio, new
Mortgage applications are required to
capture the BER and have to provide
evidence of flood insurance.
A Regulatory Compliance Framework is
in place which sets out how the Bank
manages current and emerging Regulatory
Compliance risks and upstream analysis
is completed in the Bank’s Upstream
Regulatory Registry to identify upcoming
regulatory requirements with which the
Bank must comply.
Risk Register
The Risk Register contains the details
of current and emerging risks from each
of the Group Risk functions, including
CR&E risk, utilising the ‘top down’ Risk
Identification and ‘bottom up’ RCSA
processes which form the basis of the
Bank’s Top 10 and Emerging Risks Report.
Task Force on Climate-related Financial Disclosures
(continued)
PTSB Group Holdings plc - Annual Report 2024
286
Risk Appetite
Risk Appetite is set by the Board and
represents the level and nature of risk
(within the Risk Categories) that the
Bank is willing to accept in pursuit of
its strategic objectives. A qualitative
CR&E Risk Appetite Statement has been
included in the Bank’s Risk Appetite
Statement confirming that the Bank’s
appetite for CR&E risk is ‘Medium’,
reflecting the cross-cutting nature of
this risk and the Bank’s existing risks.
Through the delivery of the CR&E Risk
Implementation Plan, CR&E metrics have
been designed including those related to
Credit Risk, which are being monitored
monthly, Financial, which are being
monitored quarterly and Operational and
IT Risk, which has been integrated into the
regular tracking and reporting process.
Business Continuity Management (BCM)
The Bank has in place a BCM Plan that
considers adverse weather conditions that
may, in some cases, cause a reduction in
operational capacity.
Physical Risk Analysis
The Bank has progressed Physical Risk
analysis in the Lending Portfolio. The
Bank has utilised publicly available flood
mapping data, taken from the Office of
Public Works (OPW), to carry out analysis
on the Retail Mortgage Lending Portfolio
to identify areas of Physical Risk.
The Bank has also sourced data from
an external data provider to further
enhance mapping and assessing of CR&E
risk impact. This has enabled and will
continue to support the progression of
CR&E analysis with the most accurate and
up to date CR&E risk view in our Lending
Portfolio.
For Ireland, these risk types correspond
to coastal erosion and fluvial and pluvial
flood risk. The Bank has mapped property
in the PTSB Retail Mortgage Portfolio
into relevant segments based on defined
flood risk scores and corresponding risk
thresholds. This forms part of the relevant
CR&E risk metrics incorporated within
standard monthly reporting processes as
further data requirements are developed.
C. Integration of processes for
identifying, assessing and managing
climate-related and environmental
risks into overall risk management.
CR&E risk issues are integrated across
all governance mechanisms through
delivery of the Board approved ESG Risk
Workstream. A CR&E RMF has also been
developed that is linked to the ERMF.
CR&E Risk as a Key Risk
CR&E risk is included as a Key Risk
Category within the ERMF and has two
sub-risk categories of Physical Risk and
Transition Risk. Over the last year, the
Bank has continued to integrate CR&E
risk into the Bank through a suite of
supporting documentation, such as, the
ERMF, the CR&E Risk Framework and
associated Frameworks and Policies. The
supporting documentation describes the
activities required to support the ongoing
risk management process, and to promote
a comprehensive and consistent approach
to risk management across the Bank.
Materiality Assessment
As outlined above, a refreshed CR&E Risk
Materiality Assessment was conducted
that adopted a transmission channel
lens, including forward-looking analysis
and consideration for plausible climate
futures. The aim of this assessment was
to further understand the impact of CR&E
risk (Physical and Transition Risk) on the
Bank’s existing Risk Categories in the
ERMF.
The outputs of this assessment identified
several Physical and Transition Risk
transmission channels as material,
including a number within the Key Risk
Categories of Credit Risk, Compliance
Risk, Reputation and Conduct Risk
and Business Risk. Where possible,
quantitative analysis was completed
and will be used to drive further risk
management enhancements.
Review of Policies:
The allocation of roles and responsibilities
across the 3LOD are clearly set out within
the CR&E RMF.
Priority Policies have been identified for
consideration of CR&E risk enhancements,
with further updates to follow as part of
the Bank’s Policy Review Cycle.
Monitoring of CR&E risk requirements
will continue in business as usual as
both, CR&E risk, and the Bank’s own risk
management processes evolve.
Metrics and Targets
TCFD recommended
disclosure: Disclose the metrics
and targets used to assess
and manage relevant climate-
related risks and opportunities
where such information is
material.
A. Metrics used to assess climate-
related and environmental risks and
opportunities in line with strategy
and risk management process.
PTSB has a suite of Credit Risk-related
metrics that are in place and being
monitored monthly covering Data, Physical
and Transition Risk. In addition, two
Board-level Key Performance Indicators
(KPIs) related to CR&E risk factors were
developed as part of the CR&E Risk
Implementation Plan. These KPIs aim to
enhance the monitoring and oversight
capacity of the Board in relation to CR&E
risk factors, such as Financed Emissions.
PTSB’s focus is on continuing to disclose
transparently with a commitment to
measuring and managing the carbon
impact of our operations and lending
portfolio.
We measure our carbon emissions across
Scope 1, 2 and 3 using the Greenhouse
Gas (GHG) Protocol. In the measurement
of Scope 3 Category 15 – Investments
(our financed emissions) we used the
Partnership for Carbon Accounting
Financials (PCAF), Financed Emissions
Standard.
Scope 1 includes direct GHG emissions
from sources that are owned or controlled
by the Bank, such as natural gas
combustion and company owned vehicles.
Scope 2 accounts for GHG emissions from
the generation of purchased electricity,
heat and steam generated off-site.
The emissions are reported using both
a location-based and a market-based
method.
Scope 3 includes all the Bank’s other
indirect emissions: Purchased Goods and
Services, Capital Goods, Other Fuel and
Energy, Transportation and Distribution,
Waste, Business Travel, Employee
Commuting (including home working) and
Investments (financed emissions).
PTSB Group Holdings plc - Annual Report 2024
287
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Scope 3 categories which have been deemed immaterial to the Bank include Leased Assets, Processing of Sold Products, Use of Sold
Products, End-of-Life Treatment of Sold Products and Franchises. These categories will be monitored annually to ensure that they
remain immaterial.
B. Disclose Scope 1, Scope 2 and, if appropriate, Scope 3 greenhouse gas (GHG) emissions and the related risks.
A breakdown of our carbon impact across Scope 1, 2 and 3 can be found below:
Emissions
2023 tCO2e
2024 tCO2e
Scope 1
841
882
Scope 2 (Location-based value)
2,217
1,714
Scope 2 (Market-based value)
0
0
Scope 3
295,820
301,479
Total (Location-based value)
298,878
304,075
Total (Market-based value)
296,661
302,361
Scope 3 emissions breakdown
2023 tCO2e
2024 tCO2e
Purchased Goods and Services
19,117
19,586
Capital Goods
662
869
Other Fuel & Energy
335
317
Upstream Transportation and Distribution
1,827
838
Waste
7
2
Business Travel
167
272
Employee Commuting
5,840
6,024
Investments - Financed Emissions
267,865
273,571
Intensities
2023 tCO2e
2024 tCO2e
Scope 1 & 2 (Location-based value) tCO2e/FTE
0.92
0.88
Scope 1 & 2 (Market-based value) tCO2e/FTE
0.25
0.24
Total (Location-based value)/€million Revenue
343.54
303.47
Total (Market-based value)/€million Revenue
340.99
301.76
Notes:
•
Total Scope 1, 2, and 3 GHG emissions were previously reported as 345,093 tCO2e in the PTSB Annual Report 2023. The revision in the figure is due to
refinements in data quality and accuracy used in calculating the mortgage portfolio financed emissions.
•
Data was calculated using The Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, Revised Edition, (‘GHG Protocol’) methodology and
Partnership for Carbon Accounting Financials (PCAF) Financed Emissions Standard.
•
Emission factors were sourced from DEFRA’s Greenhouse gas reporting: conversion factors 2024, the Commission of Utilities (CRU) 2023, Carbon Cube,
Climatque and Motorcheck.ie.
•
The CarbonCube® uses procurement spend data to calculate carbon emissions. Spend data is categorised, and emissions factors are matched to the
categorised spend to calculate emissions. This data can then be enhanced over time with supplier-specific data, as it becomes available.
•
We adopt the operational control approach on reporting boundaries. In 2024, the data covers 100% of our operations in the Republic of Ireland.
•
All 15 categories of Scope 3 emissions were evaluated, and material categories have been disclosed.
•
Category 15 includes the Bank’s Retail and Commercial Mortgage Portfolio and Asset Finance Motor Vehicle Loans for Personal and Business Banking
customers. Mortgage Portfolio emissions are calculated as a product of Carbon Intensity*LTV*Floor Area. LTV is calculated as (Accumulated Balance
Amount)/(Original Value Amount), generating a value between 0 and 1. Asset Finance Motor Vehicle Loan emissions are calculated as a product of attribution
factor*distance travelled*CO2 Emissions. Attribution factor is calculated as (Outstanding Amount / Total value at origination), generating a value between 0 and
1.
•
Data is subject to estimation and there exists limitations of the accuracy of the data as an input to the estimate. Our approach will continue to evolve in line with
industry developments and as data quality improves.
•
Figures are rounded.
Task Force on Climate-related Financial Disclosures
(continued)
PTSB Group Holdings plc - Annual Report 2024
288
Scope 1 and 2
During 2024, we continued to make progress in reducing our Scope 1 and 2 carbon emissions. This has been achieved through the
procurement of 100% energy certified as renewable from 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.
Our absolute carbon emissions have decreased by 15% since 2023 (using Scope 2 location-based values).
Scope 3
As part of our ongoing commitment to reduce our carbon footprint, during 2024, we progressed our data collection processes for our
Scope 3 emissions. Through our partnership with Efficio, we have used the CarbonCube® spend based carbon footprint calculator,
refining the methodology of calculating emissions through detailed classification of spend categories for Purchased Goods and
Services, Capital Goods, Upstream Transportation and Distribution and Business Travel.
For emissions associated with Waste and Water, activity data provided directly from our suppliers is used to calculate emissions. For
Employee Commuting, an employee survey is used to gather responses on our colleagues commuting and work from home habits.
Scope 3 – Financed Emissions
Mortgage Portfolio
Over the past number of years, the Bank has been reporting on its Mortgage Portfolio emissions. Throughout 2024, this process was
streamlined, and further data enhancements have led us to recalculate our Mortgage Portfolio emissions which constituted 93% of
the Bank’s total Loan Book as of 31 December 2024.
To calculate emissions associated with the Mortgage Portfolio, the Bank used available BER codes that have a kg CO2e/m2 identified,
currently c.22%. To address the gap, a BER proxy process was developed to estimate the BER rating where no valid BER certificate
was available.
This process relies on identifying the property location by matching property addresses to Eircodes and available collateral
characteristics (age, dwelling type, heating fuel type and location) to estimate BERs and kg CO2e/m2.
The proxy methodology stems from the creation of a Lookup Table which is generated using the data sourced externally from the
Sustainable Energy Authority of Ireland (SEAI), which contains a complete list of c. 1.2m properties from the national distribution. This
Lookup Table contains averaged ratings across key characteristic variables present in both datasets. These averages are what are
used to fill in the blanks of unknown data points within the mortgage book and are extrapolated to generate the Financed Emissions
estimate.
Using the standards set by the Partnership for Carbon Accounting Financials (PCAF), the emissions are calculated as follows:
Financed Emissions = Σ(Attribution Factor x Buildings Emissions)
This process resulted in a total estimate for Scope 3 Financed Emissions for the Retail Mortgage Portfolio of 252,817 tCO2e and
Commercial Mortgages of 3,677 tCO2e for 2024, resulting in a 4% reduction in absolute emissions since 2023.
We are committed to continually improving data quality over time and will disclosure transparently on any changes in methodologies
or emissions.
Asset Finance Portfolio – Motor Vehicle Loans
To calculate emissions associated with the Motor Vehicle Loans, the Bank sourced CO2 values for each vehicle measured in grams
per kilometre (g/km) and the average kilometres travelled in the year (segmented by vehicle and fuel types) from external sources,
currently for 60% of the motor vehicle exposure. A proxy value was then used to estimate the emissions for the remaining 40% of the
Portfolio.
PTSB Group Holdings plc - Annual Report 2024
289
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The Bank’s financed emissions are
calculated in accordance with the
Partnership for Carbon Accounting
Financials (PCAF). We are committed to
continually improving data quality over
time and will disclosure transparently
on any changes in methodologies or
emissions.
This process resulted in a total estimate
for Scope 3 Financed Emissions for Asset
Finance Motor Vehicle Loans of 17,077
tCO2e for 2024.
C. Targets used to manage climate-
related and environmental risks
and opportunities and performance
against targets.
Science Based Targets (SBTs)
PTSB deepened our commitment to
long-term sustainability and committed
to new climate action goals by signing
Phase 2 of Business in the Community
Ireland’s Low Carbon Pledge. The
refreshed Pledge focuses on setting
carbon emissions reduction targets based
on science and includes measuring and
reducing our carbon footprint in line
with the Paris Agreement and the latest
Intergovernmental Panel on Climate
Change (IPCC) findings.
The Science Based Target Initiative
(SBTi) provide a pathway for companies
to reduce greenhouse gas emissions,
aiming to mitigate the severe impacts of
climate change while ensuring sustainable
business growth. Targets are deemed
'science-based' when they align with
the latest climate science necessary to
limit global warming to 1.5°C above pre-
industrial levels, as outlined in the Paris
Agreement.
Following a significant programme of
work, during 2024 the Bank worked
to develop our SBTs in line with the
SBTi’s Version 2 Guidance for Financial
institutions. The work included the
development of a corresponding
Carbon Reduction Plan to support us
in achieving our Targets once set. The
Targets and Plan will be submitted to the
SBTi during Q1 2025 for validation. We
will communicate our Targets once the
validation process reaches completion.
Remuneration
At present, the Bank does not have in
place a Variable Pay Scheme (outside of
commission-based scheme in place in our
Retail Banking Network), and therefore
does not currently have a mechanism to
directly link Executive pay to sustainability
outcomes.
Under the leadership of the Chief
Sustainability and Corporate Affairs
Officer, a Head of Sustainability and
supporting team are in place to manage
and deliver the Bank’s Sustainability
Strategy. Similarly, under the leadership
of the Chief Risk Officer, an Enterprise
Risk Management Team and a Climate
Risk Manager are in place to manage and
deliver all CR&E risk programming.
Specific objectives aligned to the
Bank’s overall Sustainability Strategy
are included within team member
objectives, depending on their role within
the function. Delivery of objectives is
assessed through a formal performance
review process that occurs at regular
intervals throughout the year. Delivering
on strategy, as well as the overall
performance in the role, impacts the level
of monetary base pay increase achieved.
The Bank is at an advanced stage of
design of an enterprise-wide Variable
Pay Scheme. This Scheme will include
the delivery of sustainability factors as a
key metric in determining the appropriate
reward on a collective and individual
basis, Further information on the structure
of the Scheme will be included in future
TCFD Reports as the detail becomes
available.
Task Force on Climate-related Financial Disclosures
(continued)
PTSB Group Holdings plc - Annual Report 2024
290
Financial
Statements
Consolidated Financial Statements
Independent Auditor’s Report
292
Consolidated Financial Statements
300
Notes to the Consolidated Financial Statements
306
Company Financial Statements
Company Financial Statements
402
Notes to the Company Financial Statements
406
PTSB Group Holdings plc - Annual Report 2024
291
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Report on the audit of the
financial statements
Opinion
We have audited the financial
statements of Permanent TSB Group
Holdings plc (‘the Company’ or ‘PTSB’)
and its consolidated undertakings
(‘the Group’) for the year ended 31
December 2024 set out on pages 300
to 408, contained within the reporting
package 635400DTNHVYGZODKQ93-
2024-12-31-0-en.zip, which comprise
the consolidated income statement,
consolidated statement of comprehensive
income, consolidated statement of
financial position, consolidated statement
of changes in equity, consolidated
statement of cash flows, company
statement of financial position, company
statement of changes in equity, company
statement of cash flows and related
notes, including the Group’s material
accounting policies set out in note 1
and the Company’s material accounting
policies set out in Note A on page 406.
Certain required disclosures have been
presented elsewhere in the Annual Report,
rather than in the notes to the financial
statements. These are incorporated in the
financial statements by cross-reference
and are identified as audited.
The financial reporting framework that
has been applied in their preparation
is Irish Law, including the Commission
Delegated Regulation 2019/815 regarding
the single electronic reporting format
(ESEF) and International Financial
Reporting Standards (IFRS) as adopted by
the European Union and, as regards the
Company financial statements, as applied
in accordance with the provisions of the
Companies Act 2014.
In our opinion:
• the financial statements give a true
and fair view of the assets, liabilities
and financial position of the Group and
Company as at 31 December 2024 and
of the Group’s profit for the year then
ended;
Independent Auditor’s Report to the Members of
Permanent TSB Group Holdings plc
• the Group financial statements have
been properly prepared in accordance
with IFRS as adopted by the European
Union;
• the Company financial statements have
been properly prepared in accordance
with IFRS as adopted by the European
Union, as applied in accordance with
the provisions of the Companies Act
2014; and
• the Group and Company financial
statements 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.
Basis for opinion
We conducted our audit in accordance
with International Standards on Auditing
(Ireland) (ISAs (Ireland)) and applicable
law. Our responsibilities under those
standards are further described in the
Auditor’s Responsibilities section of our
report. We believe that the audit evidence
we have obtained is a sufficient and
appropriate basis for our opinion. Our
audit opinion is consistent with our report
to the Board Audit Committee (‘BAC’).
We were appointed as auditor by the
Board of Directors on 19 May 2023.
The period of total uninterrupted
engagement is the two years ended 31
December 2024. We have fulfilled our
ethical responsibilities under, and we
remained independent of the Group in
accordance with, ethical requirements
applicable in Ireland, including the Ethical
Standard issued by the Irish Auditing and
Accounting Supervisory Authority (IAASA)
as applied to public interest entities. No
non-audit services prohibited by that
standard were provided.
Conclusions relating to going concern
In auditing the financial statements, we
have concluded that the director’s use of
the going concern basis of accounting in
the preparation of the financial statements
is appropriate. Our evaluation of the
director’s assessment of the Group’s and
Company’s ability to continue to adopt
the going concern basis of accounting
included:
• Evaluating management’s assessment
of the Group’s and the Company’s ability
to continue to adopt the going concern
basis of accounting. In our evaluation
of management’s conclusions, we
considered the inherent risks to the
Group’s and Company’s business model
and analysed how those risks might
affect the Group’s and Company’s
financial resources or ability to continue
operations over the going concern
period. The risks that we considered
most likely to adversely affect the
Group and Company’s available financial
resources over this period were:
- the availability of funding and liquidity
in the event of a market-wide stress
scenario; and
- the impact on regulatory capital
requirements in the event of an
economic slowdown or recession.
• We also considered whether these risks
could plausibly affect the availability
of financial resources in the going
concern period by comparing severe,
but plausible, downside scenarios that
could arise from these risks individually
and collectively against the level of
available financial resources indicated
by the Group’s financial forecasts.
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
or the Company’s ability to continue as
a going concern for a period of at least
twelve months from the date when the
financial statements are authorised for
issue.
Our responsibilities and the
responsibilities of the directors with
respect to going concern are described in
the relevant sections of this report.
In relation to the Group and the
Company’s reporting on how they have
applied the UK Corporate Governance
Code and the Irish Corporate Governance
Annex, 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.
KPMG, an Irish partnership and a member firm of the KPMG global organisation of independent member firms affiliated with
KPMG International Limited, a private English company limited by guarantee.
PTSB Group Holdings plc - Annual Report 2024
292
Detecting irregularities including
fraud
We identified the areas of laws and
regulations that could reasonably be
expected to have a material effect on the
financial statements and risks of material
misstatement due to fraud, using our
understanding of the Group’s industry,
regulatory environment and other external
factors and inquiry with the directors. In
addition, our risk assessment procedures
included:
• Inquiring with the directors and
management as to the Group’s policies
and procedures regarding compliance
with laws and regulations, identifying,
evaluating and accounting for litigation
and claims, as well as whether they
have knowledge of non-compliance or
instances of litigation or claims.
• Inquiring of directors and Group Internal
Audit (“GIA”) and inspecting policy
documentation as to the Group’s high-
level policies and procedures to prevent
and detect fraud, including the Group’s
channel for “whistleblowing”, as well
as whether the directors and GIA have
knowledge of any actual, suspected or
alleged fraud.
• Inquiring of directors and GIA regarding
their assessment of the risk that the
financial statements may be materially
misstated due to irregularities, including
fraud.
• Inspecting the Group’s regulatory and
legal correspondence.
• Reading Board and Board Audit
Committee minutes and where relevant,
sub-Committee minutes.
• Considering remuneration incentive
schemes and performance targets for
management and executive directors.
• Performing planning analytical
procedures to identify any usual or
unexpected relationships.
We discussed identified laws and
regulations, fraud risk factors and the
need to remain alert among the audit
team.
Firstly, the Group is subject to laws
and regulations that directly affect the
financial statements including companies
and financial reporting legislation. We
assessed the extent of compliance with
these laws and regulations as part of
our procedures on the related financial
statement items, including assessing
the financial statement disclosures and
agreeing said disclosures to supporting
documentation when necessary.
Secondly, the Group is subject to many
other laws and regulations where the
consequences of non-compliance could
have a material effect on amounts or
disclosures in the financial statements, for
instance through the imposition of fines
or litigation. We identified the following
areas as those most likely to have such an
effect: regulatory capital and liquidity and
certain aspects of company legislation
recognising the financial and regulated
nature of the Group’s activities.
Auditing standards limit the required audit
procedures to identify non-compliance
with these non-direct laws and regulations
to inquiry of the directors and other
management and inspection of regulatory
and legal correspondence, if any. These
limited procedures did not identify actual
or suspected non-compliance.
We assessed events or conditions that
could indicate an incentive or pressure to
commit fraud or provide an opportunity
to commit fraud. As required by auditing
standards, we performed procedures
to address the risk of management
override of controls. On this audit we do
not believe there is a fraud risk related
to revenue recognition. We identified a
fraud risk in respect of model adjustments
involving management judgement relating
to the Group’s impairment loss allowances
on loans and advances to customers.
Further detail in respect of model
adjustments involving management
judgement relating to the Group’s
impairment loss allowance is set out in the
key audit matter disclosures in this report.
In response to the fraud risks, we also
performed procedures including:
• Based on risk criteria, identifying journal
entries and other adjustments to test
and comparing the identified entries to
supporting documentation;
• Assessing significant accounting
estimates for bias; and
• Assessing the disclosures in the
financial statements.
Owing to the inherent limitations of an
audit, there is an unavoidable risk that
we may not have detected some material
misstatements in the financial statements,
even though we have properly planned
and performed our audit in accordance
with auditing standards. For example, the
further removed non-compliance with
laws and regulations (irregularities) is from
the events and transactions reflected in
the financial statements, the less likely
the inherently limited procedures required
by auditing standards would identify such
irregularities.
In addition, as with any audit, there
remains a higher risk of non-detection
of irregularities, as these may involve
collusion, forgery, intentional omissions,
misrepresentations, or the override of
internal controls. We are not responsible
for preventing non-compliance and cannot
be expected to detect non-compliance
with all laws and regulations.
Key audit matters: our assessment
of risks of material misstatement
Key audit matters are those matters
that, in our professional judgement, were
of most significance in the audit of the
financial statements and include the most
significant assessed risks of material
misstatement (whether or not due to
fraud) identified by us, including those
which had the greatest effect on: the
overall audit strategy; the allocation of
resources in the audit; and directing the
efforts of the engagement team. These
matters were addressed in the context of
our audit of the financial statements as a
whole, and in forming our opinion thereon,
and we do not provide a separate opinion
on these matters.
In arriving at our audit opinion above, the
key audit matters, in decreasing order of
audit significance, were as follows:
PTSB Group Holdings plc - Annual Report 2024
293
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Group key audit matters
Impairment allowances on loans and advances to customers at amortised cost, including off- balance sheet elements (€392m (2023:
€570m))
Refer to pages 314 to 316 (accounting policy) and pages 348 to 352 (financial disclosures)
The key audit matter
How the matter was addressed in our audit
The calculation of expected credit losses
(“ECLs”) requires a high degree of judgement
to reflect recent developments in credit
quality, arrears experience and/or emerging
macroeconomic risks.
The key areas where we identified significant
management judgement and therefore increased
levels of audit focus in the Group’s estimation of
ECLs include but are not limited to:
1. Impairment loss allowance under IFRS 9 -
accuracy of modelled ECL estimate:
The calculation of expected credit losses uses
complex and inherently judgemental modelling
techniques. ECLs may be inappropriate if certain
models or underlying assumptions do not
accurately predict defaults or recoveries over
time, become out of line with wider industry
experience, or fail to reflect the credit risk of
financial assets.
As a result of these factors, we have identified a
significant risk of error arising from complexity,
estimation uncertainty in certain models and
underlying assumptions. Furthermore, these
models are one of the key drivers of the
complexity and estimation uncertainty in the
ECL estimate and resulted in an enhanced audit
effort.
1. Impairment loss allowance under IFRS 9 - accuracy of modelled ECL estimate:
We performed end-to-end process walkthroughs to identify the key systems,
applications and key controls used in the impairment loss allowance modelling
processes.
In conjunction with our credit modelling specialists, we tested the design,
implementation and operating effectiveness of key controls, including controls
over model validation, model monitoring and controls over significant model
inputs and outputs.
In conjunction with our credit modelling specialists, we challenged the model
development, validation and impairment teams through inquiry and inspection
of the Company’s policies and standards of these functions, to assess the
appropriateness of the models used by the Company.
We tested the completeness and accuracy of identified critical data elements
used within the ECL models.
In conjunction with our credit modelling specialists, we independently re-
performed testing over key aspects of the models underlying the calculation of
ECLs, including:
• Re-performance of ECL execution for a selection of ECL models using PTSB’s
statistical analysis system (SAS);
• Independent rebuild and replication testing of the IFRS 9 secured PD model,
and
• Inspected model validation and model monitoring reports to assess whether
the findings have been appropriately considered, addressed by management
and included in the model adjustments involving management judgement as
relevant.
2. Impairment loss allowance under IFRS 9 -
model adjustments involving management
judgement:
Model adjustments involving management
judgement (“Model adjustments”) are raised
by management to address known impairment
model limitations or emerging trends.
We identified a significant risk of error and
fraud associated with the valuation of those
model adjustments with the greatest degree of
management judgement. Model adjustments
represent approximately 35% of the ECL. These
adjustments are inherently uncertain and
significant management judgement is involved
in estimating certain model adjustments and
management overlays.
2. Impairment loss allowance under IFRS 9 - model adjustments involving
management judgement:
We performed end-to-end process walkthroughs and tested the design,
implementation and operating effectiveness of the key controls over the
identification, calculation, review and authorisation of model adjustments.
In conjunction with our credit modelling specialists, we evaluated the conceptual
soundness of certain model adjustments by critically assessing management’s
methodology, including the limitation and/or risk that those model adjustments
are seeking to address, and the model adjustments‘ compliance with the
requirements of IFRS 9.
We inspected the model adjustments calculation methodology and tested
the completeness and accuracy of key relevant data inputs into the model
adjustment calculation.
We tested the completeness and accuracy of the model adjustments having
regard for the risk profile of the loan books, as well as known model limitations,
and by challenging management on their significant assumptions relating
to the credit risk impact of prevailing macroeconomic uncertainty such as
unemployment and inflation.
We challenged the overall reasonableness of the model adjustments by
comparing the model adjustments recognised by management to the model
limitations and/or data limitations that we consider to exist in the portfolio.
We performed benchmarking analysis with peer banks over ECL coverage levels
and we assessed whether any model adjustments identified for testing are
indicative of fraud, management bias or other deficiencies.
Independent Auditor’s Report to the Members
of Permanent TSB Group Holdings plc
(continued)
PTSB Group Holdings plc - Annual Report 2024
294
The key audit matter
How the matter was addressed in our audit
3. Impairment loss allowance under IFRS 9 -
economic scenarios:
Economic scenarios have a direct impact on the
loan staging classification and the resultant ECL.
Significant management judgement is applied
to the determination of the economic scenarios
and the weightings applied to them.
We have identified a significant risk of error
with respect to management judgement relating
to the selection of scenarios, the associated
scenario probabilities and the material economic
variables which drive the scenarios and the
related weightings.
For the reasons outlined above the engagement
team determine this matter to be a key audit
matter.
3. Impairment loss allowance under IFRS 9 - economic scenarios:
We performed end-to-end process walkthroughs and tested the design,
implementation and operating effectiveness of the key controls related to the
estimation of macroeconomic forecasts used in measuring ECL including the
economic scenarios and probability weightings applied to them.
In conjunction with our economics specialist, we challenged management and
management‘s specialists and inspected related documentation to assess
whether the basis for significant management assumptions and judgements are
reasonable and consistent with independent consensus forecasts.
In conjunction with our economics specialist, we challenged and assessed
the plausibility of the significant assumptions underpinning PTSB’s economic
scenarios which have been identified as GDP, unemployment, House Price Index
(‘HPI‘), Consumer Price Index (‘CPI’) and ECB rates by comparing to independent
and observable economic forecasts, leveraging a number of external data
points.
We involved our economic specialist to assist in assessing the appropriateness
of the Company’s methodology for determining the economic scenarios used
and the probability weightings applied to them.
We challenged whether management’s forward- looking information
incorporated within the Group’s upside and downside scenarios were
reasonable, having regard to all available information at year- end.
We assessed whether the disclosures appropriately disclose and address the
uncertainty which exists when determining the ECL. In addition, we assessed
whether the disclosure of the significant judgements and assumptions was
sufficiently clear.
Our results:
We found the significant judgements used by management in determining the
impairment loss allowance and current year release, including the accuracy
of modelled ECL estimates, application of model adjustments and economic
scenarios to be reasonable.
PTSB Group Holdings plc - Annual Report 2024
295
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Company key audit matter
Impairment evaluation of the investment by PTSB Company-only in PTSB plc (€2.08bn (2023: €2.35bn))
Refer to page 332 (accounting policy) and page 407 (financial disclosures)
The key audit matter
How the matter was addressed in our audit
The PTSB Company-only Balance Sheet includes a €2.08
billion investment in PTSB plc at 31 December 2024.
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).
The recoverable amount at 31 December 2024 is based on
the VIU of the subsidiary investment which exceeds market
capitalisation. Given the inputs used in arriving at the VIU,
there is a degree of judgement involved in estimating the value
of the underlying business at 31 December 2024.
As a result of the subjectivity involved in the VIU estimation
and its significance and magnitude to the Company, the
engagement team consider this to be a significant risk due to
error as well as a key audit matter.
Our audit procedures included performing an end- to-end
process walkthrough over the impairment assessment carried
out by management over the carrying value of the investment.
We assessed the design and implementation of controls of
management’s annual impairment review over the Investment
in subsidiary;
We challenged management’s impairment assessment
and supporting calculations relating to the Investment in
subsidiary;
We independently recalculated the fair value less cost of
disposal of the Investment in subsidiary;
We challenged the appropriateness of the discounted cash
flow valuation method applied, reasonability of forecasted
free cash flows and other key relevant data inputs used and
appropriateness of discount rate applied which forms part of
management’s calculations;
We assessed the relevant macroeconomic assumptions
underlying the relevant forecasts in the context of economic
consensus and for alignment with Group’s Medium Term Plan
(‘MTP’) and other accounting estimates used by the Group;
We challenged the significant assumptions underpinning
the MTP forecasts used in the VIU calculation for
reasonableness by benchmarking to observable market data,
actual performance of the Company and via corroborating
discussions with management;
We challenged management’s use of selected discount
rate, growth rate, free-cash flows and data inputs with the
assistance of our Corporate Finance Specialists;
We performed a retrospective review of PTSB plc’s FY2024
results compared to the prior year VIU forecasts;
We assessed the adequacy of the financial statement
disclosures in respect of the investment in the Company-only
financial statements.
Our results:
Based on procedures we performed, we considered the
methods and assumptions relating to the impairment of
investment in PTSB plc to be reasonable. The final impairment
of €263m has been recorded in the Company-only financial
statements.
Independent Auditor’s Report to the Members
of Permanent TSB Group Holdings plc
(continued)
PTSB Group Holdings plc - Annual Report 2024
296
Our application of materiality and an
overview of the scope of our audit
Materiality for the Group financial
statements and Company financial
statements as a whole was set at €20m
(2023: €12m), determined with reference
to benchmark of net assets (of which it
represents 0.8% (2023: 0.5%)).
We consider net assets to be the most
appropriate benchmark given the volatility
in profit or loss arising over recent years
driven by certain exceptional activities
and recent instability in the economic
environment. Moreover, we believe that
net assets, rather than profitability,
provides us with a more appropriate
and consistent year-on-year basis for
determining materiality. In applying our
judgement in determining materiality, we
considered a number of factors which
had the most significant impact were:
the ownership structure of the Group
and Company, Debt arrangements, our
understanding of the Group and Company
and its environment; and earnings
sensitivities.
Performance materiality for the Group
financial statements and Company
financial statements as a whole was set
at €15m (2023: €9m), determined with
reference to benchmark of net assets
(of which it represents 75% of materiality
(2023: 75%)). We use performance
materiality to reduce to an appropriately
low level the probability that the
aggregate of uncorrected and undetected
misstatements exceeds overall materiality.
In applying our judgement in determining
performance materiality, we considered a
number of factors, including the number
and value of misstatements detected and
the number and severity of deficiencies
in control activities identified in the prior
year financial statements audit.
We reported to the Board Audit
Committee any corrected or uncorrected
identified misstatements exceeding
€1m (2023: €600k), in addition to other
identified misstatements that warranted
reporting on qualitative grounds.
We applied materiality in planning and
performing the audit to assist us in the
following:
• Determining the overall audit strategy,
including identifying the significant risks
and procedures to be performed.
• Evaluating the effect of identified
misstatements on the audit and in
forming our audit opinion.
Our audit was undertaken to the
materiality and performance materiality
level specified above and was all
performed by a single engagement team
in Dublin.
Other information
The directors are responsible for the
preparation of the other information
presented in the Annual Report together
with the financial statements. The other
information comprises the information
included in the directors' report and
the non-financial statement included
on the Company's website at www.
permanenttsb.ie and the Strategic Report
set out on pages 2 to 32, the unaudited
sections of the Risk Management Report
set out on pages 33 to 66, the Directors'
Report set out on pages 68 to 73, the
Corporate Governance Statement set out
on pages 74 to 124 and the parts of 'Other
Information' on pages 410 to 421 labelled
'unaudited'.
The financial statements and our auditor’s
report thereon do not comprise part of
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
as explicitly stated below, any form of
assurance conclusion thereon.
Our responsibility is to read the other
information and, in doing so, consider
whether, based on our financial
statements audit work, the information
therein is materially misstated or
inconsistent with the financial statements
or our audit knowledge. Based solely on
that work we have not identified material
misstatements in the other information.
Based solely on our work on the other
information undertaken during the course
of the audit we report that, in those parts
of the directors’ report specified for our
consideration, which does not include
the information required by the European
Union (Disclosure of Non-Financial and
Diversity Information by certain large
undertakings and groups) Regulations
2017:
• we have not identified material
misstatements in the directors’ report;
• in our opinion, the information given in
the directors’ report is consistent with
the financial statements; and
• in our opinion, those parts of the
directors’ report specified for our
review, which does not include
sustainability reporting when required
by Part 28 of the Companies Act 2014,
have been prepared in accordance with
the Companies Act 2014.
PTSB Group Holdings plc - Annual Report 2024
297
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Corporate governance statement
We have reviewed the directors’ statement
in relation to going concern, longer-
term viability, 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
specified for our review by the Listing
Rules of Euronext Dublin and the UK
Listing Authority.
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:
• Directors’ statement with regards the
appropriateness of adopting the going
concern basis of accounting and any
material uncertainties identified set out
on page 68;
• Directors’ explanation as to their
assessment of the Group’s prospects,
the period this assessment covers and
why the period is appropriate set out on
page 68;
• Director’s statement on whether it has a
reasonable expectation that the Group
will be able to continue in operation and
meets its liabilities set out on page 68;
• Directors’ statement on fair, balanced
and understandable and the information
necessary for shareholders to assess
the Group’s position and performance,
business model and strategy set out on
page 130;
• Board’s confirmation that it has carried
out a robust assessment of the
emerging and principal risks and the
disclosures in the annual report that
describe the principal risks and the
procedures in place to identify emerging
risks and explain how they are being
managed or mitigated set out on page
68;
Independent Auditor’s Report to the Members
of Permanent TSB Group Holdings plc
(continued)
• Section of the annual report that
describes the review of effectiveness
of risk management and internal control
systems set out on pages 97 and 98;
and;
• Section describing the work of the
Board Audit Committee set out on page
105.
The Listing Rules of Euronext Dublin also
requires us to review certain elements of
disclosures in the report to shareholders
by the Board of Directors’ remuneration
committee.
We have nothing to report in this regard.
In addition as required by the Companies
Act 2014, we report, in relation to
information given in the Corporate
Governance Statement on pages 74 to
124, that:
• based on the work undertaken for our
audit, in our opinion, the description of
the main features of internal control and
risk management systems in relation
to the financial reporting process, and
information relating to voting rights
and other matters required by the
European Communities (Takeover Bids
(Directive 2004/EC) Regulations 2006
and specified for our consideration, is
consistent with the financial statements
and has been prepared in accordance
with the Act;
• based on our knowledge and
understanding of the Company and its
environment obtained in the course
of our audit, we have not identified
any material misstatements in that
information; and
• the Corporate Governance Statement
contains the information required by the
European Union (Disclosure of Non-
Financial and Diversity Information by
certain large undertakings and groups)
Regulations 2017.
We also report that, based on work
undertaken for our audit, the information
required by the Act is contained in the
Corporate Governance Statement.
Our opinions on other matters
prescribed by the Companies Act 2014
are unmodified
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 financial statements to be readily
and properly audited and the financial
statements are in agreement with the
accounting records.
We have nothing to report on other
matters on which we are required to
report by exception
The Companies Act 2014 requires us to
report to you if, in our opinion:
• the disclosures of directors’
remuneration and transactions required
by Sections 305 to 312 of the Act are
not made;
• the Company has not provided the
information required by Section 1110N
in relation to its remuneration report for
the financial year 31 December 2023;
• the Company has not provided the
information required by section 5(2) to
(7) of the European Union (Disclosure of
Non-Financial and Diversity Information
by certain large undertakings and
groups) Regulations 2017 for the year
ended 31 December 2023 as required
by the European Union (Disclosure of
Non-Financial and Diversity Information
by certain large undertakings and
groups) (amendment) Regulations 2018.
We have nothing to report in this regard.
PTSB Group Holdings plc - Annual Report 2024
298
Respective responsibilities and
restrictions on use
Responsibilities of directors for the
financial statements
As explained more fully in the directors’
responsibilities statement set out on page
130, the directors are responsible for: the
preparation of the financial statements
including being satisfied that they give a
true and fair view; such internal control
as they determine is necessary to enable
the preparation of financial statements
that are free from material misstatement,
whether due to fraud or error; assessing
the Group and Company’s ability to
continue as a going concern, disclosing,
as applicable, matters related to going
concern; and using the going concern
basis of accounting unless they either
intend to liquidate the Group or the
Company or to cease operations, or have
no realistic alternative but to do so.
Auditor’s responsibilities for the audit of
the financial statements
Our objectives are to obtain reasonable
assurance about whether the financial
statements as a whole are free from
material misstatement, whether due to
fraud or error, and to issue an auditor’s
report that includes our opinion.
Reasonable assurance is a high level
of assurance, but is not a guarantee
that an audit conducted in accordance
with ISAs (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.
A fuller description of our responsibilities
is provided on IAASA’s website at https://
iaasa.ie/publications/description-of-the-
auditors-responsibilities-for-the-audit-of-
the- financial-statements/.
The purpose of our audit work and to
whom we owe our responsibilities
Our report is made solely to the
Company’s members, as a body, in
accordance with Section 391 of the
Companies Act 2014. Our audit work has
been undertaken so that we might state
to the Company’s members those matters
we are required to state to them in an
auditor’s report and for no other purpose.
To the fullest extent permitted by law, we
do not accept or assume responsibility
to anyone other than the Company and
the Company’s members, as a body, for
our audit work, for this report, or for the
opinions we have formed.
Frank Gannon
for and on behalf of KPMG
Chartered Accountants, Statutory Audit
Firm
1 Harbourmaster Place
IFSC
Dublin 1
D01 F6F5
3 March 2025
PTSB Group Holdings plc - Annual Report 2024
299
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Consolidated Income Statement
For the year ended 31 December 2024
Year ended
Year ended
Note
31 December
2024
31 December
2023
€m
€m
Interest income calculated using the effective interest rate method
4
870
766
Other interest income
4
29
12
Interest income
899
778
Interest expense
4
(287)
(158)
Net interest income
612
620
Fee and commission income
5
98
86
Fee and commission expense
5
(43)
(44)
Net fee and commission income
55
42
Net trading income
6
2
3
Net other operating income
3
3
Total operating income
672
668
Administrative, staff and other expenses (excluding exceptional items)
7
(419)
(378)
Bank levy and other regulatory charges
8
(33)
(60)
Depreciation of property and equipment
23
(29)
(27)
Amortisation of intangible assets
24
(62)
(40)
Exceptional items
Restructuring and other costs
9
(2)
(2)
Costs incurred in relation to the Ulster Bank transaction
9
-
(31)
Total operating expenses
(545)
(538)
Operating profit before credit impairment and taxation
127
130
Credit Impairment
Loans and advances to customers
21
30
(56)
Exceptional impairment arising from deleveraging of loans
9
2
5
Total credit impairment write-back/(charge)
32
(51)
Operating profit before taxation
159
79
Taxation
10
3
(11)
Profit for the year
162
68
Attributable to:
Equity holders of the parent
119
25
Other equity holders*
43
43
*Profits attributable to Other equity holders reflects the coupons paid on the Group’s AT1 instruments in the calendar year.
Earnings per ordinary share
€ Cent
€ Cent
Basic earnings per share of €0.5 ordinary share
11
21.7
4.5
Diluted earnings per share of €0.5 ordinary share
11
21.7
4.5
300
PTSB Group Holdings plc - Annual Report 2024
Consolidated Statement of Comprehensive Income
For the year ended 31 December 2024
Year ended
Year ended
Note
31 December
2024
31 December
2023
€m
€m
Profit for the year
162
68
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
18
4
5
Tax relating to fair value of equity instruments
10
(1)
(2)
Revaluation of property
23
(11)
(12)
Tax relating to revaluation of property
10
4
5
Other comprehensive (expense), net of tax
(4)
(4)
Total comprehensive income for the year, net of tax
158
64
Attributable to:
Equity holders of the parent
115
21
Other equity holders*
43
43
* Profits attributable to Other equity holders reflects the coupons paid on the Group’s AT1 instruments in the calendar year.
PTSB Group Holdings plc - Annual Report 2024
301
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Consolidated Statement of Financial Position
As at 31 December 2024
Note
31 December
2024
31 December
2023
€m
€m
Assets
Cash at bank
12
72
71
Items in the course of collection
12
23
40
Loans and advances to banks
13
2,202
2,051
Derivative financial instruments
14
59
36
Other assets
15
7
60
Assets classified as held for sale
16
12
12
Debt securities
17
4,327
3,256
Equity securities
18
9
5
Prepayments and contract assets
19
63
80
Loans and advances to customers
20
21,423
21,427
Interest in associated undertakings
22
21
16
Property and equipment
23
183
205
Intangible assets
24
213
187
Deferred taxation
25
316
309
Current tax asset
2
-
Total assets
28,932
27,755
Liabilities
Deposits by banks
26
105
398
Customer accounts
27
24,120
22,966
Derivative financial instruments
14
-
1
Debt securities in issue
28
1,731
1,512
Other liabilities
29
129
148
Accruals
12
13
Current tax liability
-
1
Provisions
30
46
40
Subordinated liabilities
31
257
257
Total liabilities
26,400
25,336
Equity
Share capital
33
272
273
Share premium
33
804
804
Other reserves
33
(813)
(810)
Retained earnings
33
1,901
1,784
Shareholders’ equity
2,164
2,051
Other equity instruments
33
368
368
Total equity
2,532
2,419
Total liabilities and equity
28,932
27,755
On behalf of the Board:
Julie O’Neill
Chairperson
Eamonn Crowley
Chief Executive
Barry D’Arcy
Chief Financial Officer
Conor Ryan
Company Secretary
302
PTSB Group Holdings plc - Annual Report 2024
Consolidated Statement of Changes in Equity
For the year ended 31 December 2024
Share capital Share premium
Revaluation
reserve*
Fair value
reserve*
Other capital
reserve*
Retained
earnings
Attributable to
equity holders
of the parent
Other equity
instrument
Total
€m
€m
€m
€m
€m
€m
€m
€m
€m
Balance at 1 January 2023
273
804
49
16
(856)
1,744
2,030
368
2,398
Profit for the year
-
-
-
-
-
25
25
43
68
Other comprehensive income, net of tax (note 34)
-
-
(7)
3
-
-
(4)
-
(4)
Total comprehensive income/(expense) for the period
-
-
(7)
3
-
25
21
43
64
Transactions with owners, recorded directly in equity:
Contributions by and distributions to owners
AT1 coupon paid (note 33)
-
-
-
-
-
-
-
(43)
(43)
Reclassification of cumulative gain (net of tax) of equity
instruments on disposal
-
-
-
(15)
-
15
-
-
-
Total contributions by and distributions to owners
-
-
-
(15)
-
15
-
(43)
(43)
Balance as at 31 December 2023
273
804
42
4
(856)
1,784
2,051
368
2,419
Balance at 1 January 2024
273
804
42
4
(856)
1,784
2,051
368
2,419
Profit for the year
-
-
-
-
-
119
119
43
162
Other comprehensive income, net of tax (note 34)
-
-
(7)
3
-
-
(4)
-
(4)
Total comprehensive income/(expense) for the period
-
-
(7)
3
-
119
115
43
158
Transactions with owners, recorded directly in equity:
Contributions by and distributions to owners
Buyback of ordinary shares
(1)
-
-
-
1
(2)
(2)
-
(2)
AT1 coupon paid (note 33)
-
-
-
-
-
-
-
(43)
(43)
Reclassification of cumulative gain (net of tax) of equity
instruments on disposal
-
-
-
-
-
-
-
-
-
Total contributions by and distributions to owners
(1)
-
-
-
1
(2)
(2)
(43)
(45)
Balance as at 31 December 2024
272
804
35
7
(855)
1,901
2,164
368
2,532
* All are included in other reserves in the statement of financial position
PTSB Group Holdings plc - Annual Report 2024
303
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Consolidated Statement of Cash Flows
For the year ended 31 December 2024
31 December
31 December
2024
2023
€m
€m
Cash flows from operating activities
Operating profit before taxation
159
79
Adjusted for non-cash items and other adjustments:
Depreciation, amortisation and impairment of property, equipment and intangibles
91
67
Impairment (write-back)/charge on:
- Loans and advances to customers
(32)
45
Other income
(1)
(2)
Other mortgage related adjustments
70
67
Other provisions
10
6
Net interest income*
221
115
Other non-cash items*
(63)
(34)
455
343
(Increase)/decrease in operating assets:
Derivative financial instruments
(13)
(15)
Other assets
67
10
Debt securities
35
57
Prepayments and contract assets
13
131
Loans and advances to customers
(26)
(371)
Increase/(decrease) in operating liabilities:
Deposits by banks (including central bank)
(316)
(251)
Customer accounts
1,010
1,135
Debt securities in issue
99
769
Derivative financial instruments
(1)
-
Other liabilities and accruals
(29)
13
Provisions
(8)
(41)
831
1,437
Net cash inflow from operating activities before tax
1,286
1,780
Tax paid
(4)
(7)
Net cash inflow from operating activities
1,282
1,773
Cash flows from investing activities
Maturities of debt securities - HTC
170
728
Purchase of debt securities - HTC
(1,212)
(827)
Purchase of property and equipment
(15)
(24)
Purchase of intangible assets
(26)
(37)
Cash transferred for business combinations
-
(41)
Forward contract derivatives
-
(1,595)
Investment in associated undertakings
(3)
(7)
Sale of Visa shares
-
30
Net cash flows from investing activities
(1,086)
(1,773)
304
PTSB Group Holdings plc - Annual Report 2024
Consolidated Statement of Cash Flows (continued)
For the year ended 31 December 2024
31 December
31 December
2024
2023
€m
€m
Cash flows from financing activities
Buyback of ordinary shares
(2)
-
Payment of lease liabilities
(7)
(7)
AT1 coupon payment
(43)
(43)
Interest paid on T2 capital notes
(8)
(8)
Interest paid on T2 hedging derivative
(1)
(1)
Net cash flows from financing activities
(61)
(59)
Increase/(decrease) in cash and cash equivalents
135
(59)
Analysis of changes in cash and cash equivalents
Cash and cash equivalents as at 1 January
2,162
2,221
Increase/(decrease) in cash and cash equivalents
135
(59)
Cash and cash equivalents at the end of the year
2,297
2,162
* For the year ended 31 December 2024 the Other non-cash items line item has been disaggregated
The net increase/(decrease) in cash and cash equivalents includes interest received of €965m (2023: €857m) and interest paid of €244m
(2023: €117m) and dividends paid of €43m (2023: €43m).
Reconciliation of liabilities arising from financing activities
Subordinated
liabilities
Lease liabilities
Tier 2 hedging
derivatives
Total
€m
€m
€m
€m
1 January 2024
257
35
(6)
286
Financing Cashflows:
Lease liability
-
(7)
-
(7)
Interest paid on Tier 2 capital notes
(8)
-
-
(8)
Interest paid on Tier 2 hedging derivatives
-
-
(1)
(1)
Non-cash movements:
Additions to lease liabilities
-
7
-
7
Interest accrued on Tier 2 capital notes
8
-
-
8
Interest accrued on Tier 2 hedging instrument
-
-
1
1
31 December 2024
257
35
(6)
286
1 January 2023
252
38
-
290
Financing Cashflows:
Lease liability
-
(7)
-
(7)
Interest paid on Tier 2 capital notes
(8)
-
-
(8)
Interest paid on Tier 2 hedging derivatives
-
-
(1)
(1)
Non-cash movements:
Additions to lease liabilities
-
4
-
4
Interest accrued on Tier 2 capital notes
8
-
-
8
Hedge adjustment on Tier 2 capital notes
5
-
(5)
-
31 December 2023
257
35
(6)
286
305
PTSB Group Holdings plc - Annual Report 2024
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements
Notes
Page
1. Corporate information, basis of preparation and material accounting policies
307
2. Critical accounting estimates and judgements
326
3. Operating segments
333
4. Net interest income
334
5. Net fee and commission income
334
6. Net trading income
335
7. Administrative, staff and other expenses (excluding exceptional items)
335
8. Bank levy and other regulatory charges
336
9. Exceptional items
336
10. Taxation
337
11. Earnings per ordinary share
338
12. Cash and cash equivalents
339
13. Loans and advances to banks
339
14. Derivative financial instruments
340
15. Other assets
342
16. Assets classified as held for sale
343
17. Debt securities
343
18. Equity securities
344
19. Prepayments and contract assets
344
20. Loans and advances to customers
345
21. Impairment provisions
348
22. Interest in associated undertakings
353
23. Property and equipment
354
24. Intangible assets
356
25. Deferred taxation
357
26. Deposits by banks
358
27. Customer accounts
359
28. Debt securities in issue
359
29. Other liabilities
360
30. Provisions
360
31. Subordinated liabilities
361
32. Leases
362
33. Share capital, reserves and other equity instruments
364
34. Analysis of other comprehensive income
366
35. Measurement basis and fair values of financial instruments
367
36. Financial risk management
372
37. Capital management
391
38. Current/non-current assets and liabilities
392
39. Transfer of financial assets
392
40. Offsetting financial assets and financial liabilities
394
41. Commitments and contingencies
395
42. Related parties
396
43. Sale of loans and advances to customers
399
44. Principal subsidiary undertakings and interest in subsidiaries and structured entities
400
45. Reporting currency and exchange rates
401
46. Events after the reporting period
401
306
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material 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 2024.
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 2024 were approved by the Board and authorised for issue by the
Directors on 3 March 2025.
The material accounting policies applied in the preparation of the financial statements for the year ended 31 December 2024 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 (SOCI), the consolidated statement of financial position (SOFP), the consolidated statement of changes in equity (SOCE), the
consolidated statement of cash flows (SOCF), the Company SOFP, the Company SOCE, the Company SOCF and the notes to the
consolidated and the Company financial statements, which have been prepared in accordance with IFRS and interpretations issued by the
IFRS 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 44 for further information.
The Company’s loss after tax for the year ended 31 December 2024 was €216m (31 December 2023: profit €45m). For further information,
see the Company financial statements on pages 402 to 408.
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 such as 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 and individual 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 and individual financial statements.
PTSB Group Holdings plc - Annual Report 2024
307
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material 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 21);
• Deferred taxation (notes 10 and 25);
• Fair value of financial instruments (note 35);
• Impairment review of subsidiary undertaking (note 44).
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 in their current status, and over 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 2024. 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 2024 is a period of twelve months from the date of
approval of these financial statements (3 March 2026).
In making this assessment, the Directors and Management have considered the Group’s and Company’s 2025-2029 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 grew at a steady pace in 2024 and is expected to continue to grow into 2025. This is supported by a strong labour market,
increased Government investment and increasing real wages. Consumer price inflation eased in the second half of 2024 as the ECB began to
cut interest rates in June 2024 when inflation began to fall, and it is expected to continue easing in the medium term.
Further to this, the Group and Company continues to be materially reliant on Government and EU policy, and impacted by geopolitical events;
such as proposed policy changes arising from the new US administration which could impact trade, FDI and public finances, uncertainty
around the future trading relationship between Ireland/Eurozone and the UK and US, ongoing global conflicts, 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 through continued
management of its financial position through capital management.
Funding & Liquidity
The Group and Company continued to have sufficient liquidity throughout 2024 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.
The Group and Company continues to hold a significant liquidity buffer at 31 December 2024 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 to continue on a going concern basis over
the period of assessment.
308
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
Profitability and Capital Adequacy
The Group and Company made a profit for the year ended 31 December 2024. Directors and Management have reviewed the Medium Term
Plan and based on this, the near-term macro-economic conditions of the country, 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, and a deterioration in economic
conditions as might arise from an uncertainty from the Group’s and Company’s principal risks. 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 2023 has been prepared on a consistent basis with 2024.
1.5 Summary of material 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 44.
Interest in associated undertakings
Interest in associated undertakings encompass investments in entities wherein 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.
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 to make payments on behalf of the associate, in which case, 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.
PTSB Group Holdings plc - Annual Report 2024
309
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
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) and (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.
(b) Goodwill
The Group measures goodwill as the excess of (i) the 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.
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.
(iii) Foreign currencies
Foreign currency transactions are translated into the functional currency of each 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 equity investments in
respect of which an election has been made to present subsequent changes in fair value in Other Comprehensive Income (OCI) are
recognised in OCI.
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;
• Income and expenses are translated at the average exchange rates for the year; and
• All resulting exchange differences are recognised in OCI and as a separate component of equity.
(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.
310
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
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.
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;
• 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.
Other interest income presented in the consolidated income statement includes interest income on lease receivables.
(b) Fee and commission income and expense
As outlined above, fee 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. Fee 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 on derivatives that do not qualify for hedge accounting, 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).
The definition of exceptional items was refined to exclude gains and losses on material loan deleveraging post 31 December 2021. However,
releases on those transactions which occurred prior to this refinement continue to be included in exceptional items is consistent with the
treatment of the losses on deleveraging of loans in prior years.
(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.
PTSB Group Holdings plc - Annual Report 2024
311
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
(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.
(vi) Current and deferred taxation
Taxation comprises both current and deferred tax. Taxation is recognised as income or expense 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%).
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 (i) affects neither accounting nor taxable profit or loss and (ii) does not give rise to equal taxable and deductible temporary
differences.
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:
• 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.
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 of the Group currently are recorded at fair value and are classified, on initial recognition, as amortised cost designated as fair
value hedges, or elected at FVOCI. 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.
312
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
The classification requirements for debt and equity instruments are described below.
Debt instruments
Debt instruments, including loans and debt securities, are currently classified as amortised cost
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 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 have been elected to be accounted for at FVOCI).
Based on the above assessments, the Group currently classifies its debt instruments into one category as per below:
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.
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 within Loans and advances to customers and Debt securities and interest
income is recognised in net interest income.
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. The Group has classified certain equity instruments as FVOCI on initial recognition as per
above. Dividends received are recorded in the income statement.
PTSB Group Holdings plc - Annual Report 2024
313
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
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;
• lease receivables;
• loan commitments; and
• guarantees.
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 Significant increase in Credit Risk (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.
314
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
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.
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 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:
• 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:
• 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).
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.
PTSB Group Holdings plc - Annual Report 2024
315
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
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.
Credit losses on items not recognised in the statement of financial position such as undrawn lending commitments (where the loan
commitment relates to a loan already recognised as a financial asset), letters of credit and guarantees (other than financial guarantee
contracts) are reported under loans and advances to customers. Credit losses on loan commitments where there is no recognised financial
asset are reported under Provisions.
(c) Financial liabilities and equity
Financial liabilities are currently classified at amortised cost unless mandatorily required to be classified at FVTPL, for example derivatives.
Derivative liabilities are dealt with under separate accounting policies. All of the Group’s financial liabilities, other than derivative liabilities, are
classified at amortised cost.
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 EIR 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.
Financial liabilities measured at amortised cost
Financial liabilities include deposits by banks (including Central Banks), customer accounts, debt securities in issue and subordinated debt.
The related interest expense is recognised in net interest income.
Debt securities issued 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.
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 and paid 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.
316
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
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 Structured Entities (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 in issue. 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.
Financial liabilities
The Group derecognises a financial liability when its contractual obligations are discharged, cancelled, or expired. 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
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 35.
(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, the Group engages in fair value hedges which is hedging the exposure to changes in the fair value of a
recognised asset or liability in relation to interest rate risk.
PTSB Group Holdings plc - Annual Report 2024
317
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material 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 Group uses interest rate swaps to hedge its exposure to changes in the fair value of fixed-rate euro notes issued in respect of the
EURIBOR benchmark interest rate. The Group hedges interest rate risk only to the extent of the benchmark interest rate because the changes
in the fair value of a fixed-rate note issued are significantly influenced by changes in the benchmark interest rate.
Before fair value hedge accounting is applied the Group determines whether an economic relationship between the hedged item and the
hedging instrument exists. This is performed by comparing the critical terms of each of the instruments and also regression analysis to assess
whether the hedging instrument is expected to be highly effective in offsetting changes in the fair value of the hedged item i.e. that the fair
value of the hedged item and the fair value of the hedging instrument move in opposite directions and therefore offset. The Group establishes
a hedge ratio by aligning the par amount of the fixed-rate note and the notional amount of the interest rate swap designated as a hedging
instrument. The Group then performs regression analysis to ensure that the hedge relationship is highly effective as per above. This analysis is
also performed at reporting periods to ensure that the hedge relationship remains highly effective.
The main sources of ineffectiveness will include differences in maturities of the instruments and different interest basis calculations.
The effective portion of fair value gains on hedging derivatives and the gain or loss on the hedged item are recognised in net interest income.
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) 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.
As a result, IFRS 13 requires entities to consider the effects of credit risk when determining a fair value measurement.
The Group mitigates 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.
318
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
(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 Group’s accounting policy as detailed above with the lease commencement date being the
acquisition date.
As a lessee
The Group recognises a right-of-use asset (Property Plant and Equipment) and a lease liability (Other liabilities) 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 the present value of the lease payments that are not paid at the commencement date, discounted 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 fixed payments, including in-substance fixed payments.
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.
PTSB Group Holdings plc - Annual Report 2024
319
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
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 assets are held under a finance lease, the present value of the lease payments is recognised as a receivable at an amount equal to the
net investment in the lease. The difference between the gross receivable and the present value of the receivable is recognised as unearned
finance income. Lease income is included within net interest income and is recognised over the term of the lease reflecting a constant
periodic rate of return on the net investment in the lease. Finance lease receivables are recognised within Loans and Advances to Customers
and the related interest income within net interest income.
The Group applies the derecognition and impairment requirements in IFRS 9 to the net investments in the lease.
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.
(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.
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.
320
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
The estimated useful lives are as follows:
Freehold Buildings
50 years
Leasehold Buildings
50 years or term of lease if less than 50 years
Office Equipment
5 – 7 years
Computer Hardware
3 – 7 years
Motor Vehicles
3 – 5 years
Fixtures and fittings
7 – 10 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 directly
attributable 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.
(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 and 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.
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.
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.
PTSB Group Holdings plc - Annual Report 2024
321
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
(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.
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 loan commitments are recognised in Provisions except where the loan commitment relates to a loan already recognised as a
financial asset. In this case the ECL is recognised in 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 section (vii) (d) above 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.
322
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
(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 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 depending on whether the counterparty is a bank or not.
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 net interest income over the life of the agreements using the EIR.
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.
(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 sale-and-repurchase
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.
PTSB Group Holdings plc - Annual Report 2024
323
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
1. Corporate information, basis of preparation and material accounting policies (continued)
1.6 Application of new and revised IFRS
In 2024, the Group assessed the impact of new and revised pronouncement of IFRSs which took effect during the year. The changes to IFRSs
during 2024 did not have 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 2024.
The following table outlines the new pronouncements coming into effect for accounting periods on or after 1 January 2024 and did not have a
significant impact on the financial statements.
Accounting Standard
Update
Description of Change
Key impacts for PTSB
Effective Date
IAS 1 – Classification of Liabilities
as Current or Non-current
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.
This amendment has had no
material impact on current or
future reporting.
Annual periods beginning on or
after 1 January 2024.
Lease Liability in a Sale and
Leaseback (Amendments to IFRS
16)
Clarifies how to measure sales in a
sale and lease back agreement.
The aim is to ensure it meets the
requirements of IFRS15 revenue
recognition.
This amendment has had no
material impact on current or
future reporting.
Annual periods beginning on or
after 1 January 2024.
Non-current Liabilities with
Covenants (Amendments to IAS
1)
Clarifies how conditions with
which an entity must comply
within twelve months after the
reporting period affect the
classification of a liability.
This amendment has had no
material impact on current or
future reporting.
Annual periods beginning on or
after 1 January 2024.
Supplier Finance Arrangements
(Amendments to IAS 7 and IFRS
7)
Provides disclosure requirements,
and ‘signposts’ within existing
disclosure requirements, that ask
entities to provide qualitative and
quantitative information about
supplier finance arrangements.
This amendment has had no
material impact on current or
future reporting.
Annual periods beginning on or
after 1 January 2024.
1.8 Impact of other accounting standards with effective periods beginning on or after 1 January 2025.
The following table outlines the new pronouncements coming into effect for accounting periods on or after 1 January 2025 and are not
deemed to have a significant impact on the financial statements with the exception of IFRS 18 impacts detailed below.
Accounting Standard
Update
Description of Change
Key impacts for PTSB
Effective
Date
Lack of Exchangeability
(Amendments to IAS 21)
Provides guidance to specify when
a currency is exchangeable and
how to determine the exchange
rate when it is not.
This amendment is expected to
have no material impact on current
or future reporting.
Annual periods beginning on or
after 1 January 2025. Not yet
endorsed by the EU.
Amendments IFRS 9 and IFRS 7
regarding the classification and
measurement of financial
instruments
The amendments address matters
identified during the post-
implementation review of the
classification and measurement
requirements of IFRS 9 Financial
Instruments.
The potential impact on future
reporting is expected to be minor.
Further consideration will be given
to the amendment closer to the
first applicable reporting period if it
is adopted by the EU.
Annual reporting periods
beginning on or after 1 January
2026.
Not yet endorsed by the EU.
324
PTSB Group Holdings plc - Annual Report 2024
1. Corporate information, basis of preparation and material accounting policies (continued)
Accounting Standard
Update
Description of Change
Key impacts for PTSB
Effective
Date
IFRS 18 Presentation and
Disclosures in Financial
Statements
IFRS 18 includes requirements for
all entities applying IFRS for the
presentation and disclosure of
information in financial statements.
This amendment is likely to have a
material impact on future reporting
and we have begun analysing its
potential impact.
Applicable to annual reporting
periods beginning on or after 1
January 2027.
Not yet endorsed for use in the
EU.
Known impacts of IFRS 18
i) results of associates to be
shown outside operating profit
ii) cash flow statement to start
with operating profit
iii) management defined
performance measures to be
disclosed in a single note to the
financial statements.
Enhanced guidance is provided on
how to group items in the financial
statements and the impact of this
and other changes are still being
considered.
IFRS 19 Subsidiaries without
Public Accountability:
Disclosures
IFRS 19 specifies the disclosure
requirements an eligible subsidiary
is permitted to apply instead of the
disclosure requirements in other
IFRS Accounting Standards.
This amendment is expected to
have no material impact on current
or future reporting.
Applicable to annual reporting
periods beginning on or after 1
January 2027.
Not yet endorsed for use in the
EU.
Annual Improvements to IFRS
Accounting Standards — Volume
11
The pronouncement comprises
the following amendments:
IFRS 1: Hedge accounting by a
first-time adopter
IFRS 7: Gain or loss on
derecognition
IFRS 7: Disclosure of deferred
difference between fair value and
transaction price
IFRS 7: Introduction and credit risk
disclosures
IFRS 9: Lessee derecognition of
lease liabilities
IFRS 9: Transaction price
IFRS 10: Determination of a ‘de
facto agent’
IAS 7: Cost method
The potential impact on future
reporting is expected to be minor.
Further consideration will be given
to the amendment closer to the
first applicable reporting period if it
is adopted by the EU.
Applicable to annual reporting
periods beginning on or after 1
January 2026.
Not yet endorsed for use in the
EU.
PTSB Group Holdings plc - Annual Report 2024
325
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
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 rates remaining high and continued cost inflation, elevates the uncertainty associated with
judgements, estimates and assumptions made by Management. The Irish economy demonstrated resilience in the current economic climate in
2024. The results of the actions taken by the Government, EBA and CBI point toward a positive trajectory. 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.
(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.
The following concepts introduce significant judgement within impairment and have a significant impact on the level of ECL allowances.
Determination of significant increase in credit risk (SICR)
The Group’s criteria for assessing whether there has been a significant increase in credit risk can cause some volatility in the classification of
performing exposures and amount of the recognised ECL allowances in any accounting period. This is because in line with IFRS 9, Stage 1
loans require a 12-month ECL whereas a lifetime ECL is recognised for Stage 2 loans.
Criteria to determine whether a significant increase in credit risk has occurred at the reporting date are set out in section 3.1, Risk
management.
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.
In its calculation of ECL allowance, the Group considers multiple scenarios and possible outcomes together with their probability of
occurrence. Scenarios are designed to capture a range of 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, 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. The Group’s approach to economic scenario development and
application will be reviewed during the redevelopment of the Group’s IFRS 9 model suite over the course of the next 12 - 18 months.
326
PTSB Group Holdings plc - Annual Report 2024
2. Critical accounting estimates and judgements (continued)
Three scenarios are considered in the Group’s calculation of ECL allowance at the reporting date. 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. Macroeconomic
scenarios and associated weights are reviewed by the Asset and Liability Committee (“ALCo”) before approval for use by the Board Risk and
Compliance committee.
The table below compares the key macroeconomic variables and probability weightings used for the year-end ECL process to those used at
December 2023. Macroeconomic input parameters were last updated in December 2024.
The updated Base Case scenario reflects marginally higher unemployment forecasts and a worsening GDP outlook vs previous year, due to
headwinds in the global economy as a result of geopolitical pressures. The Upside and Downside scenarios are updated to present extreme ‘1-
in-20’ scenarios relative to the updated Base scenario. Given the severity of these scenarios (5th Percentile upside and 95th Percentile
downside), their combination captures the macroeconomic uncertainty arising from the current economic environment.
31 December 2024
31 December 2023
Base Case
Upside
Scenario
Downside
Scenario
Base Case
Upside
Scenario
Downside
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
Average value
over the
forecast
period
Percentile
50th
5th
95th
50th
5th
95th
Scenario Probability
Weighting
54%
23%
23%
54%
23%
23%
Irish Residential House
Prices
3%
2%
12%
-10%
2%
2%
12%
-10%
Irish Unemployment
6%
6%
4%
12%
6%
5%
4%
11%
Irish GDP
1%
2%
5%
-2%
3%
3%
6%
-2%
Consumer Price Index
2%
2%
2%
4%
3%
2%
2%
4%
ECB Base Rate
2%
2%
1%
4%
4%
3%
1%
4%
The macroeconomic scenarios used at the reporting date are described below.
Base scenario
Global inflationary forces have continued to ease through 2024, freeing all major monetary authorities to cut interest rates in the second half of
the year. A soft landing in the global economy, with unemployment and default rates remaining subdued compared to previous cycles, and a
steady recovery in growth, provided a more attractive backdrop for the global economy in 2024. However, the change in the political
leadership of the world’s largest economy, and a radically different approach to international trade agreements presents a new and significant
threat to the global macro-economic outlook.
A more benign interest rate environment and the increased number of high wage earners in the economy means that house prices are
expected to see upward pressure, albeit at a much more modest rate. Underlying driving forces, such as a) decade of under supply of
housing, b) strong population growth through inward migration and population dynamics, c) record rental values and d) exceptionally strong
construction price inflation, are expected to support property prices in the medium term.
Unemployment is expected to increase over the forecast period due to a weakened outlook in global trade. Average GDP growth over the
forecast period reflects the uptick in unemployment.
Upside scenario
The upside scenario reflects a much stronger outcome for the Irish economy than in the base scenario. While there is both historical context
and statistical backing to the key forecasts it is a positive extremity.
Consistent with the longer-term nominal house price average gain of 9.3% since 1970 and 6.4% globally during that period, the HPI forecast for
the extreme positive scenario, puts average HPI increases at 12% per annum. Average GDP growth over the forecast period is 5%, 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.
Substantially below trend CPI growth returns in the Irish economy over the forecast horizon, with inflation trends remaining highly supportive
of economic growth.
PTSB Group Holdings plc - Annual Report 2024
327
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
2. Critical accounting estimates and judgements (continued)
Downside scenario
The Downside scenario is an extreme negative 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. In this scenario, there is a
prolonged period of unemployment, averaging at 12% per annum over the forecast period. Five years of sub normal growth across the forecast
horizon 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. 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 more fragmented global supply chain and the larger scale deglobalisation impact. House price decline reflects
worsened conditions.
Scenario application
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 overlay
adjustments to modelled ECL outcomes, the ECL impairment allowance would be €95m less than reported at 31 December 2024.
Similarly, excluding overlay adjustments to modelled ECL 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 €107m less than reported at 31 December 2024. Whereas,
if the Group were to only use its Downside Scenario, the ECL impairment allowance would be €309m greater than reported at 31 December
2024.
The BAC review the adequacy of ECL allowance on a half-yearly basis. 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.
Management judgement has been incorporated into the Group’s impairment measurement process for the period and includes:
• Criteria applied to determine significant increase in credit risk;
• Management judgement in impairment model parameters; and
• Overlay adjustments to modelled ECL outcomes.
Criteria applied to determine significant increase in credit risk
The Group considers both quantitative and qualitative measures, including other reasonable and supportable information that would not
otherwise be considered, in the assessment of whether a significant increase in credit risk (SICR) has arisen. Further details on the Group’s
approach to assessing SICR are set out in section 3.1, Risk management; Loan impairment.
At December 2024, a collective risk assessment has been conducted on a cohort of customers who could be disproportionately impacted by
headwinds at the reporting date. This assessment has resulted in a management decision to classify €225 million of stage 1 residential
mortgage loans as stage 2, with a corresponding €2 million uplift to modelled expected credit loss allowances. This does not form part of
management’s judgement in impairment model parameters or overlay adjustments.
Management judgement applied to impairment model parameters
At December 2024, the residential mortgage LGD parameter utilised in the ECL calculation was updated to reflect management judgement in
respect of the future resolution profile of the non-performing loans and observed model sensitivity to intense house price growth during the
year (+€44m). Changes in individual exposure LGD does not impact staging classification. The secured LGD model is scheduled for
redevelopment in 2025.
Overlay adjustments to modelled ECL outcomes
Overlay adjustments approved for 31 December 2024 (with 2023 comparison where applicable), are set out below and categorised as follows:
• Non-performing exposures: Overlay to recognise risk of elevated loss outcomes for aged default cohorts.
• Model to be built: Application of minimum provision coverage floors where appropriate models are not yet available.
• Model Limitations: Overlay to recognise limitations associated with the Group’s current IFRS 9 models.
• Forward-Looking Outlook: ECL adjustments required due to emerging risks or headwinds not captured in modelled results.
328
PTSB Group Holdings plc - Annual Report 2024
2. Critical accounting estimates and judgements (continued)
Overlay adjustments to modelled ECL outcomes
31 December
2024
31 December
2023
€m
€m
Non-performing exposures
35
50
Model to be built
10
13
Model limitations
26
29
Forward-looking outlook
21
44
Total
92
136
Non-performing Exposures (NPE)
An overlay of €35m is in place 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. The overlay is based on the Group’s assumptions around
collateral realisation on defaulted assets in respect of coverage levels on non-performing loans based on years in default. Given the nature of
this overlay, there is no impact on the Group’s SICR assessment and assessment is determined by level of non-performing loans within loans
and advances to customers at 31 December 2024. This overlay has reduced from December 2023 due to the Glas III portfolio loan sale and
paydown during the year. The requirement for this overlay will be removed upon the implementation of a redeveloped residential mortgage
LGD model, which will consider the impact of NPE vintage on loss outcomes, scheduled for H2 2025.
Model to be Built
A €10m overlay has been applied in respect of portfolios which were acquired from Ulster Bank in 2023. This overlay incorporates minimum
provision coverage floors, based on pre-determined benchmarks. Given the nature of these acquisitions, the overlay is applied at portfolio
level which does not give rise to a staging adjustment. The development of specific impairment models for these portfolios, planned for H1
2026, is expected to remove the requirement for this overlay.
Model Limitations
Construction of the Group’s IFRS9 models was based on a single economic cycle covering a period of low and stable inflation rates.
Management is of the view that the modelled impairment allowance may not fully reflect expected credit losses for certain cohorts of
borrowers. At the reporting date, a €26m management overlay is held for this risk. The requirement for this overlay is expected to reduce
throughout 2025 and 2026 as key milestones in the IFRS 9 Provision Models Programme are met.
Forward-Looking Outlook
The bank is forward-looking in its risk identification process to ensure emerging risks are identified. It acknowledges that not all forward-
looking adjustments can be considered in IFRS9 models and as a result will require reassessment on a regular basis.
A €21m overlay to reflect the uncertainty associated with the current economic headwinds comprises of:
• €15m in respect of specific commercial sectors where management consider heighted default risk associated with emerging risks not
captured within modelled results (31 December 2023: €17m) with impacted obligations and associated overlay reported as Stage 2;
• €3m in respect of performing consumer accounts to reflect recent default and recovery experience not yet captured within modelled ECL
(31 December 2023: €10m). The ongoing requirement for this overlay will be assessed as part of the unsecured model redevelopment
scheduled for 2026; and
• €3m in respect of Stage 1 residential mortgage accounts to reflect the potential for geopolitical headwinds to further stress less seasoned
mortgage exposures.
• An overlay of €17m held at December 2023 to reflect cost of living challenges associated with the increased interest rate environment, is
no longer deemed necessary based on observed performance and current point in the interest rate cycle.
(b) Deferred taxation
At 31 December 2024, the Group had a net deferred tax asset of €316m (31 December 2023: €309m), see note 25 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.
PTSB Group Holdings plc - Annual Report 2024
329
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
2. Critical accounting estimates and judgements (continued)
The most important judgement relates to Management’s assessment of the recoverability of the deferred tax asset relating to carried forward
tax losses, being €323m at 31 December 2024. 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.
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 movements and inflationary risks;
• 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 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 non-performing assets;
- Net Interest Margin, 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 €323m of a deferred tax asset on tax losses on the statement of financial position
as at 31 December 2024.
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 2029 and assuming a level of profitability growth consistent with GDP
growth of approximately 2.5%, it will take c. 12 years for the deferred tax asset on tax losses of €323m 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, with modest GDP growth expected over the medium term. 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 is broadly in line with that at 31 December 2023 where the DTA was
expected to be utilised by 2034. Assumptions underpinning the deferred tax asset recoverability analysis are broadly in line with prior periods.
330
PTSB Group Holdings plc - Annual Report 2024
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 25,
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 stress 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 5 years (i.e. full utilisation by 2041). 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 12 years, i.e. full utilisation is expected by 2036.
(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 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 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 35.
PTSB Group Holdings plc - Annual Report 2024
331
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
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. It is noted that the market capitalization does not include a control premium. 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 before adjusting for impairment was €2,346m
and recoverable amount based on the VIU was €2,083m resulting in a €263m impairment charge for the year (31 December 2023: no
impairment charge).
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 cash flows are forecast based on the asset in its current condition, and do not take
account of planned management actions, such as the limited Voluntary Severance Scheme announced in late 2024, which would result in a
significantly higher recoverable amount were it to be included. See note 41 for further details on the Voluntary Severance Scheme.
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;
• Increase in revenue reflective of balance sheet growth;
• Operating profits based on historical experience and average margins;
• 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% (31 December 2023: 2.5%) was used.
Discount rate
The discount rate used is a post-tax weighted average cost of capital of the Group of 11.5% (31 December 2023: 11.5%) 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.
332
PTSB Group Holdings plc - Annual Report 2024
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 of €1,633m, resulting in an additional impairment charge of €450m;
• An increase in ECB interest rate of 100bps would result in a VIU in excess of the carrying value after impairment charge, resulting in no
additional impairment charge;
• An increase in operating expenses of €20m per annum, would result in a VIU of €1,878m, resulting in an additional impairment charge of
€205m;
• A decrease in operating expenses of €20m per annum, would result in a VIU in excess of the carrying value after impairment charge,
resulting in no additional impairment charge;
• A decrease of 1% in long-term growth rate would result in a VIU of €1,898m, resulting in an additional impairment charge of €184m;
• An increase of 1% in long-term growth rate would result in a VIU in excess of the carrying value after impairment charge, resulting in no
additional impairment charge;
• An increase of 1% in the discount rate would result in a VIU of €1,834m, resulting in an additional impairment charge of €249m; and
• A decrease of 1% in the discount rate would result in a VIU in excess of the carrying value after impairment charge, resulting in no additional
impairment charge.
3. Operating segments
The Group reports one operating segment which reflects the internal management reporting structure of the Group and how the Chief
Operating Decision Maker (CODM) assesses performance and allocates resources. The ExCo as the CODM 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.
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 has assessed its operating segments and continues to be satisfied that there is only one operating segment based on reporting to
the CODM, in accordance with IFRS 8.5. The requirements of IFRS 8 will continue to be assessed on an ongoing basis as the Group’s business
develops.
3.1 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 €1,002m (31 December 2023: €870m). The main products from which the
Group earns external revenue include: mortgages; consumer finance; treasury assets; and wholesale funding. The interest income from these
products is set out in the table below. Interest income from external customers split by product:
31 December
2024
31 December
2023
€m
€m
Mortgages
673
611
Consumer finance*
74
50
Treasury assets
65
36
Wholesale funding**
87
81
Total
899
778
*Consumer finance comprises income from term loans, credit cards, overdrafts and asset financing.
**Wholesale funding comprises loans and advances to other banks.
3.2 Profit for the year based on geographical location
During the year ended 31 December 2024 the Group’s profit was solely incurred in Ireland. During the year ended 31 December 2023, the
majority of the Group’s profit was incurred in Ireland. During 2023, an immaterial loss (less than €1m) was incurred outside of Ireland in the
Group’s IOM subsidiary PBI Ltd, which entered liquidation on 20 December 2023.
3.3 Assets and liabilities based on geographical location
All assets and liabilities were held in Ireland at 31 December 2024 and 31 December 2023.
PTSB Group Holdings plc - Annual Report 2024
333
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
4. Net interest income
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Interest income
Loans and advances to customers (excluding lease receivables)
718
649
Loans and advances to banks
87
81
Debt securities and other fixed-income securities
65
36
Interest income calculated using the effective interest rate method
870
766
Other interest income*
29
12
Interest income
899
778
Interest expense
Deposits from banks
(23)
(35)
Due to customers
(139)
(43)
Debt securities in issue
(114)
(71)
Loans and advances to banks
(1)
-
Subordinated liabilities
(9)
(8)
Lease liabilities
(1)
(1)
Interest expense
(287)
(158)
Net interest income
612
620
*Other interest income consists of interest income on lease receivables
Loans and advances to customers interest income includes a charge of €32m (31 December 2023: €29m) in respect of deferred acquisition
costs and €22m (31 December 2023: €24m) amortisation on the business combination related fair value adjustments. Other interest income
includes a charge of €2m (31 December 2023: €nil) in respect of deferred acquisition costs and €2m (31 December 2023: €1m) amortisation
on the business combination related fair value adjustments.
Debt securities in issue includes €12m net interest expense on derivatives that are in hedge relationships (31 December 2023: €2m) and
subordinated liabilities includes €1m net interest expense on derivatives that are in hedge relationships (31 December 2023: €nil).
5. Net fee and commission income
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Fee and commission income
Retail banking and credit card fees
86
76
Brokerage and insurance commission
11
9
Other fees and commission income
1
1
Fee and commission income
98
86
Fee and commission expense*
(43)
(44)
Net fee and commission income
55
42
* Fee and commission expenses primarily comprises retail banking and credit cards fees.
334
PTSB Group Holdings plc - Annual Report 2024
6. Net trading Income
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Held-for-trading
Foreign exchange gains
2
3
Net trading income
2
3
7. Administrative, staff and other expenses (excluding exceptional items)
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Staff costs (as detailed below)
233
201
Other general and administrative expenses
186
177
Administrative, staff and other expenses (excluding exceptional items)
419
378
Administrative, staff and other expenses (excluding exceptional items) includes costs of €3m in relation to legacy cases (31 December 2023:
€2m)
Fees paid to the Group’s auditors for services outlined below
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Statutory auditor’s remuneration (including expenses and excluding VAT)
- Audit of the individual and the Group financial statements
2.0
1.8
- Other assurance services*
0.6
0.2
- Other non-audit services**
0.2
1.4
* Other assurance services in 2024 relate to interim financial statement review, CSRD Regulations and Country by Country Reporting. In 2023, other assurance
services included ESG related costs and interim financial statement review related costs.
** Other non-audit services in 2024 include AI compliance and ID&V vendor assessment and March Euro Note Programme. In 2023, other non-audit services costs
included fees and interim fees for professional services in relation to Project Sun, DTR Claim, and costs in relation to the Lombard KYC processes.
Staff costs
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Wages and salaries (including commission payable to sales staff)
205
183
Social insurance
22
20
Pension costs (payments to defined contribution pension schemes)
21
17
Total staff costs
248
220
Staff costs capitalised
(15)
(16)
Staff costs charged to exceptional items
-
(3)
Total staff costs included in the Income Statement
233
201
Staff costs of €15m (31 December 2023: €16m), have been capitalised to Intangible assets (see note 24), 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.
PTSB Group Holdings plc - Annual Report 2024
335
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
7. Administrative, staff and other expenses (excluding exceptional items) (continued)
Staff numbers
Closing and average number of staff (including Executive Directors) employed during the year are as follows:
Closing staff numbers*
Average staff numbers
2024
2023
2024
2023
Customer facing
1,198
1,116
1,194
1,024
Non-customer facing
2,161
2,214
2,155
2,031
Total number of staff
3,359
3,330
3,349
3,055
*Closing staff numbers are calculated on a full time equivalent (FTE) basis.
8. Bank levy and other regulatory charges
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Bank levy
23
22
Other regulatory charges
10
38
Bank levy and other regulatory charges
33
60
Other regulatory charges include €4m for the Central Bank Industry Funding Levy (31 December 2023: €4m), €nil for the Deposit Guarantee
Scheme (31 December 2023: €28m), €nil related to Single Resolution Fund (31 December 2023: €4m) and €2m related to other regulatory
charges (31 December 2023: €2m).
9. Exceptional items
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Costs incurred in relation to the Ulster Bank transaction (a)
-
(31)
Other (b)
(2)
(2)
Impairment write-back from deleveraging of loans (c)
2
5
Exceptional items
-
(28)
(a) During 2024, no costs were incurred in relation to the Ulster Bank transaction (31 December 2023: €31m) as migration completed in 2023.
(b) Other costs of €2m (31 December 2023: €2m) relate to additional costs arising in respect of a previous disposal of a business, offset by a
provision release.
(c) 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 2024, warranty provisions and accruals of €2m (31 December 2023: €5m) were released in relation to loan deleveraging transactions
that the Group executed pre-31 December 2021.
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.
336
PTSB Group Holdings plc - Annual Report 2024
10. Taxation
(a) Analysis of taxation charge
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Current taxation
Charge for current year
1
1
1
1
Deferred taxation
Origination and reversal of temporary differences
(4)
10
Deferred taxation recognised in the income statement (note 25)
(4)
10
Taxation (credited)/charged to income statement
(3)
11
Effective tax rate
(2%)
14%
The Group taxation for the year ended 31 December 2024 was €3m credit (31 December 2023: €11m charge). The current tax charge of €1m
(31 December 2023: €1m) arises on trading income and certain non trading transactions, subject to the chargeable gains regime. Please refer
to Note 25 ‘Deferred taxation’ for details of the components of deferred taxation.
(b) Reconciliation of standard to effective tax rate
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Profit on the Group activities before tax
159
79
Tax calculated at standard ROI corporation tax rate of 12.5% (2023: 12.5%)
20
10
Tax effect of non-deductible expenses and non-trading income
-
1
Previously unrecognised tax losses
(16)
-
Adjustments of tax for prior periods
(6)
-
Other
(1)
-
Taxation (credited)/charged to income statement
(3)
11
(c) Tax effects of each component of other comprehensive income
Year ended 31 December 2024
Gross
Tax
Net
€m
€m
€m
Revaluation of property
(11)
4
(7)
Fair value reserve:
- Change in fair value of equity instruments
4
(1)
3
- Current tax on equity instrument disposal
-
-
-
- Deferred tax on equity instrument disposal
-
-
-
31 December 2024
(7)
3
(4)
PTSB Group Holdings plc - Annual Report 2024
337
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
10. Taxation (continued)
Year ended 31 December 2023
Gross
Tax
Net
€m
€m
€m
Revaluation of property
(12)
5
(7)
Fair value reserve:
- Change in fair value of equity instruments
5
(2)
3
- Current tax on equity instrument disposal
21
(6)
15
- Deferred tax on equity instrument disposal
(21)
6
(15)
31 December 2023
(7)
3
(4)
11. Earnings per ordinary share
(a) Basic earnings per ordinary share
Year ended
Year ended
31 December
2024
31 December
2023
Weighted average number of ordinary shares in issue and ranking for dividend excluding treasury shares
545,458,174
545,584,539
Profit for the year attributable to equity holders
€162m
€68m
Less AT1 coupon paid (see note 33)
(€43m)
(€43m)
Profit for the year attributable to equity holders less AT1 coupon paid
€119m
€25m
Basic earnings per ordinary share (€ cent)
21.7
4.5
(b) Diluted earnings per ordinary share
Year ended
Year ended
31 December
2024
31 December
2023
Weighted average number of ordinary shares excluding treasury shares held under employee benefit trust
used in the calculation of diluted earnings per share
545,458,174
545,584,539
Diluted earnings per ordinary share (€ cent)
21.7
4.5
Diluted earnings 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 2024 or 31 December 2023, as the AT1 securities issued in 2022 and 2020 have no conversion features within the
securities.
338
PTSB Group Holdings plc - Annual Report 2024
11. Earnings per ordinary share (continued)
Weighted average number of ordinary shares*
2024
2023
Number of ordinary shares in issue at 1 January (note 33)
545,589,119
545,589,119
Treasury shares held (note 33)
(4,580)
(4,580)
Net movements during the year
Weighted average shares bought back**
(126,365)
-
Weighted average number of ordinary shares
545,458,174
545,584,539
* When calculating the earnings 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.
** On the 14 October 2024 the Group completed a share buyback of 592,943 ordinary shares. See note 33 for further details.
There are no instruments with a potential to be converted to ordinary shares at 31 December 2024. The AT1 securities issued in 2022 and
2020 have no conversion features within the securities.
12. Cash and cash equivalents
For the purpose of the statement of cash flows, cash and cash equivalents comprise the following:
31 December
2024
31 December
2023
€m
€m
Cash at bank
72
71
Items in the course of collection
23
40
Loans and advances to banks repayable on demand (maturity of less than 3 months) (note 13)
2,202
2,051
Cash and cash equivalents as per statement of cash flows
2,297
2,162
At 31 December 2024, restricted cash of €181m (31 December 2023: €217m) (which is within loans and advances to banks repayable on
demand) consists of cash of €180m (31 December 2023: €217m) held by the Group’s securitisation entities and €1m (31 December 2023: €nil)
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; and
• when the notes are fully repaid these reserve funds can be used to pay outstanding principal on the subordinated loan.
13. Loans and advances to banks
31 December
2024
31 December
2023
€m
€m
Held at amortised cost
Placed with central banks
1,887
1,688
Placed with other banks
315
363
Loans and advances to banks
2,202
2,051
Placements with other banks includes restricted cash of €181m (31 December 2023: €217m) of which €180m (31 December 2023: €217m) is
held by the Group’s securitisation entities and €1m (31 December 2023: €nil) 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 2024 is €341m (31 December 2023: €nil).
Loans and advances to banks amounting to €2,202m (31 December 2023: €2,051m) have a maturity of less than three months and therefore
have been treated as cash and cash equivalents.
PTSB Group Holdings plc - Annual Report 2024
339
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
14. Derivative financial instruments
Derivative instruments are used by the Group, for risk management purposes, to hedge against interest rate risk and foreign currency risk.
Certain derivative instruments, while being economic hedges, 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; and
• Interest rate swaps which involve the exchange of fixed and variable rate interest payments between two parties at specified times based
on a common nominal amount and maturity date.
Further details on the Group’s risk management policies in connection with Derivatives and the policy surrounding Hedge Accounting are set
out in section 3.3 of the Risk Management Report.
The notional amounts and fair values of derivative instruments held by the Group are set out in the table below:
31 December 2024
31 December 2023
Contract/
notional amount
Fair
value
asset
Fair
value
liability
Contract/
notional amount
Fair
value
asset
Fair
value
liability
€m
€m
€m
€m
€m
€m
Derivatives held for hedging
Interest rate swaps
1,900
59
1,200
36
-
1,900
59
-
1,200
36
-
Derivatives held for trading
Currency Forwards
51
-
-
57
-
1
51
-
-
57
-
1
Derivative financial instruments
as per the statement of financial
position
1,951
59
-
1,257
36
1
Fair value hedges of interest rate risk
The Group uses fair value hedge accounting for hedge relationships to protect against changes in the fair value of financial assets and
financial liabilities due to movements in interest rates. The Group uses interest rate swaps to hedge fair value interest rate risk. The financial
instruments that are currently hedged for interest rate risk are fixed rate debt securities in issue and subordinated debt. All hedging
instruments are included within derivative financial instruments on the balance sheet and hedge ineffectiveness is included within net trading
income on the income statement (31 December 2024 €nil, 31 December 2023 €nil).
The Group held the following interest rate swaps as hedging instruments in fair value hedges of interest rate risk at 31 December 2024 and 31
December 2023.
Fair value hedges - Interest rate swaps*
31 December 2024
Less than 1
month
1 to 3 months
3 months to 1
year
1 to 5 years
5 years +
Liabilities:
Hedges of debt securities in issue
Nominal principal amount (€m)
-
-
-
1,650
-
Average interest rate (%)
-
-
-
2.85%
-
Hedges of subordinated debt
Nominal principal amount (€m)
-
-
-
250
-
Average interest rate (%)
-
-
-
3.48%
-
340
PTSB Group Holdings plc - Annual Report 2024
14. Derivative financial instruments (continued)
31 December 2023
Less than 1
month
1 to 3 months
3 months to 1
year
1 to 5 years
5 years +
Liabilities:
Hedges of debt securities in issue
Nominal principal amount (€m)
-
-
300
650
-
Average interest rate (%)
-
-
3.89%
3.17%
-
Hedges of subordinated debt
Nominal principal amount (€m)
-
-
-
250
-
Average interest rate (%)
-
-
-
3.48%
-
*The fixed rate on the interest rate swaps detailed above are swapped out for variable 3 month Euribor. The swaps pay 3 month EURIBOR on a quarterly basis and
receive fixed on an annual basis.
The tables below set out the amounts relating to items designated as (a) hedging instruments and (b) hedged items in fair value hedges of
interest rate risk together with the related hedge ineffectiveness at 31 December 2024 and December 2023.
(a) Hedging Instruments
31 December
2024
Nominal
Assets
Liabilities
Line item in SOFP
where the
hedging
instrument is
included
Change in fair
value used for
calculating hedge
ineffectiveness
for the year
Hedge
ineffectiveness
recognised in the
income
statement
Line item in the
income
statement that
included hedge
ineffectiveness
€m
€m
€m
€m
€m
Interest rate
swaps hedging:
Debt securities
in issue
1,650
53
-
Derivative
assets
19
-
Net trading
income
Subordinated
debt
250
6
-
Derivative
assets
-
-
Net trading
income
31 December
2023
Nominal
Assets
Liabilities
Line item in SOFP
where the
hedging
instrument is
included
Change in fair
value used for
calculating hedge
ineffectiveness
for the year
Hedge
ineffectiveness
recognised in the
income
statement
Line item in the
income
statement that
included hedge
ineffectiveness
€m
€m
€m
€m
€m
Interest rate
swaps hedging:
Debt securities
in issue
950
30
-
Derivative
assets
14
-
Net trading
income
Subordinated
debt
250
6
-
Derivative
assets
5
-
Net trading
income
PTSB Group Holdings plc - Annual Report 2024
341
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
14. Derivative financial instruments (continued)
(b) Hedged Items
31 December
2024
Carrying amount of hedged items
recognised in the SOFP
Accumulated amount of fair value
hedge adjustments on the hedged
items included in the carrying
amount of the hedged item
Line item in the
SOFP where
hedged item is
included
Change in fair
value of hedged
items used for
calculating hedge
ineffectiveness
for the year
Accumulated
amount of fair
value hedge
adjustments
remaining in the
SOFP for any
hedged items
that have ceased
to be adjusted for
hedging
Assets
Liabilities
Assets
Liabilities
€m
€m
€m
€m
€m
€m
Debt securities
in issue
-
(1,731)
-
(33)
Debt securities
in issue
(19)
-
Subordinated
debt
-
(257)
-
(5)
Subordinated
liabilities
-
-
31 December
2023
Carrying amount of hedged items
recognised in the SOFP
Accumulated amount of fair value
hedge adjustments on the hedged
items included in the carrying
amount of the hedged item
Line item in the
SOFP where
hedged item is
included
Change in fair
value of hedged
items used for
calculating hedge
ineffectiveness
for the year
Accumulated
amount of fair
value hedge
adjustments
remaining in the
SOFP for any
hedged items
that have ceased
to be adjusted for
hedging
Assets
Liabilities
Assets
Liabilities
€m
€m
€m
€m
€m
€m
Debt securities
in issue
-
(997)
-
(14)
Debt securities
in issue
(14)
-
Subordinated
debt
-
(257)
-
(5)
Subordinated
liabilities
(5)
-
15. Other assets
31 December
2024
31 December
2023
€m
€m
Receivables
-
57
Other
7
3
7
60
Other assets include €6m relating to our Interest First deposit product at 31 December 2024 (31 December 2023: €nil).
Receivables of €57m at 31 December 2023 relates to amounts due to the Group on completion of the liquidation of PBI Ltd which entered
liquidation on 15 December 2023. This was received during 2024.
342
PTSB Group Holdings plc - Annual Report 2024
16. Assets classified as held for sale
At 31 December 2024, assets classified as held for sale of €12m (31 December 2023: €12m) consists of:
• €7m (31 December 2023: €11m) which relates to collateral in possession, these properties are expected to be sold within the next 12
months; and
• €5m (31 December 2023: €1m) which relates to three branch properties (31 December 2023: two branch properties) that are no longer
occupied by the Group, the sales of these properties are expected to complete within the next 12 months.
17. Debt securities
31 December
2024
31 December
2023
Total HTC
Total HTC
€m
€m
Government bonds
4,259
3,256
Covered bonds
68
-
Gross debt securities
4,327
3,256
As at 31 December 2024, 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 Hold to Collect (HTC) business model basis are accounted for at amortised cost.
Government bonds of €4.3bn (31 December 2023: €3.3bn) comprise of Irish, Spanish, Portuguese, French, Italian, Belgian, Austrian and EU
government bonds which are classified as HTC.
Covered bonds of €0.1bn (31 December 2023: €nil) comprise of French corporate bonds which are classified as HTC.
The HTC securities represent a portfolio of securities structured for the purpose of collecting contractual cashflows to maturity. The Group has
no HTC&S debt securities as at 31 December 2024 and 31 December 2023.
At 31 December 2024, debt securities at amortised cost with a fair value of €371m (31 December 2023: €529m) 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 2024 are stage 1 for ECL purposes.
(a) HTC
The movement in HTC securities is classified as follows:
31 December
2024
31 December
2023
HTC
HTC
€m
€m
As at 1 January
3,256
3,177
Additions
1,212
828
Maturities
(170)
(728)
Interest net of cash receipts
7
(14)
Amortisation of premium/(discount)
22
(7)
Total
4,327
3,256
(b) Amounts arising from impairment provisioning on debt securities:
Held at amortised cost
As at 31 December 2024, the amount arising from ECL on debt securities measured at amortised cost is €0.6m (31 December 2023: €0.6m).
The ECL on debt instruments measured at amortised cost is offset against the carrying amount of the assets in the statement of financial
position.
PTSB Group Holdings plc - Annual Report 2024
343
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
18. Equity securities
31 December
2024
31 December
2023
€m
€m
As at 1 January
5
30
Revaluation
4
5
Disposal
-
(30)
Total equity securities
9
5
The carrying value of equity securities can be analysed as follows:
31 December
2024
31 December
2023
€m
€m
Unlisted
9
5
Gross equity securities
9
5
The Group holds Series A and Series B preferred stock in Visa Inc. at 31 December 2024 with a value of €9m (31 December 2023: €5m). The
Series A preferred stock was issued from Visa Inc during 2024 upon the conversion of Series B preferred stock. These were fair valued at
Series A €7m and Series B €2m at 31 December 2024 (31 December 2023: €nil and €5m) and are recognised in the Statement of Financial
Position at FVOCI.
During 2023 the Group disposed of its previous holding of Visa A shares for €30m. These Series A preferred stock were initially issued upon
the conversion of Series B preferred stock by Visa Inc in 2020.
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 35 for details).
19. Prepayments and contract assets
31 December
2024
31 December
2023
€m
€m
Visa prepayments
30
43
Other prepayments
33
37
63
80
344
PTSB Group Holdings plc - Annual Report 2024
20. Loans and advances to customers
Loans and advances by category are set out below:
31 December
2024
31 December
2023
€m
€m
Residential mortgages
- Held through special purpose entities
5,342
5,664
- Held directly
14,661
14,642
Total residential mortgages
20,003
20,306
Commercial mortgage loans
493
437
Consumer finance
553
499
Finance leases and hire purchase receivables
466
446
Gross loans and advances to customers
21,515
21,688
Less: provision for impairment (note 21)
(392)
(570)
Deferred fees, discounts and business combination related fair value adjustments
300
309
Net loans and advances to customers
21,423
21,427
Loans and advances can be analysed into tracker, fixed and variable rate loans as follows:
Gross loans and advances to
customers
Net loans and advances to
customers
31 December
2024
31 December
2023
31 December
2024
31 December
2023
€m
€m
€m
€m
Tracker rate
2,692
3,453
2,563
3,186
Variable rate
4,669
3,788
4,525
3,632
Fixed rate
14,154
14,447
14,035
14,300
Gross loans and advances to customers
21,515
21,688
21,123
21,118
Deferred fees, discounts and business combination related fair value
adjustments
300
309
300
309
Gross loans and advances to customers and deferred fees
21,815
21,997
21,423
21,427
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:
31 December
2024
31 December
2023
€m
€m
Residential mortgages held through special purpose entities
5,342
5,664
Notes issued by special purpose entities
- rated
5,164
4,911
- unrated
262
806
PTSB Group Holdings plc - Annual Report 2024
345
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
20. Loans and advances to customers (continued)
The notes issued by these special purpose entities comprise the following:
31 December
2024
31 December
2023
€m
€
Held by other banks and institutions as part of collateralised lending or sale and repurchase agreements
(note 26)
-
287
Rated notes, available for collateral *
4,265
3,725
Rated notes, unavailable for collateral
899
899
Unrated notes
262
806
5,426
5,717
*The eligibility of available collateral will depend on the criteria of the counterparty.
Loans and advances balance movement for the year ended 31 December 2024 and the year ended 31 December 2023 is set out in the
following tables:
Non-credit impaired
Credit impaired
Total
Stage 1
Stage 2
Stage 3
POCI
€m
€m
€m
€m
€m
Balance as at 1 January 2024
19,057
1,913
718
-
21,688
New assets originated*
2,228
212
2
-
2,442
Loans acquired
-
-
-
-
-
Stage Transfers:
Transfers from Stage 1 to Stage 2
(711)
711
-
-
-
Transfers to Stage 3
(36)
(96)
132
-
-
Transfers from Stage 2 to Stage 1
465
(465)
-
-
-
Transfers from Stage 3
4
57
(61)
-
-
Net movement arising from transfer of Stage
(278)
207
71
-
-
Redemptions and repayments
(1,906)
(297)
(49)
-
(2,252)
Decrease due to write offs
(1)
(2)
(19)
-
(22)
Disposals
-
-
(341)
-
(341)
Other movements
-
-
-
-
-
Balance as at 31 December 2024
19,100
2,033
382
-
21,515
*Loan originations are net of repayments in the year
346
PTSB Group Holdings plc - Annual Report 2024
20. Loans and advances to customers (continued)
Non-credit impaired
Credit impaired
Total
Stage 1
Stage 2
Stage 3
POCI
€m
€m
€m
€m
€m
Balance as at 1 January 2023
17,455
1,699
649
1
19,804
New assets originated*
2,205
122
10
-
2,337
Loans acquired**
1,308
127
55
-
1,490
Stage Transfers:
Transfers from Stage 1 to Stage 2
(432)
432
-
-
-
Transfers to Stage 3
(43)
(136)
179
-
-
Transfers from Stage 2 to Stage 1
195
(195)
-
-
-
Transfers from Stage 3
-
95
(95)
-
-
Net movement arising from transfer of Stage
(280)
196
84
-
-
Redemptions and repayments
(1,631)
(230)
(62)
-
(1,923)
Decrease due to write offs
-
(1)
(18)
-
(19)
Disposals
-
-
-
-
-
Other movements
-
-
-
(1)
(1)
Balance as at 31 December 2023
19,057
1,913
718
-
21,688
*Loan originations are net of repayments in the year
**Net of repayments
Amounts receivable under finance leases and hire purchase receivables
The following balances principally comprise of leasing arrangements and hire purchase agreements of vehicles, plant, machinery and
equipment:
31 December
2024
31 December
2023
€m
€m
Gross receivables
Not later than 1 year
184
172
Later than 1 year and not later than 2 years
146
138
Later than 2 years and not later than 3 years
99
97
Later than 3 years and not later than 4 years
60
59
Later than 4 years and not later than 5 years
26
26
Later than 5 years
7
8
Total
522
500
Unearned future finance income
(56)
(54)
Deferred costs incurred on origination
6
5
Present value of minimum payments
472
451
ECL allowance for uncollectible minimum payments receivable
(19)
(20)
PTSB Group Holdings plc - Annual Report 2024
347
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
21. Impairment provisions
Loans and advances to customers
The following tables 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 2024 was €382m (31 December 2023: €718m). Refer to note 36 for further details.
ECL provisions
31 December 2024
Loans and
advances to
customers
of which
NPLs
NPL % of total
loans
Stage 1
Stage 2
Stage 3
Total
Total ECL
provisions as
% of total
loans
€m
€m
%
€m
€m
€m
€m
%
Residential:
- Home loans
19,539
259
1.3%
98
38
73
209
1.1%
- Buy-to-let
464
71
15.3%
2
43
31
76
16.4%
Commercial
493
24
4.9%
5
36
9
50
10.1%
Consumer finance
553
20
3.6%
8
14
16
38
6.9%
Finance leases and hire
purchase receivables
466
8
1.7%
10
3
6
19
4.1%
Total gross loans
21,515
382
1.8%
123
134
135
392
1.8%
Impairment provision
(392)
Deferred fees, discounts
and business combination
related fair value
adjustments
300
Balance as at 31 December
2024
21,423
ECL provisions
31 December 2023
Loans and
advances to
customers
of which
NPLs
NPL % of total
loans
Stage 1
Stage 2
Stage 3
Total
Total ECL
provisions as
% of total
loans
€m
€m
%
€m
€m
€m
€m
%
Residential:
- Home loans
19,557
403
2.1%
131
51
110
292
1.5%
- Buy-to-let
749
267
35.6%
2
58
99
159
21.2%
Commercial
437
20
4.6%
8
47
11
66
15.1%
Consumer finance
499
16
3.2%
12
8
13
33
6.6%
Finance leases and hire
purchase receivables
446
12
2.7%
12
-
8
20
4.5%
Total gross loans
21,688
718
3.3%
165
164
241
570
2.6%
Impairment provision
(570)
Deferred fees, discounts
and business combination
related fair value
adjustments
309
Balance as at 31 December
2023
21,427
348
PTSB Group Holdings plc - Annual Report 2024
21. Impairment provisions (continued)
A reconciliation of the provision for impairment losses for loans and advances to customers is as follows:
2024
Residential
mortgages
Commercial
Consumer
finance
Finance
leases and
hire purchase
receivables
Total
€m
€m
€m
€m
€m
Total by portfolio
ECL as at 1 January 2024
451
66
33
20
570
Redemptions and repayments
(28)
-
-
-
(28)
Net remeasurement of loss allowance
(35)
(20)
3
(8)
(60)
Loan originations
28
14
5
8
55
Loans acquired
-
-
-
-
-
Net movement excluding derecognition
(35)
(6)
8
-
(33)
Derecognition-disposals
(124)
(9)
-
-
(133)
Derecognition-repossessions
-
-
-
-
-
Derecognition-write offs*
(7)
(1)
(3)
(1)
(12)
Derecognition
(131)
(10)
(3)
(1)
(145)
ECL as at 31 December 2024**
285
50
38
19
392
Net movement excluding derecognition (from above)
(33)
Interest income booked but not recognised
(11)
Other movements***
13
Write offs net of recoveries
1
Impairment write-back on loans and advances to customers for the
year ended 31 December 2024
(30)
*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.
**Closing ECL incorporates ECL of €12m on loan commitments.
***Includes impairment charge on deleveraging (€9m) and provisions on loan commitments where there is no recognised financial asset (€4m).
PTSB Group Holdings plc - Annual Report 2024
349
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
21. Impairment provisions (continued)
2023
Residential
mortgages
Commercial
Consumer
finance
Finance leases
and hire purchase
receivables
Total
€m
€m
€m
€m
€m
Total by portfolio
ECL as at 1 January 2023
447
40
34
-
521
Redemptions and repayments
(22)
(1)
-
-
(23)
Net remeasurement of loss allowance
(8)
2
(5)
-
(11)
Loan originations
29
16
3
-
48
Loans acquired
12
10
4
20
46
Net movement excluding derecognition
11
27
2
20
60
Derecognition-disposals
-
-
-
-
-
Derecognition-repossessions
-
-
-
-
-
Derecognition-write offs*
(7)
(1)
(3)
-
(11)
Derecognition
(7)
(1)
(3)
-
(11)
ECL as at 31 December 2023**
451
66
33
20
570
Net movement excluding derecognition (from
above)
60
Interest income booked but not recognised
(12)
Other movements***
6
Write offs net of recoveries
2
Impairment charge on loans and advances to
customers for the year ended 31 December 2023
56
*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.
**Closing ECL incorporates ECL of €8m on loan commitments.
***Includes costs in respect of deleveraging (€2m) and impairment of interest in associated undertakings (€4m).
350
PTSB Group Holdings plc - Annual Report 2024
21. Impairment provisions (continued)
Stage 1
Stage 2
Stage 3
Total
2024
€m
€m
€m
€m
Total by stage
ECL as at 1 January 2024
165
164
241
570
Transfer to Stage 1
23
(22)
(1)
-
Transfer to Stage 2
(13)
22
(9)
-
Transfer to Stage 3
(1)
(10)
11
-
Stage transfers
9
(10)
1
-
Redemptions and repayments
(6)
(15)
(7)
(28)
Net remeasurement of loss allowance
(79)
(24)
43
(60)
Loan originations
34
20
1
55
Loans Acquired
-
-
-
-
Net movement excluding derecognition
(51)
(19)
37
(33)
Derecognition-disposals
-
-
(133)
(133)
Derecognition-repossessions
-
-
-
-
Derecognition-write offs*
-
(1)
(11)
(12)
Derecognition
-
(1)
(144)
(145)
ECL as at 31 December 2024**
123
134
135
392
Net movement excluding derecognition (from above)
(33)
Interest income booked but not recognised
(11)
Other movements***
13
Write offs net of recoveries
1
Impairment write-back on loans and advances to customers for the
year ended 31 December 2024
(30)
*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.
**Closing ECL incorporates ECL of €12m on loan commitments.
***Includes impairment charge on deleveraging (€9m) and provisions on loan commitments where there is no recognised financial asset (€4m).
PTSB Group Holdings plc - Annual Report 2024
351
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
21. Impairment provisions (continued)
Stage 1
Stage 2
Stage 3
Total
2023
€m
€m
€m
€m
Total by stage
ECL as at 1 January 2023
136
163
222
521
Transfer to Stage 1
31
(30)
(1)
-
Transfer to Stage 2
(6)
21
(15)
-
Transfer to Stage 3
-
(21)
21
-
Stage transfers
25
(30)
5
-
Redemptions and repayments
(5)
(11)
(7)
(23)
Net remeasurement of loss allowance
(38)
12
15
(11)
Loan originations
18
27
3
48
Loans Acquired
29
3
14
46
Net movement excluding derecognition
4
31
25
60
Derecognition-disposals
-
-
-
-
Derecognition-repossessions
-
-
-
-
Derecognition-write offs*
-
-
(11)
(11)
Derecognition
-
-
(11)
(11)
ECL as at 31 December 2023**
165
164
241
570
Net movement excluding derecognition (from above)
60
Interest income booked but not recognised
(12)
Other movements***
6
Write offs net of recoveries
2
Impairment charge on loans and advances to customers for the year
ended 31 December 2023
56
*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.
**Closing ECL incorporates ECL of €8m on loan commitments.
***Includes costs in respect of deleveraging (€2m) and impairment of interest in associated undertakings (€4m).
Modified Financial Assets
There have been no significant modified financial assets for which the loss allowance has changed from lifetime to 12-month ECL at 31
December 2024 and 31 December 2023.
352
PTSB Group Holdings plc - Annual Report 2024
22. Interest in associated undertakings
31 December
31 December
2024
2023
€m
€m
Clearpay
1
1
First Home Scheme Ireland
20
15
21
16
The Group owns a non-controlling interest in Clearpay DAC (33%) as at 31 December 2024. This investment is accounted for under the equity
method in the consolidated financial statements and has a carrying value of €1m at 31 December 2024 (31 December 2023: €1m). This
investment will be increased or decreased by the Group’s share of the profit or loss which will be assessed annually.
On 15 November 2023 Synch Payments DAC announced that it would cease operations and an impairment of €3.5m was recognised in 2023.
In 2024, the Group ceased recognising its investment in Synch Payments DAC as it was liquidated on 26 February 2024.
On 1 July 2022, the Group invested in First Home Scheme Ireland DAC along with the Irish Government, AIB and Bank of Ireland. First Home
Scheme Ireland DAC is incorporated and operates in the Republic of Ireland providing equity support to future homeowners by taking a
beneficial interest in residential dwellings which enables customers to purchase these residential dwellings. The participants fund these
purchases, as well as costs, through a loan facility. The Group owns a non-controlling interest of 25% as 31 December 2024. This investment
in associate is accounted for under the equity method in the consolidated financial statements and was initially recognised at €11m being the
Group's agreed 13.5% contribution rate.
The Group has presented summarised financial information of the First Home Scheme Ireland DAC in line with IFRS 12 below as well as a
reconciliation of the summarised financial information to the carrying value above.
31 December
31 December
2024
2023
€m
€m
Summarised Statement of financial position
Current assets
41
58
Cash and cash equivalents
41
58
Non-current assets
226
89
Current liabilities
(1)
(1)
Non-current liabilities
(266)
(146)
Non-current financial liabilities
(266)
(146)
Summarised Income statement
Other operating income
13
9
Operating expenses
(7)
(6)
Finance expense
(6)
(3)
Reconciliation of summarised financial information to carrying value
1 January
15
10
Share of loan facility*
2
-
Drawdowns of loan facility**
3
5
31 December
20
15
*The Group’s share of the loan facility is based on the finance expense amount disclosed above and the share of the remaining profit from the Revenue less
Operating expenses above.
**The total drawdowns on the loan facility are disclosed in the notes to the First Home Scheme Ireland DAC financial statements. The amount above is the Group’s
contributions.
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.
PTSB Group Holdings plc - Annual Report 2024
353
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
23. Property and equipment
Right-of-use assets*
Held at fair value
land and
buildings
Fixtures and
fittings
Held at cost
office and
computer
equipment Leased buildings
Leased motor
vehicles
Total
2024
€m
€m
€m
€m
€m
€m
Cost or valuation
At 1 January
86
147
118
65
3
419
Additions
-
12
2
5
2
21
Revaluations
(11)
-
-
-
-
(11)
Depreciation write-back on
revaluation
(1)
-
-
-
-
(1)
Disposals or cancellations
(3)
-
-
-
-
(3)
At 31 December
71
159
120
70
5
425
Accumulated depreciation
At 1 January
-
(93)
(87)
(31)
(3)
(214)
Provided in the year
(1)
(10)
(11)
(6)
(1)
(29)
Eliminate on revaluation
1
-
-
-
-
1
At 31 December
-
(103)
(98)
(37)
(4)
(242)
Net book value at 31 December
71
56
22
33
1
183
*For further details on right-of-use assets refer to note 32.
Of the €11m net revaluation loss, €11m 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.
Right-of-use assets*
Held at fair value
land and
buildings
Fixtures and
fittings
Held at cost
office and
computer
equipment Leased buildings
Leased motor
vehicles
Total
2023
€m
€m
€m
€m
€m
€m
Cost or valuation
At 1 January
91
128
109
61
3
392
Additions
-
19
9
1
-
29
Additions from Business
Combinations
9
-
-
3
-
12
Revaluations
(12)
-
-
-
-
(12)
Depreciation write-back on
revaluation
(1)
-
-
-
-
(1)
Disposals or cancellations
(1)
-
-
-
-
(1)
At 31 December
86
147
118
65
3
419
Accumulated depreciation
At 1 January
-
(84)
(77)
(25)
(2)
(188)
Provided in the year
(1)
(9)
(10)
(6)
(1)
(27)
Eliminate on revaluation
1
-
-
-
-
1
At 31 December
-
(93)
(87)
(31)
(3)
(214)
Net book value at 31 December
86
54
31
34
-
205
*For further details on right-of-use assets refer to note 32.
354
PTSB Group Holdings plc - Annual Report 2024
23. Property and equipment (continued)
Of the €12m revaluation loss, €12m 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.
The net book value of land and buildings includes the following:
31 December
31 December
2024
2023
€m
€m
Land
24
26
Buildings - freehold fair value
47
60
Buildings - fixtures and fittings
45
42
Buildings - leasehold
44
46
160
174
Buildings – leasehold includes €11m (31 December 2023: €12m) of fixtures and fittings within leased buildings.
Land and buildings as at 31 December 2024 held at fair value was €71m (31 December 2023: €86m). The historic cost of land and buildings
under the cost model is €43m (31 December 2023: €44m).
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 2024 and 31 December 2023 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 2024 and 30 November 2023.
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 6.64% to 10.50%. 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 2024 and 31 December 2023 are as follows:
31 December 2024
Level 1
Level 2
Level 3
Total fair value
€m
€m
€m
€m
Land
-
-
24
24
Buildings - freehold
-
-
47
47
-
-
71
71
31 December 2023
Level 1
Level 2
Level 3
Total fair value
€m
€m
€m
€m
Land
-
-
26
26
Buildings - freehold
-
-
60
60
-
-
86
86
PTSB Group Holdings plc - Annual Report 2024
355
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
23. Property and equipment (continued)
Key unobservable inputs
The following table summarises the valuation techniques and inputs used in the determination of freehold land and building values:
31 December 2024
Cap Yield
Rent per sqm
%
€
Low
High weighted average
Low
High weighted average
Freehold Land and Buildings
Urban Centres
6.64%
8.50%
6.87%
237
1,700
626
Urban Other
7.50%
9.75%
8.15%
210
770
351
Rural
8.00%
10.50%
8.99%
108
269
202
31 December 2023
Cap Yield
Rent per sqm
%
€
Low
High weighted average
Low
High weighted average
Freehold Land and Buildings
Urban Centres
5.35%
9.65%
9.03%
237
4,252
657
Urban Other
7.50%
9.50%
8.23%
194
770
348
Rural
8.00%
10.75%
9.07%
108
266
196
Interrelationship between key unobservable inputs and fair value measurement
The estimated fair value would increase/(decrease) if:
• capital yield were higher (lower)
• the rent per square metre were higher (lower)
24. Intangible assets
Software
31 December
2024
31 December
2023
€m
€m
Cost
At 1 January
360
293
Additions
88
67
At 31 December
448
360
Accumulated amortisation
At 1 January
(173)
(133)
Provided in the year
(62)
(40)
At 31 December
(235)
(173)
Net book value at 31 December
213
187
Research and development expenditure in the period to 31 December 2024 was €27m (31 December 2023: €28m) and is included in Note 7:
Administrative, staff and other expenses (excluding exceptional items).
356
PTSB Group Holdings plc - Annual Report 2024
25. Deferred taxation
31 December
2024
31 December
2023
€m
€m
Deferred tax liabilities
(15)
(18)
Deferred tax assets
331
327
Net deferred tax assets
316
309
Net deferred tax assets are attributable to the following:
2024
At 1 January
Recognised in
income
statement
Recognised in
other
comprehensive
income
At 31 December
€m
€m
€m
€m
Property and equipment (including right of use assets)
(17)
-
4
(13)
Unrealised gains/(losses) on assets/liabilities
(1)
-
(1)
(2)
Losses carried forward, movements comprised of
323
-
-
323
- Losses generated/(utilised) in the period
-
(16)
-
(16)
- Losses previously unrecognised tax losses
-
16
-
16
Other temporary differences
-
4
-
4
Other Liabilities (including lease liabilities)
4
-
-
4
309
4
3
316
2023
At 1 January
Recognised in
income
statement
Recognised in
other
comprehensive
income
At 31 December
€m
€m
€m
€m
Property and equipment (including right of use assets)
(18)
(4)
5
(17)
Unrealised gains/(losses) on assets/liabilities
(7)
-
6
(1)
Losses carried forward
334
(11)
-
323
Other temporary differences
-
1
(1)
-
Other Liabilities (including lease liabilities)
-
4
-
4
309
(10)
10
309
PTSB Group Holdings plc - Annual Report 2024
357
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
25. Deferred taxation (continued)
The Group applied Deferred Tax related to Assets and Liabilities arising from a Single Transaction (Amendments to IAS 12) from 1 January
2023. Following the amendments, the Group has recognised a separate deferred tax asset in relation to its lease liabilities and a deferred tax
liability in relation to its right-of-use assets.
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 2024 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 2024 amounted to €20m (31 December 2023:
€36m).
Included in the overall deferred tax asset is a deferred tax asset of €nil in relation to Permanent TSB Group Holdings plc (31 December 2023:
€nil).
In accordance with IFRS these balances are recognised on an undiscounted basis.
Pillar Two – minimum effective tax rate
In 2021 the Organisation for Economic Co-operation and Development (OECD) released the 15% minimum effective tax rate (“Pillar Two”)
Model Rules. Pillar Two legislation has been enacted in Ireland, effective 1 January 2024. The Group has performed an assessment of the
Group’s potential exposure to Pillar Two income taxes. Based on the assessment performed, the Group will be in scope of the Pillar Two
legislation for the Group’s financial year beginning 1 January 2025. The Group will continue to assess the application of Pillar Two legislation for
future reporting periods. The Group has applied the IAS 12 temporary exception to the accounting for deferred taxes arising from the
implementation of the Pillar Two rules.
26. Deposits by banks
31 December
2024
31 December
2023
€m
€m
Placed by other banks and institutions on repurchase agreements
65
380
Other deposits
40
18
Deposits by banks
105
398
Securities which are sold under agreements to repurchase are secured by Irish and other eligible 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 €371m at 31 December 2024 (31 December 2023: €529m). Other deposits include €40m (31 December 2023: €18m) of cash
collateral placed with PTSB in relation to derivative positions and repurchase agreements.
358
PTSB Group Holdings plc - Annual Report 2024
27. Customer accounts
31 December
2024
31 December
2023
€m
€m
Term deposits
5,104
3,028
Demand deposits
7,520
8,451
Current accounts
9,187
9,329
Notice and other accounts
2,309
2,158
Customer accounts
24,120
22,966
All customer accounts above are held at amortised cost.
At 31 December 2024, the Group held corporate deposits of €1,468m (31 December 2023: €1,316m).
An analysis of the contractual maturity profile of customer accounts is set out in the liquidity risk section of note 36 of the consolidated
financial statements.
28. Debt securities in issue
31 December
2024
31 December
2023
€m
€m
At amortised cost
Bonds and medium-term notes
1,731
1,512
1,731
1,512
Maturity analysis
Repayable in less than 1 year
56
54
Repayable in greater than 1 year but less than 5 years
1,168
960
Repayable in greater than 5 years
507
498
1,731
1,512
Bonds and medium-term notes
In the first half of 2024, PTSBGH issued €500m of Senior Unsecured Medium Term Notes at a fixed rate of 4.25% per annum, maturing on 10
July 2030. Interest is payable on the nominal amount annually in arrears on the coupon date.
Senior Unsecured Medium Term notes of €300m at a fixed rate of 5.25% were redeemed on the optional redemption date of 01 July 2024.
€1,650m of Senior Unsecured Medium Term Notes are currently hedged for fair value interest rate risk. At 31 December 2024, debt securities
in issue contains €33m hedge adjustment (31 December 2023: €14m). Further details are included in note 14 of the financial statements.
PTSB Group Holdings plc - Annual Report 2024
359
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
29. Other liabilities
31 December
2024
31 December
2023
€m
€m
Amounts falling due within one year
PAYE and social insurance
6
6
Other taxation including deposit interest retention tax (DIRT)
12
4
Creditor accruals
67
95
Other*
9
8
Lease liability (see note 32 for further information on lease liabilities)
6
6
Total amounts falling due within one year
100
119
Amounts falling due greater than one year
Lease liability (see note 32 for further information on lease liabilities)
29
29
Total amounts falling due greater than one year
29
29
Total other liabilities
129
148
* Other includes liability of €8m for Visa balances at 31 December 2024 (31 December 2023: €8m).
30. Provisions
2024
2023
Restructuring
costs
Provision for
legacy, legal
and
compliance
liabilities
Other
Total
Restructuring
costs
Provision for
legacy, legal
and
compliance
liabilities
Other
Total
€m
€m
€m
€m
€m
€m
€m
€m
As at 1 January
2
13
25
40
4
23
53
80
Provisions made during the
year
-
13
5
18
-
2
6
8
Write-back of provisions
during the year
-
(3)
(2)
(5)
-
(1)
(6)
(7)
Provisions used during the
year
(1)
(6)
-
(7)
(2)
(11)
(28)
(41)
As at 31 December
1
17
28
46
2
13
25
40
The provision at 31 December 2024 is €46m (31 December 2023: €40m) which is comprised of the following:
Restructuring costs
During 2020, the Group announced an Enterprise Transformation program. At 31 December 2020, a provision for restructuring of €27m was
recognised based on the estimate of the costs of this program. From 2021, additional provisions of €10m were made and amounts of €36m
were utilised. The remaining provision of €0.4m is included in the Restructuring provision. This program is expected to conclude in 2025.
The Group remains a lessee on a number of non-cancellable leases over properties that it no longer occupies following a restructure in 2013. A
provision of €0.6m relates to dilapidation costs associated with these properties.
360
PTSB Group Holdings plc - Annual Report 2024
30. Provisions (continued)
Provision for legacy, legal and compliance liabilities
As at 31 December 2024, the Group has provisions of €17m relating to legal, compliance and other costs of ongoing disputes in relation to
legacy business issues (31 December 2023: €13m).
A provision of €13m was made during 2024 relating to legal, compliance and other costs of ongoing disputes in relation to legacy business
issues. €4m of this relates to ECL (31 December 2023: €nil) held against loan commitments (see note 41 for further detail) (where the loan
commitment relates to a loan already recognised as a financial asset, the ECL is recognised in Loans and advances to customers).
Management has exercised judgement in arriving at the estimated provision in respect of the potential liabilities.
Other
As at 31 December 2024, Other provisions of €28m (31 December 2023: €25m) primarily relates to indemnities and guarantees provided by
the Group, along with warranties relating to the deleveraging of various asset portfolios.
31. Subordinated liabilities
31 December
2024
31 December
2023
€m
€m
At amortised cost:
€250m Tier 2 capital notes due August 2031, Callable 2026
257
257
257
257
31 December
2024
31 December
2023
€m
€m
Maturity date
Repayable in less than 1 year
3
3
Repayable in greater than 1 year but less than 5 years
-
-
Repayable in greater than 5 years
254
254
257
257
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 Capital Requirement Regulations.
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.
The Tier 2 capital notes are currently hedged for fair value interest rate risk. At 31 December 2024, subordinated liabilities contain €5m hedge
adjustment (31 December 2023: €5m). Further details on hedging are included in note 14 of the financial statements.
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, additional Tier 1 capital notes 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.
The Group did not have any defaults of principal or interest or other breaches with respect to its subordinated liabilities during the years ended
31 December 2024 and 31 December 2023.
PTSB Group Holdings plc - Annual Report 2024
361
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
32. Leases
Right-of-use assets*
Land and
buildings
Motor vehicles
Total
€m
€m
€m
As at 1 January 2024
34
-
34
Additions
5
2
7
Lease exits and cancellations
-
-
-
Depreciation of right-of-use assets
(6)
(1)
(7)
Balance as at 31 December 2024
33
1
34
Right-of-use assets*
Land and
buildings
Motor vehicles
Total
€m
€m
€m
As at 1 January 2023
36
1
37
Additions
4
-
4
Lease exits and cancellations
-
-
-
Depreciation of right-of-use assets
(6)
(1)
(7)
Balance as at 31 December 2023
34
-
34
Lease liabilities*
Land and
buildings
Motor vehicles
Total
€m
€m
€m
As at 1 January 2024
35
-
35
Additions
5
2
7
Lease exits or cancellations
-
-
-
Repayment of lease liabilities
(6)
(1)
(7)
Balance as at 31 December 2024
34
1
35
Lease liabilities*
Land and
buildings
Motor vehicles
Total
€m
€m
€m
As at 1 January 2023
37
1
38
Additions
4
-
4
Lease exits or cancellations
-
-
-
Repayment of lease liabilities
(6)
(1)
(7)
Balance as at 31 December 2023
35
-
35
* Right-of-use assets are included in Property and equipment and lease liabilities are included in Other liabilities.
362
PTSB Group Holdings plc - Annual Report 2024
32. Leases (continued)
Lease liabilities
31 December
2024
31 December
2023
€m
€m
Maturity analysis - contractual undiscounted cash flows*
Less than one year
6
7
One to five years
19
18
More than five years
12
12
Total undiscounted lease liabilities
37
37
Lease liabilities included in the statement of financial position
35
35
Current lease liability
6
6
Non-current lease liability
29
29
* The maturity analysis of undiscounted lease liabilities are disclosed in note 36.
Amounts recognised in income statement
31 December
2024
31 December
2023
€m
€m
Interest on lease liabilities*
(1)
(1)
Expenses relating to short-term leases
(1)
-
Depreciation of right-of-use assets
(7)
(7)
Total charge in income statement
(9)
(8)
* Interest expense on the lease liabilities amounted to €0.6m (31 December 2023: €0.9m) whereas expenses relating to short-term leases amounted to €0.8m (31
December 2023: €0.5m) and is included in Administrative, staff and other expenses (excluding exceptional items).
Amounts recognised in statement of cash flow
31 December
2024
31 December
2023
€m
€m
Operating cashflows:
Short-term leases
(1)
-
Financing cash flows:
Cash outflow for leases principal and interest
(7)
(7)
Total
(8)
(7)
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 2024 (31 December 2023: no sub-leases). Further details on ‘leases as a lessor’ are included
in note 1 of the financial statements.
PTSB Group Holdings plc - Annual Report 2024
363
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
33. 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 shares rank equally with regard to the Bank’s residual assets.
Authorised share capital
31 December 2024
31 December
2024
Number of shares
€m
Ordinary shares of €0.50 each
1,550,000,000
775
31 December 2023
31 December
2023
Number of shares
€m
Ordinary shares of €0.50 each
1,550,000,000
775
Issued share capital
The movement in the number of paid up ordinary shares is as follows:
Balances as at 31 December 2024
€ 0.50 Ordinary
shares
Total
As at 1 January 2024
545,589,119
Movement*
(592,943)
As at 31 December 2024
544,996,176
Issued share capital (€m)
272
272
Shares held under employee benefit trust
4,580
% of authorised capital issued
35%
Balances as at 31 December 2023
€ 0.50 Ordinary
shares
Total
As at 1 January 2023
545,589,119
Movement
-
As at 31 December 2023
545,589,119
Issued share capital (€m)
273
273
Shares held under employee benefit trust
4,580
% of authorised capital issued
35%
* In 2024 Permanent TSB Group Holdings plc completed a share buyback of 592,943 ordinary shares at a price of €1.74 per ordinary share totalling €1m. The
shares were recognised as treasury shares upon repurchase and were subsequently cancelled. The nominal amount, €0.30m, was transferred from share capital to
the capital redemption reserve with the total repurchase amount of €1m being deducted from retained earnings in addition to €1m of related transaction costs. The
number of ordinary shares in issue at 31 December 2024 was 544,996,176 (31 December 2023: 545,589,119).
364
PTSB Group Holdings plc - Annual Report 2024
33. Share capital, reserves and other equity instruments (continued)
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.
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 and is disposed of by the end of the year.
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. €1m was transferred into the capital redemption reserve during 2024 as a result of the share buyback.
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.
€43m (31 December 2023: €43m) coupon interest on the AT1 securities was paid from this reserve during 2024.
Other equity instruments – (Non-distributable)
Additional Tier 1 securities
31 December
2024
31 December
2023
€m
€m
As at 1 January
368
368
Profit
43
43
AT1 coupon paid
(43)
(43)
Additional Tier 1 securities
368
368
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. The
Company may, at its sole discretion, redeem the AT1 securities in full on any day falling in the period commencing 26 October 2027 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. 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 a 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 of each year. The Company may, at 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. 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.
PTSB Group Holdings plc - Annual Report 2024
365
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
33. 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.
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 the securities rank behind the claims against the Group of all other subordinated and
unsubordinated creditors.
34. 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 2024
Revaluation
reserve Fair value reserve
Total
€m
€m
€m
Other comprehensive income/(expense) net of tax
Revaluation of property
(7)
-
(7)
Fair value reserve (equity instruments)
Change in fair value of equity instruments
-
3
3
Total other comprehensive income/(expense), net of tax
(7)
3
(4)
31 December 2023
Revaluation
reserve Fair value reserve
Total
€m
€m
€m
Other comprehensive income/(expense) net of tax
Revaluation of property
(7)
-
(7)
Fair value reserve (equity instruments)
Change in fair value of equity instruments
-
3
3
Total other comprehensive income/(expense), net of tax
(7)
3
(4)
366
PTSB Group Holdings plc - Annual Report 2024
35. 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 2024
Note
Held at
amortised
cost
At fair value
through OCI
At fair value
through
profit or loss
Designated
as fair value
hedges
Total carrying
value
Fair value
€m
€m
€m
€m
€m
€m
Financial assets
Cash at bank
12
72
-
-
-
72
72
Items in course of collection
12
23
-
-
-
23
23
Loans and advances to banks
13
2,202
-
-
-
2,202
2,202
Derivative financial instruments
14
-
-
-
59
59
59
Other assets
15
7
-
-
-
7
7
Debt securities
17
4,327
-
-
-
4,327
4,253
Equity securities
18
-
9
-
-
9
9
Loans and advances to customers
20
21,423
-
-
-
21,423
21,456
Financial liabilities
Deposits by banks
26
105
-
-
-
105
105
Customer accounts
27
24,120
-
-
-
24,120
24,062
Derivative financial instruments
14
-
-
-
-
-
-
Debt securities in issue
28
1,698
-
-
33
1,731
1,822
Other financial liabilities
29
129
-
-
-
129
129
Subordinated liabilities
31
252
-
-
5
257
250
31 December 2023
Note
Held at
amortised
cost
At fair value
through OCI
At fair value
through profit
or loss
Designated
as fair value
hedges
Total carrying
value
Fair value
€m
€m
€m
€m
€m
€m
Financial assets
Cash at bank
12
71
-
-
-
71
71
Items in course of collection
12
40
-
-
-
40
40
Loans and advances to banks
13
2,051
-
-
-
2,051
2,051
Derivative financial instruments
14
-
-
-
36
36
36
Other assets
15
60
-
-
-
60
60
Debt securities
17
3,256
-
-
-
3,256
3,137
Equity securities
18
-
5
-
-
5
5
Loans and advances to customers
20
21,427
-
-
-
21,427
21,343
Financial liabilities
Deposits by banks
26
398
-
-
-
398
398
Customer accounts
27
22,966
-
-
-
22,966
22,907
Derivative financial instruments
14
-
-
1
-
1
1
Debt securities in issue
28
1,498
-
-
14
1,512
1,593
Other financial liabilities
29
148
-
-
-
148
148
Subordinated liabilities
31
252
-
-
5
257
240
PTSB Group Holdings plc - Annual Report 2024
367
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
35. Measurement basis and fair values of financial instruments (continued)
The following table sets out the fair value of financial instruments that the Group holds at 31 December 2024. 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.
Basis and fair values of financial instruments
31 December 2024
Note
Total carrying
value
Level 1
Level 2
Level 3
Total fair value
€m
€m
€m
€m
€m
Financial assets
Cash at bank
12
72
72
-
-
72
Items in course of collection
12
23
-
23
-
23
Loans and advances to banks
13
2,202
-
2,202
-
2,202
Derivative financial instruments
14
59
-
59
-
59
Debt securities
17
4,327
4,145
108
-
4,253
Equity securities
18
9
7
-
2
9
Loans and advances to customers
20
21,423
-
-
21,456
21,456
Financial liabilities
Deposits by banks
26
105
-
105
-
105
Customer accounts
27
24,120
-
24,062
-
24,062
Derivative financial instruments
14
-
-
-
-
-
Debt securities in issue
28
1,731
-
1,822
-
1,822
Other financial liabilities
29
129
-
129
-
129
Subordinated liabilities
31
257
-
250
-
250
31 December 2023
Note
Total carrying
value
Level 1
Level 2
Level 3
Total fair value
€m
€m
€m
€m
Financial assets
Cash at bank
12
71
71
-
-
71
Items in course of collection
12
40
-
40
-
40
Loans and advances to banks
13
2,051
-
2,051
-
2,051
Derivative financial instruments
14
36
-
36
-
36
Debt securities
17
3,256
3,137
-
-
3,137
Equity securities
18
5
-
-
5
5
Loans and advances to customers
20
21,427
-
-
21,343
21,343
Financial liabilities
Deposits by banks
26
398
-
398
-
398
Customer accounts
27
22,966
-
22,907
-
22,907
Derivative financial instruments
14
1
-
1
-
1
Debt securities in issue
28
1,512
-
1,593
-
1,593
Other financial liabilities
29
148
-
148
-
148
Subordinated liabilities
31
257
-
240
-
240
368
PTSB Group Holdings plc - Annual Report 2024
35. 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 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 2024 are €4,327m (31 December 2023: €3,256m) and consist of HTC securities. HTC securities are derived
from observable inputs through independent pricing sources such as Bloomberg.
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 carrying 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 derived from observable inputs through independent pricing sources such
as Bloomberg. All instruments are hedged for interest rate risk. Further details on hedging are included in note 14 of the financial statements.
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. The fair values of debt securities in issue and subordinated liabilities include the fair value hedge adjustment in
relation to interest rate swaps. Since 2023, due to changes in market conditions, quoted prices in active markets are no longer available for
these instruments. However, there is sufficient information available to measure the fair value of these instruments based on observable
market inputs. Therefore, debt securities in issue and subordinated liabilities are now classified as Level 2 in the fair value hierarchy.
PTSB Group Holdings plc - Annual Report 2024
369
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
35. 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. Derivative financial instruments are fair valued through profit or loss.
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 sources 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 2024. The Series A preferred stock was issued from Visa
Inc during 2024 upon the conversion of Series B preferred stock. At 31 December 2024, PTSB Group holds Series A preferred stock with a
value of €7m and Series B preferred stock with a value of €2m in Visa Inc (31 December 2023: €5m Series B preferred stock). This is
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
31 December 2024
Note
Level 1
Level 2
Level 3
Total
€m
€m
€m
€m
Financial assets measured at fair value
Derivative financial instrument
14
-
59
-
59
Equity instruments
18
7
-
2
9
Financial liabilities measured at fair value
Derivative financial instrument
14
-
-
-
-
31 December 2023
Note
Level 1
Level 2
Level 3
Total
€m
€m
€m
€m
Financial assets measured at fair value
Derivative financial instrument
14
-
36
-
36
Equity instruments
18
-
-
5
5
Financial liabilities measured at fair value
Derivative financial instrument
14
-
1
-
1
Reconciliation of level 3 fair value measurements of financial assets
2024
2023
€m
€m
Equity Instruments
As at 1 January
5
4
Revaluation movement in OCI – Fair value reserve (equity instruments)
4
1
Conversion of Series B preferred stock to Series A preferred stock
(7)
-
As at 31 December
2
5
There were no transfers between level 1, level 2 or level 3 of the fair value hierarchy during 2024 or 2023 for financial assets except for the
conversion of Series B preferred stock to Series A preferred stock.
370
PTSB Group Holdings plc - Annual Report 2024
35. Measurement basis and fair values of financial instruments (continued)
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 2024 or 2023 for financial liabilities.
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 2024
Valuation technique
Significant
unobservable inputs
Range of estimates for
unobservable inputs
Fair value
€m
Ranges of estimates
changes in the fair
value
Visa Inc. Series B
Preferred Stock
Quoted market price
(Discounted)*
Final share
conversion rate
0 - 90%
2
0 – 90%
* Discount has been applied for illiquidity and the conversion rate variability of the Visa Inc. Series B Preferred stock.
31 December 2023
Valuation technique
Significant
unobservable
inputs
Range of estimates for
unobservable inputs
Fair value
€m
Ranges of estimates
changes in the fair
value
Visa Inc. Series B
Preferred Stock
Quoted market price
(Discounted)*
Final share conversion
rate
0 – 90%
5
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 B preferred stock
The Series B preferred stock was fair valued at €2m at 31 December 2024 (31 December 2023: €5m) and is 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 B preferred shares at 31 December 2024 and 31 December 2023. 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 B preferred stock is denominated in US dollars and is exposed to FX risk.
PTSB Group Holdings plc - Annual Report 2024
371
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. 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.
Note
31 December
2024
31 December
2023
€m
€m
Cash at bank
12
72
71
Items in course of collection
12
23
40
Loans and advances to banks (iii)
13
2,202
2,051
Derivative financial instruments (ii)
14
59
36
Other assets
15
7
60
Debt securities (i)
17
4,327
3,256
Loans and advances to customers (iv)
20
21,423
21,427
28,113
26,941
Commitments
41
1,618
1,380
29,731
28,321
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 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 2024 or at 31
December 2023, with the exception of the corporate bond.
31 December
2024
31 December
2023
€m
€m
Rating
Aaa
726
309
Aa1
292
30
Aa2
-
356
Aa3
2,116
1,578
A3
439
448
Baa1
599
432
Baa3
155
103
Total
4,327
3,256
372
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
The following table discloses, by country, the Group’s exposure to sovereign debt and corporate debt as at:
31 December
2024
31 December
2023
€m
€m
Country
Ireland
1,524
1,559
EU
658
309
Spain
599
432
France
578
356
Portugal
439
448
Austria
292
30
Italy
155
103
Belgium
82
19
Total
4,327
3,256
(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 all 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 Group manages its
collateral derivative positions with counterparties on a net basis. The uncollateralised derivative positions are held with investment grade
counterparties. The cumulative positive market value of derivative assets at 31 December 2024 was €59m (31 December 2023: €36m) which
relates to fair value hedge interest rate swaps used to hedge interest rate risk on fixed rate debt securities in issue. See note 14 for further
detail.
(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.
31 December
2024
31 December
2023
€m
€m
Rating
AAA
1,887
1,687
Aa1
23
-
Aa2
6
75
Aa3
125
231
A1
90
2
A2
71
56
Total
2,202
2,051
PTSB Group Holdings plc - Annual Report 2024
373
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. 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, consumer
finance and finance leases and hire purchase receivables.
31 December
2024
31 December
2023
Measured at amortised cost
€m
€m
Residential mortgages:
Home loan
19,539
19,557
Buy-to-let
464
749
Total residential mortgages
20,003
20,306
Commercial
493
437
Consumer finance
553
499
Finance leases and hire purchase receivables
466
446
Total measured at amortised cost
21,515
21,688
Analysed by ECL staging:
Stage 1
19,100
19,057
Stage 2
2,033
1,913
Stage 3
382
718
POCI
-
-
Total measured at amortised cost
21,515
21,688
Of which at the reporting date
Neither past due nor Stage 3
21,081
20,909
Past due but not Stage 3
52
61
Stage 3
382
718
Total measured at amortised cost
21,515
21,688
Of which are reported as non-performing loans
382
718
Deferred fees, discounts and business combination related fair value adjustments
300
309
The following tables provide an aged analysis of home loan, buy-to-let and commercial mortgages which are past due but not Stage 3.
31 December 2024
Home loans
Buy-to-let
Commercial
Total
€m
€m
€m
€m
0-30 days
24
1
2
27
31-60 days
4
-
-
4
61-90 days
7
-
-
7
Total past due not Stage 3
35
1
2
38
Fair value of collateral held
35
1
2
38
374
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
Home loans
Buy-to-let
Commercial
Total
Fair value of collateral held
€m
€m
€m
€m
0-30 days
24
1
2
27
31-60 days
4
-
-
4
61-90 days
7
-
-
7
Total past due not Stage 3
35
1
2
38
31 December 2023
Home loans
Buy-to-let
Commercial
Total
€m
€m
€m
€m
0-30 days
29
3
1
33
31-60 days
7
3
1
11
61-90 days
6
-
-
6
Total past due not Stage 3
42
6
2
50
Fair value of collateral held
42
6
2
50
Fair value of collateral held
Home loans
Buy-to-let
Commercial
Total
€m
€m
€m
€m
0-30 days
29
3
1
33
31-60 days
7
3
1
11
61-90 days
6
-
-
6
Total past due not Stage 3
42
6
2
50
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.
PTSB Group Holdings plc - Annual Report 2024
375
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
Non-performing assets are defined as NPLs plus foreclosed assets.
31 December 2024
Stage 3
Home loans
Buy-to-let
Commercial
Consumer
finance
Finance leases
and hire purchase
receivables
Total
€m
€m
€m
€m
€m
€m
NPL is < 90 days
113
29
17
6
4
169
NPL is > 90 days and < 1 year past
due
55
10
-
4
2
71
NPL is 1-2 years past due
34
11
2
2
1
50
NPL is 2-5 years past due
30
12
1
3
1
47
NPL is > 5 years past due
27
9
4
5
-
45
POCI
-
-
-
-
-
-
Non-performing loans
259
71
24
20
8
382
Foreclosed assets
2
5
-
-
-
7
Non-performing assets
261
76
24
20
8
389
NPLs as % of gross loans
1.3%
15.3%
4.9%
3.6%
1.7%
1.8%
31 December 2023
Stage 3
Home loans
Buy-to-let
Commercial
Consumer
finance
Finance leases
and hire purchase
receivables
Total
€m
€m
€m
€m
€m
€m
NPL is < 90 days
167
86
11
4
6
274
NPL is > 90 days and < 1 year past
due
77
51
2
4
4
138
NPL is 1-2 years past due
44
16
1
2
1
64
NPL is 2-5 years past due
60
86
1
2
1
150
NPL is > 5 years past due
55
28
5
4
-
92
POCI
-
-
-
-
-
-
Non-performing loans
403
267
20
16
12
718
Foreclosed assets
2
9
-
-
-
11
Non-performing assets
405
276
20
16
12
729
NPLs as % of gross loans
2.1%
35.6%
4.6%
3.2%
2.7%
3.3%
Non-performing loans as a percentage of total loans and advances was 1.8% at 31 December 2024, down from 3.3% at 31 December 2023,
primarily attributed to the Glas III loan sale.
Total portfolio loss allowance: statement of financial position
The tables below outline the ECL loss allowance total at 31 December 2024 in respect of total customer loans and advances.
The impairment write-back in respect of the total loans and advances for year ended 31 December 2024 was €30m, compared to a €56m
charge for the year ended 31 December 2023.
31 December
2024
31 December
2023
€m
€m
Loss allowance - statement of financial position
Stage 1
123
165
Stage 2
134
164
Stage 3
135
241
Total loss allowance
392
570
376
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
31 December
2024
31 December
2023
%
%
Provision coverage ratio*
Stage 1
0.6%
0.9%
Stage 2
6.6%
8.6%
Stage 3
35.4%
33.5%
Total provisions/total loans
1.8%
2.6%
* 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 8% (31 December 2023: 9%) of the residential mortgage portfolio originated before 2006. Between
2006 and 2008 origination was €3bn or 17% (31 December 2023: 21%) of the residential mortgages. The remaining 75% (31 December 2023:
70%) of residential mortgages were originated between 2009 and 2024.
31 December 2024
Residential mortgages portfolio
Stage 3 residential mortgages
portfolio
Number
Balance
Number
Balance
€m
€m
2001 and before
4,110
91
251
7
2002
2,549
93
112
5
2003
4,077
191
149
11
2004
6,125
386
173
13
2005
10,033
793
332
34
2006
12,520
1,326
496
76
2007
10,755
1,276
452
79
2008
6,776
779
279
42
2009
2,056
190
61
6
2010
852
58
14
1
2011
731
58
7
1
2012
1,143
98
13
1
2013
1,549
143
17
2
2014
2,646
263
14
2
2015
3,709
397
38
3
2016
4,362
557
38
5
2017
5,348
763
42
7
2018
6,911
1,116
56
8
2019
8,863
1,564
60
10
2020
7,394
1,475
47
6
2021
8,349
1,859
31
5
2022
9,415
2,416
14
3
2023
8,291
2,173
9
2
2024
7,047
1,938
4
1
Total
135,611
20,003
2,709
330
PTSB Group Holdings plc - Annual Report 2024
377
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
31 December 2023
Residential mortgages portfolio
Stage 3 residential mortgages
portfolio
Number
Balance
Number
Balance
€m
€m
2000 and before
3,055
64
253
8
2001
2,004
60
114
4
2002
2,811
116
139
8
2003
4,443
232
219
16
2004
7,579
471
278
25
2005
11,015
943
454
61
2006
13,837
1,624
753
174
2007
11,944
1,591
773
209
2008
7,407
925
452
97
2009
2,311
212
73
8
2010
914
66
22
2
2011
789
65
9
1
2012
1,225
108
18
1
2013
1,638
158
17
2
2014
2,877
294
26
4
2015
3,949
442
52
4
2016
4,665
617
46
7
2017
5,642
843
49
6
2018
7,352
1,239
71
11
2019
9,408
1,735
64
12
2020
7,820
1,624
39
5
2021
9,065
2,135
20
3
2022
9,618
2,539
8
1
2023
8,394
2,203
4
1
Total
139,762
20,306
3,953
670
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.
378
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
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 residential mortgage portfolios is 48% at 31 December 2024 compared to 52% at 31
December 2023.
31 December 2024
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
54%
51%
54%
50% to 70%
33%
26%
33%
71% to 90%
13%
11%
12%
91% to 100%
-
4%
1%
Subtotal
100%
92%
100%
101% to 110%
-
2%
-
111% to 120%
-
2%
-
121% to 130%
-
1%
-
131% to 140%
-
-
-
141% to 150%
-
1%
-
151% to 160%
-
-
-
161% to 170%
-
-
-
171% to 180%
-
-
-
Greater than 180%
-
2%
-
Subtotal
-
8%
-
Total
100%
100%
100%
Weighted average LTV:
Stock of residential mortgages at year end
48%
56%
48%
Residential mortgages originated in the year
68%
51%
68%
Acquired residential mortgages
-
-
-
Stage 3 mortgages
53%
106%
64%
PTSB Group Holdings plc - Annual Report 2024
379
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
31 December 2023
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
45%
33%
45%
50% to 70%
38%
23%
37%
71% to 90%
16%
18%
16%
91% to 100%
-
8%
1%
Subtotal
99%
82%
99%
101% to 110%
1%
6%
1%
111% to 120%
-
2%
-
121% to 130%
-
3%
-
131% to 140%
-
2%
-
141% to 150%
-
1%
-
151% to 160%
-
1%
-
161% to 170%
-
1%
-
171% to 180%
-
-
-
Greater than 180%
-
2%
-
Subtotal
1%
18%
1%
Total
100%
100%
100%
Weighted average LTV:
Stock of existing residential mortgages
52%
70%
52%
Residential mortgages originated in the year
69%
55%
69%
Acquired residential mortgages
47%
41%
47%
Stage 3 mortgages
68%
100%
81%
Analysis by LTV of the Group’s residential mortgage lending which is neither past due nor Stage 3:
The tables below illustrate that 100% of residential home loan mortgages (31 December 2023: 100%) and 97% of residential buy-to-let
mortgages (31 December 2023: 95%) that are neither past due nor stage 3 are in positive equity as at 31 December 2024.
31 December 2024
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
54%
58%
54%
50% to 70%
33%
28%
33%
71% to 90%
13%
9%
13%
91% to 100%
-
2%
-
Subtotal
100%
97%
100%
101% to 110%
-
2%
-
111% to 120%
-
1%
-
121% to 130%
-
-
-
131% to 140%
-
-
-
141% to 150%
-
-
-
151% to 160%
-
-
-
161% to 170%
-
-
-
171% to 180%
-
-
-
Greater than 180%
-
-
-
Subtotal
-
3%
-
Total
100%
100%
100%
380
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
31 December 2023
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
46%
48%
46%
50% to 70%
38%
29%
38%
71% to 90%
16%
14%
16%
91% to 100%
-
4%
-
Subtotal
100%
95%
100%
101% to 110%
-
2%
-
111% to 120%
-
1%
-
121% to 130%
-
-
-
131% to 140%
-
1%
-
141% to 150%
-
-
-
151% to 160%
-
-
-
161% to 170%
-
-
-
171% to 180%
-
-
-
Greater than 180%
-
1%
-
Subtotal
-
5%
-
Total
100%
100%
100%
Analysis by LTV of the Group’s residential mortgage lending which are classified as Stage 3:
The tables below illustrate that 92% of residential home loan mortgages (31 December 2023: 83%) and 68% of residential buy-to-let
mortgages (31 December 2023: 60%) that are classified as Stage 3 are in positive equity as at 31 December 2024.
31 December 2024
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
54%
12%
45%
50% to 70%
26%
18%
24%
71% to 90%
10%
21%
12%
91% to 100%
2%
17%
6%
Subtotal
92%
68%
87%
101% to 110%
2%
6%
3%
111% to 120%
2%
8%
3%
121% to 130%
1%
3%
1%
131% to 140%
-
1%
1%
141% to 150%
1%
1%
1%
151% to 160%
-
1%
-
161% to 170%
-
1%
-
171% to 180%
-
1%
-
Greater than 180%
2%
10%
4%
Subtotal
8%
32%
13%
Total
100%
100%
100%
€m
€m
€m
Stage 3
259
71
330
PTSB Group Holdings plc - Annual Report 2024
381
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
31 December 2023
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
38%
7%
26%
50% to 70%
24%
11%
19%
71% to 90%
15%
26%
19%
91% to 100%
6%
16%
10%
Subtotal
83%
60%
74%
101% to 110%
3%
13%
7%
111% to 120%
3%
6%
4%
121% to 130%
2%
8%
4%
131% to 140%
1%
2%
2%
141% to 150%
2%
2%
2%
151% to 160%
2%
2%
2%
161% to 170%
1%
2%
1%
171% to 180%
-
1%
1%
Greater than 180%
3%
4%
3%
Subtotal
17%
40%
26%
Total
100%
100%
100%
€m
€m
€m
Stage 3
403
267
670
(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.
Stock of collateral in possession
31 December 2024
31 December 2023
Number
Balance
outstanding at
transfer of
ownership
Number
Balance
outstanding at
transfer of
ownership
Residential collateral in possession
€m
€m
Home loans
8
5
10
6
Buy-to-let
30
7
52
13
Total
38
12
62
19
Collateral in possession assets are sold as soon as practicable. These assets which total €7m as at 31 December 2024 (31 December 2023:
€11m) are included in assets held for sale (see note 16 for further details).
During the year no ownership of properties were transferred to the Group.
31 December 2024
Number of
disposals
Balance
outstanding at
transfer of
ownership
Gross sales
proceeds
Costs to sell
Pre
provisioning
loss on sale*
€m
€m
€m
€m
Collateral in possession
Home loans
2
1
1
-
-
Buy-to-let
22
6
4
-
2
Year ended 31 December 2024
24
7
5
-
2
* 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.
382
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
31 December 2023
Number of
disposals
Balance
outstanding at
transfer of
ownership
Gross sales
proceeds
Costs to sell
Pre
provisioning
loss on sale*
€m
€m
€m
€m
Collateral in possession
Home loans
4
1
2
1
-
Buy-to-let
57
16
10
-
6
Year ended 31 December 2023
61
17
12
1
6
* 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.
(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 analyse loans for which the Group has entered formal temporary and permanent forbearance arrangements with customers
for the years ended 31 December 2024 and 2023.
(a) Weighted Average - LTV
LTV on total residential mortgages in forbearance
The tables below illustrate that 94% of residential home loan mortgages (31 December 2023: 89%) and 75% of residential buy-to-let
mortgages (31 December 2023: 73%) that are in forbearance are in positive equity as at 31 December 2024.
31 December 2024
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
54%
16%
49%
50% to 70%
27%
18%
26%
71% to 90%
10%
26%
12%
91% to 100%
3%
15%
4%
Subtotal
94%
75%
91%
101% to 110%
1%
3%
2%
111% to 120%
2%
9%
2%
121% to 130%
1%
3%
1%
131% to 140%
-
1%
1%
141% to 150%
1%
1%
1%
151% to 160%
-
2%
-
161% to 170%
-
1%
-
171% to 180%
-
-
-
Greater than 180%
1%
5%
2%
Subtotal
6%
25%
9%
Total
100%
100%
100%
Weighted average LTV:
Stock of residential mortgages
52%
85%
57%
Residential mortgages originated in the year
72%
-
72%
Stage 3 mortgages
58%
94%
64%
PTSB Group Holdings plc - Annual Report 2024
383
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
31 December 2023
Home loans
Buy-to-let
Total
%
%
%
Less than 50%
42%
10%
37%
50% to 70%
29%
13%
26%
71% to 90%
13%
36%
17%
91% to 100%
5%
14%
6%
Subtotal
89%
73%
86%
101% to 110%
2%
10%
3%
111% to 120%
2%
3%
2%
121% to 130%
1%
3%
2%
131% to 140%
1%
2%
2%
141% to 150%
1%
2%
1%
151% to 160%
1%
1%
1%
161% to 170%
1%
1%
1%
171% to 180%
-
1%
-
Greater than 180%
2%
4%
2%
Subtotal
11%
27%
14%
Total
100%
100%
100%
Weighted average LTV:
Stock of residential mortgages
61%
91%
66%
Residential mortgages originated in the year
66%
-
66%
Stage 3 mortgages
71%
99%
76%
(b) Forbearance arrangements - 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 2024 and 31 December 2023.
(i) Residential home loan mortgages:
The incidence of the main type of forbearance arrangements for owner occupied residential mortgages are analysed below:
31 December 2024
All loans
Stage 3
Number
Balances
Number
Balances
€m
€m
Interest only
8
1
6
1
Reduced payment (less than interest only)
32
6
26
4
Reduced payment (greater than interest only)
842
117
416
61
Payment moratorium
65
9
45
6
Arrears capitalisation
550
59
348
38
Term extension
355
25
178
13
Hybrid*
150
15
118
12
Split mortgages**
74
10
74
10
Total
2,076
242
1,211
145
* Hybrid is a combination of two or more forbearance arrangements.
** Split mortgage is where a portion of outstanding debt is deferred until financial ability or circumstances improve.
384
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
31 December 2023
All loans
Stage 3
Number
Balances
Number
Balances
€m
€m
Interest only
19
4
17
3
Reduced payment (less than interest only)
47
8
32
6
Reduced payment (greater than interest only)
1,362
193
672
105
Payment moratorium
48
7
33
4
Arrears capitalisation
821
88
419
49
Term extension
481
34
232
19
Hybrid*
238
33
178
24
Split mortgages**
158
26
158
26
Total
3,174
393
1,741
236
* Hybrid is a combination of two or more forbearance arrangements.
** Split mortgage is where a portion of outstanding debt is deferred until financial ability or circumstances improve.
The tables above reflect a decrease of 1,098 cases in the year to 31 December 2024 for the Group in the number of residential home loan
mortgages in forbearance arrangements, a decrease of €151m in balances. The average balance of forborne loans is €0.117m at 31 December
2024 (31 December 2023: €0.124m).
(ii) Residential buy-to-let mortgages:
The incidence of the main type of forbearance arrangements for residential buy-to-let mortgages are analysed below:
31 December 2024
All loans
Stage 3
Number
Balances
Number
Balances
€m
€m
Interest only
6
3
5
3
Reduced payment (less than interest only)
2
1
2
1
Reduced payment (greater than interest only)
46
11
34
9
Payment moratorium
4
1
4
1
Arrears capitalisation
10
3
7
2
Term extension
16
3
10
2
Hybrid*
34
11
24
7
Split mortgages**
4
1
4
1
Total
122
34
90
26
* Hybrid is a combination of two or more forbearance arrangements.
** Split mortgage is where a portion of outstanding debt is deferred until financial ability or circumstances improve.
PTSB Group Holdings plc - Annual Report 2024
385
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
31 December 2023
All loans
Stage 3
Number
Balances
Number
Balances
€m
€m
Interest only
16
6
14
6
Reduced payment (less than interest only)
2
2
2
2
Reduced payment (greater than interest only)
82
25
61
21
Payment moratorium
3
1
1
-
Arrears capitalisation
24
6
10
3
Term extension
16
4
12
3
Hybrid*
61
28
46
19
Split mortgages**
22
7
22
7
Total
226
79
168
61
* Hybrid is a combination of two or more forbearance arrangements.
** Split mortgage is where a portion of outstanding debt is deferred until financial ability or circumstances improve.
The tables above reflect a decrease of 104 cases in the year to 31 December 2024 for the Group in the number of residential buy-to-let in
forbearance arrangements, a decrease of €45m in balances. The average balance of forborne loans is €0.279m at 31 December 2024 (31
December 2023: €0.350m).
(iii) Commercial mortgages
The incidence of the main type of forbearance arrangements for commercial mortgages are analysed below:
31 December 2024
31 December 2023
Number
Balances
Number
Balances
€m
€m
Commercial mortgages
Interest only
1
-
-
-
Reduced payment (greater than interest only)
4
1
7
3
Payment moratorium
-
-
-
-
Arrears capitalisation
11
1
24
2
Term extension
5
1
7
1
Hybrid*
2
1
4
1
Split mortgages
-
-
-
-
Total
23
4
42
7
* Hybrid is a combination of two or more forbearance arrangements.
The table above reflects a decrease of 19 cases in the year to 31 December 2024 for the Group in the number of commercial mortgages in
forbearance arrangements, a decrease of €3m in balances.
(c) 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.
386
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
(i) Reconciliation of movement of total forborne loans
Residential mortgages
Home loans
cases
Home loans
balances
Buy -to-let
cases
Buy-to-let
balances
Commercial
cases
Commercial
balances
Total cases
Total
balances
31 December 2024
€m
€m
€m
€m
Opening balance 1 January
2024
3,174
393
226
79
42
7
3,442
479
New forbearance extended
during the year*
310
37
17
3
2
1
329
41
Deleveraged loans
(543)
(83)
(81)
(33)
(4)
(1)
(628)
(117)
Exited forbearance
- re-classified to Stage 3
non-forborne
(5)
(1)
(1)
-
-
-
(6)
(1)
- expired forbearance
treatment
(749)
(77)
(23)
(5)
(12)
(1)
(784)
(83)
- expired loan paid down
(111)
(17)
(16)
(9)
(5)
(2)
(132)
(28)
Balance shift**
-
(10)
-
(1)
-
-
-
(11)
Closing balance of loans in
forbearance as at 31
December 2024
2,076
242
122
34
23
4
2,221
280
* 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.
Residential mortgages
Home loans
cases
Home loans
balances
Buy -to-let
cases
Buy-to-let
balances
Commercial
cases
Commercial
balances
Total cases
Total
balances
31 December 2023
€m
€m
€m
€m
Opening balance 1 January
2023
2,747
358
256
99
25
8
3,028
465
New forbearance extended
during the year*
1,133
118
35
7
23
1
1,191
126
Deleveraged loans
-
-
-
-
-
-
-
-
Exited forbearance
- re-classified to Stage 3
non-forborne
(24)
(3)
(4)
(3)
(1)
-
(29)
(6)
- expired forbearance
treatment
(450)
(52)
(30)
(15)
(2)
(1)
(482)
(68)
- expired loan paid down
(232)
(18)
(31)
(6)
(3)
-
(266)
(24)
Balance shift**
-
(10)
-
(3)
-
(1)
-
(14)
Closing balance of loans in
forbearance as at 31
December 2023
3,174
393
226
79
42
7
3,442
479
* 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.
PTSB Group Holdings plc - Annual Report 2024
387
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
(ii) Reconciliation of movement in forborne loans Stage 3
Home loan
cases
Home loan
balances
Buy-to-let
cases
Buy-to-let
balances
Commercial
cases
Commercial
balances
Total cases
Total
balances
31 December 2024
€m
€m
€m
€m
Opening balance 1 January
2024
1,741
236
168
61
27
6
1,936
303
New Stage 3 forborne
extended during the year*
319
38
18
5
2
1
339
44
Deleveraged loans
(542)
(83)
(81)
(33)
(4)
(1)
(627)
(117)
Exited forborne Stage 3,
now performing forborne
(272)
(30)
(9)
(2)
(3)
-
(284)
(32)
Exited forbearance
- exited forborne Stage 3,
now Stage 3 non-forborne
(3)
(1)
-
-
-
-
(3)
(1)
- expired forbearance
treatment
(11)
-
-
-
-
-
(11)
-
- expired loan paid down
(21)
(11)
(6)
(5)
(4)
(2)
(31)
(18)
Balance shift**
-
(4)
-
-
-
-
-
(4)
Closing balance of loans in
forbearance as at 31
December 2024
1,211
145
90
26
18
4
1,319
175
* 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.
Home loan
cases
Home loan
balances
Buy-to-let
cases
Buy-to-let
balances
Commercial
cases
Commercial
balances
Total cases
Total
balances
31 December 2023
€m
€m
€m
€m
Opening balance 1 January
2023
1,634
228
188
68
19
6
1,841
302
New Stage 3 forborne
extended during the year*
615
69
30
11
12
-
657
80
Deleveraged loans
-
-
-
-
-
-
-
-
Exited forborne Stage 3,
now performing forborne
(352)
(43)
(21)
(11)
-
-
(373)
(54)
Exited forbearance
- exited forborne Stage 3,
now Stage 3 non-forborne
(12)
(1)
-
-
(1)
-
(13)
(1)
- expired forbearance
treatment
(13)
(3)
(4)
(2)
(1)
-
(18)
(5)
- expired loan paid down
(131)
(12)
(25)
(5)
(2)
-
(158)
(17)
Balance shift**
-
(2)
-
-
-
-
-
(2)
Closing balance of loans in
forbearance as at 31
December 2023
1,741
236
168
61
27
6
1,936
303
* 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.
388
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
(vii) Funding profile
The below amounts for non-derivative financial liabilities is calculated using undiscounted cash flows which include an estimate of future
interest payments. Derivative liabilities include contractual undiscounted cash flows on a gross basis if the instrument is settled gross and on a
net basis if settled net.
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 2024 can be broken down into the below component parts:
31 December
2024
31 December
2023
%
%
Customer accounts
91
91
Long-term debt
8
7
Short-term debt
1
2
100
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.
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 2024
Up to
1-3
3-6
6-12
1-2
Over 2
1 month
months
months
months
years
years
Total
€m
€m
€m
€m
€m
€m
€m
Liabilities
Deposits by banks
105
-
-
-
-
-
105
Customer accounts
18,051
1,593
949
2,031
967
631
24,222
Debt securities in issue
8
16
24
49
97
1,864
2,058
Derivative financial instruments
-
-
-
-
-
-
-
Subordinated liabilities
1
1
2
4
7
285
300
Other financial liabilities
95
-
2
3
6
25
131
Total liabilities
18,260
1,610
977
2,087
1,077
2,805
26,816
31 December 2023
Up to
1-3
3-6
6-12
1-2
Over 2
1 month
months
months
months
years
years
Total
€m
€m
€m
€m
€m
€m
€m
Liabilities
Deposits by banks
398
-
-
-
-
-
398
Customer accounts
19,640
664
415
864
671
764
23,018
Debt securities in issue
8
15
23
46
384
1,366
1,842
Derivative financial instruments
1
-
-
-
-
-
1
Subordinated liabilities
1
1
2
4
7
292
307
Other financial liabilities
115
-
2
3
5
25
150
Total liabilities
20,163
680
442
917
1,067
2,447
25,716
PTSB Group Holdings plc - Annual Report 2024
389
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
36. Financial risk management (continued)
The maturity analysis for credit commitments and guarantees are presented in Note 41.
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.
31 December
2024
Up to
1-3
3-6
6-12
1-2
Over 2
1 month
months
months
months
years
years
Total
€m
€m
€m
€m
€m
€m
€m
Gross settled:
FX forwards
- inflow
52
-
-
-
-
-
52
- outflow
(52)
-
-
-
-
-
(52)
Balance at 31
December 2024
-
-
-
-
-
-
-
31 December
2023
Up to
1-3
3-6
6-12
1-2
Over 2
1 month
months
months
months
years
years
Total
€m
€m
€m
€m
€m
€m
€m
Gross settled:
FX forwards
- inflow
58
-
-
-
-
-
58
- outflow
(59)
-
-
-
-
-
(59)
Balance at 31
December 2023
(1)
-
-
-
-
-
(1)
(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
2024 IRRBB (Interest Rate Risk in the Banking Book) 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 interest until the end of the fixed rate period for fixed rate products. The Non-maturity Deposits
are assumed to have a maximum behavioural maturity of 7 years.
A summary of the Group’s interest rate gap position is as follows:
Interest rate re-pricing
31 December 2024
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
Total
€m
€m
€m
€m
€m
€m
Assets
10,261
1,156
2,494
13,437
2,314
29,662
Liabilities
(6,347)
(1,657)
(3,650)
(13,491)
(4,367)
(29,512)
Derivatives
(1,843)
51
-
2,049
-
257
Interest rate re-pricing gap
2,071
(450)
(1,156)
1,995
(2,053)
407
Cumulative interest rate re-
pricing gap
2,071
1,621
465
2,460
407
390
PTSB Group Holdings plc - Annual Report 2024
36. Financial risk management (continued)
31 December 2023
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
Total
€m
€m
€m
€m
€m
€m
Assets
9,806
999
2,224
13,574
2,018
28,621
Liabilities
(6,438)
(1,152)
(2,434)
(13,420)
(4,570)
(28,014)
Derivatives
(1,155)
343
-
978
-
166
Interest rate re-pricing gap
2,213
190
(210)
1,132
(2,552)
773
Cumulative interest rate re-pricing
gap
2,213
2,403
2,193
3,325
773
Sensitivity analysis
The following table outlines the sensitivity of the Bank’s NII to a change in interest rates. The NII sensitivity is calculated on a constant balance
sheet basis in line with the EBA Guidelines on Interest Rate Risk in the Banking Book (EBA 2022/03).
31 December 2024
100bps
200bps
m
m
Upwards
19
38
Downwards
(14)
(29)
31 December 2023
100bps
200bps
m
m
Upwards
32
65
Downwards
(31)
(62)
37. 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 an established 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 Board has overall responsibility for the
completeness and implementation of the ICAAP. The ICAAP is subject to review and evaluation by the Regulator.
The management of capital within the Group is monitored on an ongoing basis by the Board and various Executive Committees in accordance
with Board approved policy.
The Group’s regulatory capital comprises of three Tiers:
• CET1 Capital, consisting of 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;
• Tier 1 Capital, consisting of CET1 capital and qualifying convertible perpetual financial instruments with discretionary coupons; and
• Total Capital, consisting of Tier 1 capital and qualifying subordinated liabilities, revaluation reserves and other regulatory capital adjustments.
The Group’s 31 December 2024 regulatory Pillar 2 Requirement (P2R) remains at 3.25% (31 December 2023: 3.25%).
PTSB Group Holdings plc - Annual Report 2024
391
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
37. Capital management (continued)
The Group’s 31 December 2024 regulatory CET1 capital requirement is 10.33% (31 December 2023: 9.83%). The CET1 ratio requirement of
10.33% consists of Pillar 1 minimum requirement of 4.50% (31 December 2023: 4.50%), P2R of 1.83%* (31 December 2023: 1.83%), Capital
Conservation Buffer (CCB) of 2.50% (31 December 2023: 2.50%) and Countercyclical Buffer (CCyB) of 1.5% (31 December 2023: 1.0%).
The Group’s Total Capital requirement of 15.25% at 31 December 2024 (31 December 2023: 14.75%) consists of Pillar 1 minimum requirement
of 8% (31 December 2023: 8%), P2R of 3.25% (31 December 2023: 3.25%), CCB of 2.50% (31 December 2023: 2.50%) and CCyB of 1.50% (31
December 2023: 1.0%).
An Other Systemically Important Institution (O-SII) buffer of 0.5% is effective 1 January 2025, increasing CET1 and Total Capital regulatory
requirements to 10.83% and 15.75% respectively.
These requirements exclude Pillar 2 Guidance (P2G) which is not publicly disclosed.
* 56.25% of P2R must be made up of CET1
38. Current/non-current assets and liabilities
The following table provides an analysis of certain asset and liability line items as at 31 December 2024 and 31 December 2023. 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 2024
31 December 2023
Note
Current
Non-current
Total
Current
Non-current
Total
€m
€m
€m
€m
€m
€m
Assets
Cash and balances at central banks
12
72
-
72
71
-
71
Items in the course of collection
12
23
-
23
40
-
40
Loans and advances to banks
13
2,202
-
2,202
2,051
-
2,051
Derivative financial instruments
14
-
59
59
6
30
36
Other assets
15
7
-
7
60
-
60
Assets classified as held for sale
16
12
-
12
12
-
12
Debt securities
17
138
4,189
4,327
190
3,066
3,256
Equity securities
18
-
9
9
-
5
5
Prepayments and contract assets
19
63
-
63
80
-
80
Loans and advance to customers
20
2,685
18,738
21,423
2,775
18,652
21,427
Liabilities
Deposits by banks including central banks
26
105
-
105
398
-
398
Customer accounts
27
22,557
1,563
24,120
21,558
1,408
22,966
Derivative financial instruments
14
-
-
-
1
-
1
Debt securities in issue
28
56
1,675
1,731
54
1,458
1,512
Other liabilities
29
100
29
129
119
29
148
Accruals
12
-
12
13
-
13
Provisions
30
13
33
46
13
27
40
Subordinated liabilities
31
3
254
257
3
254
257
39. 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 and debt securities. 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.
392
PTSB Group Holdings plc - Annual Report 2024
39. Transfer of financial assets (continued)
(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 20) and debt securities (note 17) 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 2024 is €65m (31 December 2023: €380m).
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. Therefore, the Group is exposed to substantially all the risks and rewards of ownership including credit and market risk of the
transferred assets.
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 2024
31 December 2023
Sale and
repurchase
agreements
Securitisations
Sale and
repurchase
agreements
Securitisations
€m
€m
€m
€m
Carrying amount of assets
377
-
530
-
Carrying amount of associated liabilities
365
-
382
-
Liabilities that have recourse only to the transferred financial assets
Fair value of assets
371
-
529
-
Fair value of associated liabilities
365
-
382
-
Net position
6
-
147
-
(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.
PTSB Group Holdings plc - Annual Report 2024
393
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
40. 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 instruments 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.
The tables below also provide analysis of derivative financial assets and liabilities and repurchase and reverse repurchase agreements subject
to offsetting, enforceable master netting agreements and global master repurchase agreements:
31 December 2024
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
Assets
Derivative financial instruments
59
-
59
-
(39)
20
Reverse Repurchase Agreements
300
(300)
-
-
(1)
(1)
359
(300)
59
-
(40)
19
Liabilities
Derivative financial instruments
-
-
-
-
-
-
Repurchase Agreements
365
(300)
65
(65)
-
-
365
(300)
65
(65)
-
-
31 December 2023
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
Assets
Derivative financial instruments
36
-
36
-
(16)
20
36
-
36
-
(16)
20
Liabilities
Derivative financial instruments
(1)
-
(1)
-
-
(1)
Repurchase Agreements
380
-
380
(126)
2
256
379
-
379
(126)
2
255
394
PTSB Group Holdings plc - Annual Report 2024
41. Commitments and Contingencies
The table below gives the contractual amounts of irrevocable capital 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
31 December
2024
31 December
2023
€m
€m
Guarantees and irrevocable letters of credit
2
2
Commitments to extend credit
- less than 1 year
1,573
1,333
- 1 year and over
43
45
Total commitments to extend credit
1,616
1,378
Total credit commitments
1,618
1,380
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 30, 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. If the Bank is required to make any reimbursements under these identified scenarios,
the impact on the financial statements could be material. Based on the facts currently known, it is not practicable at this time to predict the
final outcome this could have, nor the timing and possible impact on the Bank.
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 is involved in High
Court appeals against two FSPO decisions in tracker mortgage related complaints and, while the timing and outcome of the appeals is
uncertain, based on legal advice received, no provision has been made for these cases. However, if the Bank is unsuccessful in the appeals,
the impact on the financial statements could be material. Based on the facts currently known and the current stages that the legal process is
at, it is not practicable at this time to predict the final outcome of this litigation/FSPO complaints, nor the timing and possible impact on the
Bank. The Bank is aware that there are other legal proceedings on-going in which decisions of the FSPO, upholding customers’ claims to a
tracker interest rate on their mortgage, are being challenged. While the facts of each case differ, the Bank is keeping other cases under review
to see whether any issues raised in these other proceedings could have implications for the Bank’s on-going appeals and its position in
respect of whether there could be a liability to customers who have accounts which are similar to the accounts which are the subject of the
Bank’s appeals.
As at 31 December 2024 ECL of €4m (31 December 2023: €nil) held against loan commitments are recognised in Provisions (Note 30), except
where the loan commitment relates to a loan already recognised as a financial asset. In this case the ECL is recognised in Loans and advances
to customers.
On 1 July 2022, the Group invested in First Home Scheme Ireland DAC, along with the State, AIB and Bank of Ireland. The Group committed
€54m in funding to the First Home Scheme Ireland DAC. €20m was recognised in the Statement of Financial Position in respect of the scheme
as at 31 December 2024 (31 December 2023: €15m).
In late 2024, the Group announced the opening of a limited voluntary severance scheme. The applications have now closed and are currently
being evaluated. The estimated cost of the scheme is €25m. At 31 December 2024, the Group did not have a present obligation as
applications were still open and therefore it has not met the recognition criteria for a provision under IAS 37 and is not recognised on the SOFP.
PTSB Group Holdings plc - Annual Report 2024
395
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
42. 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
2024
31 December
2023
Ordinary
Ordinary
Position
shares
shares
Julie O’Neill
Chairperson
20,000
10,000
Eamonn Crowley
Chief Executive Officer
50,000
50,000
Nicola O’Brien (retired 29 August 2024)
Chief Financial Officer
-
-
Conor Ryan
Company Secretary
10
10
Ronan O’Neill
Non-Executive Director
-
4
Donal Courtney (retired 01 October 2024)
Non-Executive Director
-
-
Ruth Wandhöfer
Non-Executive Director
-
-
Marian Corcoran
Non-Executive Director
4,500
-
Paul Doddrell
Non-Executive Director
4,046
-
Celine Fitzgerald
Non-Executive Director
6,227
-
Anne Bradley
Non-Executive Director
6,227
-
Catherine Moroney
Non-Executive Director
7,462
-
Rick Gildea
Non-Executive Director
-
-
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 2023: 4,580).
There were no transactions in the above Directors’ and Secretary’s interests between 31 December 2024 and 3 March 2025.
Details of the Directors’ remuneration is included in the Directors’ Remuneration Report on pages 125 to 129.
(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 2024
Eamonn Crowley
Chief Executive
Barry D’Arcy
Chief Risk Officer
Patrick Farrell
Chief Retail Banking Officer
Tom Hayes
Chief Technology Officer
Ger Mitchell
Chief Customer and People Officer
Andrew Walsh
Chief Legal Counsel
Peter Vance
Chief Operations Officer
Leontia Fannin
Chief Sustainability and Corporate Affairs Officer
396
PTSB Group Holdings plc - Annual Report 2024
42. Related Parties (continued)
During the year ended 31 December 2024, the following key management personnel changes occurred;
Nicola O’Brien resigned as a member of ExCo and the Board on 29 August 2024 and Leontia Fannin was appointed Chief Sustainability and
Corporate Affairs Officer on 1 August 2024.
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:
31 December
2024
31 December
2023
Non-Executive Directors
9
10
Executive Directors and Senior Management
8
8
17
18
(b) (i) Total compensation to Executive and Non-Executive Directors is as follows:
Year ended
Year ended
31 December
2024
31 December
2023
€’000
€’000
Fees
1,038
1,063
Taxable benefits
3
4
Salary and other benefits
789
920
Loss of office payments*
172
-
Pension benefits
- defined contribution
140
158
Total
2,142
2,145
* Relates to payments to former CFO
Total compensation to other key management personnel is as follows:
Year ended
Year ended
31 December
2024
31 December
2023
€’000
€’000
Taxable benefits
4
9
Salary and other benefits
2,709
2,852
Pension benefits
- defined contribution
397
365
Total
3,110
3,226
There were no connected persons to key management personnel employed by the group during 2024 or 2023.
PTSB Group Holdings plc - Annual Report 2024
397
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
42. Related Parties (continued)
(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:
31 December
2024
31 December
2023
€’000
€’000
Balances
Loans
1,734
1,147
Unsecured credit card balances and overdrafts
48
8
Deposits
1,209
4,139
Year ended
Year ended
31 December
2024
31 December
2023
€’000
€’000
Transactions during the year
Loan advances
56
-
Loan repayments
302
56
Interest received on loans
46
45
Interest paid on deposits
(7)
(2)
Loans to Directors
31 December 2024
Balance as at 1
Jan
Advances during
the year
Principal repaid
Balance
as at
31 Dec
Interest paid
Maximum
balance
€’000
€’000
€’000
€’000
€’000
€’000
Ronan O’Neill*
629
250
13
866
27
879
Eamonn Crowley**
2
40
2
40
-
42
Catherine Moroney*
-
17
4
13
1
17
631
307
19
919
28
938
31 December 2023
Balance as at 1
Jan
Advances during
the year
Principal repaid
Balance as at 31
Dec
Interest paid
Maximum
balance
€’000
€’000
€’000
€’000
€’000
€’000
Ronan O’Neill*
640
-
11
629
20
640
640
-
11
629
20
640
* Represents a loan for a person connected with this Director in accordance with section 307(3) of the Companies Act 2014.
** Includes a loan for a person connected with this Director in accordance with section 307(3) of the Companies Act 2014.
398
PTSB Group Holdings plc - Annual Report 2024
42. Related Parties (continued)
(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 €1,524m (31 December 2023: €1,559m).
• The Group had an investment in associated undertakings of €20m for the year ended 31 December 2024 involving participants that are
deemed related parties due to the common ownership by the Government. The amount and nature is referenced in note 22.
• 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 2024, the amount recognised in the income statement was €23m (31 December 2023: €22m).
• During 2024, the Group also paid €nil DGS fees to the CBI (2023: €28m) 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 Newbridge Credit Union (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. During 2024 the FIA concluded, at 31 December 2024 the Group recorded a
payable of €nil due under the FIA (31 December 2023: €2.4m).
(d) Other related party transactions
• At 31 December 2024 the Company had an intercompany balance of €1,731m (31 December 2023: €1,512m) with its principal subsidiary
PTSB plc relating to the MREL issuance.
• In November 2020, PTSB Group made an investment of €123m in PTSB plc. This investment was through the issuance of AT1 securities by
the Company. In October 2022, PTSB Group made an additional investment of €245m in PTSB plc through the issuance of AT1 securities
by the Company.
• 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.
43. Sale of loans and advances to customers
Project Glas III
In July 2024, the Group agreed the sale of a non-performing portfolio (Glas III). The portfolio’s gross balance on the Statement of Financial
Position as at the date of derecognition was €341m with a carrying amount of €208m.
In line with IFRS 9, the assets have been derecognised from the Statement of Financial Position.
As a result of the transaction, a €9m loss was recorded through the impairment line of the income statement. On 1 November 2024, the deal
completed with the receipt of the sale proceeds.
PTSB Group Holdings plc - Annual Report 2024
399
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Notes to the Consolidated Financial Statements (continued)
44. 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.
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
Nature of
business
Incorporated
in
% of ordinary
shares held
Held directly by the company:
Permanent TSB plc
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.
(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 statement of financial position.
At 31 December 2024 the investment amounted to €2,083m (31 December 2023: €2,346m). 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. The carrying value of the subsidiary undertaking before adjusting for impairment was €2,346m and recoverable amount based on
the VIU was €2,083m resulting in €263m impairment charge (2023: €nil). See Company SOFP on page 403 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.
400
PTSB Group Holdings plc - Annual Report 2024
44. Principal subsidiary undertakings and interest in subsidiaries and structured entities (continued)
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. The
Group is exposed to the variable returns of the SE’s through the subordinated loan and the deferred consideration.
The Group currently has four SEs in issue in the ROI the details of which are outlined below. During 2024, Fastnet Securities 14 DAC and
Fastnet 15 DAC collapsed and will be going into liquidation during 2025 and Fastnet 19 was incorporated:
Sub loan
provided
SEs setup with Residential Mortgages
- Fastnet Securities 16 DAC
√
- Fastnet Securities 17 DAC
√
- Fastnet Securities 18 DAC
√
- Fastnet Securities 19 DAC
√
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 2024, restricted cash of €180m (31 December 2023: €217m) relates to cash held by the Group’s securitisation.
45. 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:
31 December
2024
31 December
2023
€ / £ exchange rate
Closing
0.8292
0.8691
Average
0.8450
0.8688
€ / US$ exchange rate
Closing
1.0389
1.1050
Average
1.0808
1.0830
46. Events after the reporting period
In late 2024, the Group announced the opening of a limited voluntary severance scheme. The applications have now closed and are currently
being evaluated. The estimated cost of the scheme is €25m. At 31 December 2024, the Group did not have a present obligation as
applications were still open and therefore it has not met the recognition criteria for a provision under IAS 37 and is not recognised on the SOFP.
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 2024 and the date of the approval of
these financial statements by the Board of Directors on 3 March 2025.
PTSB Group Holdings plc - Annual Report 2024
401
General Information
Financial Statements
Sustainability
Governance
Strategic Report
Index
Page
Statement of financial position
403
Statement of changes in equity
404
Statement of cash flows
405
A Accounting policies
406
B Loans and advances to banks
406
C Investment in subsidiary
407
D Debt securities in issue
407
E Subordinated liabilities
408
F Share capital and reserves
408
G Related parties
408
H Audit fees
408
Company Financial Statements
PTSB Group Holdings plc - Annual Report 2024
402
Note
31 December
2024
31 December
2023
€m
€m
Assets
Loans and advances to banks
B
1,956
1,753
Investment in subsidiary
C
2,083
2,346
Total assets
4,039
4,099
Liabilities
Debt securities in issue
D
1,698
1,497
Other liabilities
3
2
Subordinated liabilities
E
252
252
Total liabilities
1,953
1,751
Equity
Share capital
F
272
273
Share premium
F
804
804
Retained earnings
F
642
903
Shareholders’ equity
1,718
1,980
Other equity instruments
F
368
368
Total equity
2,086
2,348
Total liabilities and equity
4,039
4,099
The accompanying notes form an integral part of these financial statements.
The Company’s loss for the financial year determined in accordance with IFRS was €216m (2023: €45m profit).
On behalf of the Board:
Julie O’Neill
Chairperson
Eamonn Crowley
Chief Executive
Barry D’Arcy
Chief Financial Officer
Conor Ryan
Company Secretary
Company Statement of Financial Position
As at 31 December 2024
PTSB Group Holdings plc - Annual Report 2024
403
Strategic Report
Governance
Sustainability
Financial Statements
General Information
Company
Share capital
Share
premium
Retained
earnings
Attributable
to equity
holders of the
parent
Other equity
instrument
Total
€m
€m
€m
€m
€m
Balance at 1 January 2023
273
804
901
1,978
368
2,346
Profit for the year ended 2023
-
-
2
2
43
45
Other comprehensive income, net of tax
-
-
-
-
-
-
Total comprehensive income for the year
-
-
2
2
43
45
Transactions with equity holders of the Bank,
recorded directly in equity:
AT1 coupon paid
-
-
-
(43)
(43)
Total contributions by and distributions to
owners
-
-
-
-
(43)
(43)
Balance as at 31 December 2023
273
804
903
1,980
368
2,348
Balance as at 1 January 2024
273
804
903
1,980
368
2,348
Loss for the year ended 2024
-
-
(259)
(259)
43
(216)
Other comprehensive income, net of tax
-
-
-
-
-
-
Total comprehensive income for the year
-
-
(259)
(259)
43
(216)
Transactions with equity holders of the Bank,
recorded directly in equity:
Buyback of ordinary shares
(1)
-
(2)
(3)
-
(3)
AT1 coupon paid
-
-
-
-
(43)
(43)
Total contributions by and distributions to
owners
(1)
-
(2)
(3)
(43)
(46)
Balance as at 31 December 2024
272
804
642
1,718
368
2,086
Company Statement of Changes in Equity
For the year ended 31 December 2024
PTSB Group Holdings plc - Annual Report 2024
404
31 December
2024
31 December
2023
€m
€m
Cash flows from operating activities:
Operating (loss)/profit before taxation
(217)
46
Adjusted for non-cash items and other adjustments:
217
(46)
-
-
Increase in operating assets:
Loans and advances to banks
B
(92)
(761)
Increase/(decrease) in operating liabilities:
Debt securities in issue
D
99
770
Other liabilities
-
(2)
Net cash inflow/(outflow) from operating activities before tax
7
7
Tax paid
-
-
Net cash inflow/(outflow) from operating activities
7
7
Cash flow from investing activities
-
Investments in subsidiary undertakings
C
46
44
Net cash flow from investing activities
46
44
Cash Flow from Financing Activities
Share buyback
(2)
-
Interest paid on Tier 2 capital notes
(8)
(8)
AT1 Coupon payment
(43)
(43)
Net cash flow from financing activities
(53)
(51)
Increase/(decrease) 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
-
-
Net cash flows from operating activities includes interest/dividends received of €153m (2023: €57m), interest paid of €105m (2023:
€31m) and dividends paid of €43m (2023: €43m).
Reconciliation of liabilities arising from financing activities
31 December
2024
31 December
2023
1 January
252
252
Financing cash flows:
Issuance of Tier 2 capital notes
-
-
Interest paid on Tier 2 capital notes
(8)
(8)
Interest accrued on Tier 2 capital notes
8
8
31 December
252
252
Company Statement of Cash Flows
For the year ended 31 December 2024
PTSB Group Holdings plc - Annual Report 2024
405
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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
31 December
2024
31 December
2023
€m
€m
Held at amortised cost
Funds placed with subsidiary, Permanent TSB plc (‘PTSB’)
1,958
1,754
ECL allowance
(2)
(1)
Loans and advances to banks
1,956
1,753
Funds placed with the principal subsidiary, PTSB are stage 1 under IFRS 9. The ratings for PTSB are as follows:
• Moody’s: Long-Term Rating “A1” with Outlook “Stable”;
• Fitch: Long-Term Rating “BBB” with Outlook “Stable”; and
In April 2024, the Company subscribed to the €500m 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 4.25% plus a margin of
0.18% per annum maturing on 10 July 2030. The interest is received annually in arrears on 10 July.
During 2024, the Company called €300m of Non-Preferred Senior loans which were issued by PTSB in 2022 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 due to mature on 30 June 2025. The interest was received annually in arrears on 30 June.
In June 2023, the Company subscribed to the €500m 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 6.625% plus a margin of
0.18% per annum maturing on 30 Jun 2029. The interest is received annually in arrears on 25 April.
In April 2023, the Company subscribed to the €650m 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 6.625% plus a margin of
0.155% per annum maturing on 25 Apr 2028. The interest is received annually in arrears on 25 April.
During 2023, the Company called €350m of Non-Preferred Senior loans, of which €300m was issued by PTSB in 2019 and €50m in
2020 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.
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.
The maximum exposure to credit risk for financial assets carried at amortised costs at 31 December 2024 is €1,956m (31 December
2023: €1,753m).
The expected credit losses on these placements were €2m at 31 December 2024 (31 December 2023: €1m).
Notes to the Company Financial Statements
PTSB Group Holdings plc - Annual Report 2024
406
C. Investment in subsidiary
31 December
2024
31 December
2023
€m
€m
At 1 January
2,346
2,346
Impairment of investment
(263)
-
At 31 December
2,083
2,346
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 2024 the investment
amounted to €2,083m (31 December 2023: €2,346m).
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 investment in PTSB before adjusting for impairment was €2,346m
and recoverable amount based on the VIU was €2,083m resulting in a €263m impairment charge for the year (31 December 2023:
no impairment charge). The VIU calculation considers the future free cash flows following the repayment of any amounts due on the
Loans and advances to banks.
While the recoverable amount based on the VIU exceeds market capitalisation at the 31 December 2024, the depressed share price is
the 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 pre-tax free cash flows at a discount rate appropriate to the investment. The discount rate used for the 2024
VIU calculation was 11.5% (31 December 2023: 11.5%).
In October 2024 Permanent TSB plc made a distribution of €2m to its sole shareholder Permanent TSB Group Holdings plc. The
distribution related to the share buyback of Permanent TSB Group Holdings plc shares in October 2024.
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
31 December
2024
31 December
2023
€m
€m
At amortised cost
Bonds and medium-term notes
1,698
1,497
1,698
1,497
Maturity analysis
Repayable in less than 1 year
56
54
Repayable in greater than 1 year but less than 5 years
1,145
945
Repayable in greater than 5 years
497
498
1,698
1,497
PTSB Group Holdings plc - Annual Report 2024
407
Strategic Report
Governance
Sustainability
Financial Statements
General Information
E. Subordinated liabilities
31 December
2024
31 December
2023
€m
€m
At amortised cost
€250m Tier 2 capital notes due August 2031, Callable 2026
252
252
252
252
Maturity analysis
Repayable in less than 1 year
3
3
Repayable in greater than 1 year but less than 5 years
-
-
Repayable in greater than 5 years
249
249
252
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 33 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 42 of the consolidated financial statements for further details.
At 31 December 2024, the Company had an intercompany balance of €1,698m (31 December 2023: €1,497m) with its principal
subsidiary PTSB relating to the MREL issuance and €252m (31 December 2023: €252m) relating to Tier 2 capital issuances.
H. Audit Fees
€0.05m audit fees were paid to the auditors, KPMG, for services relates to the audit of the separate financial statements of PTSBGH
during the year to 31 December 2024 (31 December 2023: €0.05m).
Notes to the Company Financial Statements (continued)
PTSB Group Holdings plc - Annual Report 2024
408
General
Information
Alternative Performance Measures
410
Abbreviations
418
Definitions
419
PTSB Group Holdings plc - Annual Report 2024
409
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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.
Year ended
Year ended
31 December
2024
31 December
2023
€m
€m
Operating profit before taxation per IFRS income statement
159
79
Other exceptional items (Restructuring and other costs) in IFRS total operating expenses
(2)
33
Exceptional impairment arising from deleveraging of loans
2
(5)
Non-IFRS adjustments
Other non-recurring items*
21
59
Underlying profit per management income statement
180
166
*Full breakdown of Other non-recurring items in Financial Review table 5.
Management’s definition of underlying profit excludes exceptional items and other items that Management view as non-recurring.
In the current year, deleveraging of loans post 2021, non-recurring items include accelerated amortisation of intangible assets and
additional provision relating to legacy legal cases.
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Restructuring and other costs
Income Statement
(2)
2
Costs incurred in relation to Ulster Bank business combination
Income Statement
-
31
Exceptional impairment write-back arising from deleveraging of
loans
Income Statement
2
(5)
Exceptional items
-
28
Other non-recurring items
Financial Review
21
59
Exceptional and other non-recurring items
Financial Review
21
87
Alternative Performance Measures
PTSB Group Holdings plc - Annual Report 2024
410
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Total operating expenses
Income Statement
545
538
Exceptional items
Income Statement
(2)
(33)
Non-recurring items (included within total operating expenses)
Table 5 Financial Review
(12)
(1)
Bank levy
Note 8
(23)
(22)
Regulatory charges
Note 8
(10)
(38)
Total operating expenses (excluding exceptional, other non-
recurring items and regulatory charges)
Financial Review
498
444
Total operating income
Income statement
672
668
Adjusted cost income ratio
74%
66%
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Total operating expenses
Income statement
545
538
Exceptional items
Financial review
(2)
(33)
Non-recurring items (included in total operating expenses)
Financial review
(12)
(1)
Total operating expenses (excluding exceptional and other non-
recurring items)
531
504
Total operating income
Income statement
672
668
Headline cost income ratio
Financial review
79%
75%
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.
31 December
2024
31 December
2023
Fully Loaded
Fully Loaded
Source/Cross Reference
€m
€m
Common equity tier 1
Capital Management
1,684
1,616
Risk weighted assets
Capital Management
11,494
11,546
CET 1 fully loaded
Capital Management
14.7%
14.0%
* The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
PTSB Group Holdings plc - Annual Report 2024
411
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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.
31 December
2024
31 December
2023
Transitional
Transitional
Source/Cross Reference
€m
€m
Common equity tier 1
Capital Management
1,684
1,647
Risk weighted assets
Capital Management
11,494
11,546
CET 1 transitional basis
Capital Management
14.7%
14.3%
* The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
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.
31 December 2024
31 December 2023
Transitional
Fully loaded
Transitional
Fully loaded
Source/Cross Reference
€m
€m
€m
€m
Tier 1 Capital
Capital Management
2,052
2,052
2,015
1,984
Gross balance sheet exposures
Leverage ratio exposure measure
28,847
28,847
27,669
27,669
Leverage ratio
Capital Management
7.1%
7.1%
7.3%
7.2%
* 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
2024
31 December
2023
Source/Cross Reference
€m
€m
Liquidity coverage ratio
Financial Review
255%
220%
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Net stable funding ratio (minimum 100%)
Financial Review
166%
155%
Alternative Performance Measures (continued)
PTSB Group Holdings plc - Annual Report 2024
412
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Loans and advances to customers
Note 20
21,423
21,427
Customer accounts
Note 27
24,120
22,966
Loan to deposit ratio
89%
93%
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Net interest income
Income Statement
612
620
Total average interest earning assets
Table 2 - Financial Review
27,686
26,584
Net interest margin (NIM)
2.20%
2.32%
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Residential:
- Home loans
Note 21
259
403
- Buy to let
Note 21
71
267
Commercial
Note 21
24
20
Consumer finance
Note 21
20
16
Finance leases and hire purchase receivables
Note 21
8
12
Non-performing loans
382
718
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Foreclosed assets
Note 36
7
11
PTSB Group Holdings plc - Annual Report 2024
413
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Non-performing loans
Note 21
382
718
Foreclosed assets
Note 36
7
11
Non-performing assets
389
729
15. Return on Shareholder equity (ROE) / Return on Tangible Equity (ROTE)
ROE is profit after tax less AT1 coupons paid (before exceptional and non-recurring items) expressed as a percentage of total average
equity. ROTE is profit after tax less AT1 coupons paid (before exceptional and non-recurring items) expressed as a percentage of
targeted CET1 capital.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Profit for the year after tax
Income Statement
162
68
AT1 coupons paid
SOCIE
(43)
(43)
Exceptional items and other non-recurring items (after tax)
Table 5 - Financial Review
18
76
Tax exceptional
(16)
-
Attributable earnings
121
101
Total average equity
Table 2 - Financial Review
2,457
2,424
Return on shareholder equity
4.9%
4.2%
Average RWA
Capital Management
11,521
11,087
RWA*14.1% CET1 target
1,621
1,560
Return on Tangible Equity
7.5%
6.5%
16. Risk weighted assets (RWAs)
RWAs are the Group’s assets or off balance sheet exposures, weighted according to risk.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Risk weighted assets
Capital Management
11,494
11,546
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Tier 1 Capital
Capital Management
2,052
1,984
Tier 2 Capital
Capital Management
292
290
Total Capital
Capital Management
2,344
2,274
Risk weighted assets
Capital Management
11,494
11,546
Total capital ratio (fully loaded basis)
Capital Management
20.4%
19.7%
*The full year profits recognised in the year end capital ratios remain subject to approval by the Regulator.
Alternative Performance Measures (continued)
PTSB Group Holdings plc - Annual Report 2024
414
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Tier 1 Capital
Capital Management
2,052
2,015
Tier 2 Capital
Capital Management
292
290
Total Capital
Capital Management
2,344
2,305
Risk weighted assets
Capital Management
11,494
11,546
Total capital ratio (transitional basis)
Capital Management
20.4%
20.0%
*The full year loss recognised in the year end capital ratios remain subject to approval by the Regulator.
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 2023 to December 2024, thirteen months in total.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Average interest earning assets
Loans and advances to banks
Table 2 - Financial Review
2,610
2,795
Loans and advances to customers
Table 2 - Financial Review
21,221
20,547
Debt securities and derivative assets
Table 2 - Financial Review
3,855
3,242
Total average interest earning assets
27,686
26,584
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 2023 to December 2024, thirteen months in total.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Average interest bearing liabilities
Customer accounts
Table 2 - Financial Review
23,541
22,340
Debt securities in issue and derivative liabilities
Table 2 - Financial Review
1,686
1,222
Lease liabilities
Table 2 - Financial Review
34
29
Subordinated liabilities
Table 2 - Financial Review
250
254
Deposits by banks
Table 2 - Financial Review
567
1,051
Total average interest bearing liabilities
26,078
24,896
PTSB Group Holdings plc - Annual Report 2024
415
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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 2023 to December 2024, thirteen months in total.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Average interest income on interest earning assets
Loans and advances to customers
Table 2 - Financial Review
747
661
Debt securities and derivative assets
Table 2 - Financial Review
65
36
Loans and advances to banks
Table 2 - Financial Review
87
81
Total average interest income from interest-earning assets
899
778
Total average earning assets
Table 2 - Financial Review
27,686
26,584
Average yield on average interest earning assets
3.25%
2.94%
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 2023 to December 2024, thirteen months in total.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Average interest expense on interest bearing liabilities
Customer accounts
Table 2 - Financial Review
139
43
Debt securities in issue
Table 2 - Financial Review
115
71
Lease liabilities
Table 2 - Financial Review
1
1
Subordinated liabilities
Table 2 - Financial Review
9
8
Deposits by banks
Table 2 - Financial Review
23
35
Total average interest income on interest bearing liabilities
287
158
Total average bearing liabilities
Table 2 - Financial Review
26,078
24,896
Average rate on average interest bearing liabilities
1.10%
0.64%
Alternative Performance Measures (continued)
PTSB Group Holdings plc - Annual Report 2024
416
23. NPLs as % of gross loans (NPL ratio)
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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Non-performing loans
Note 21
382
718
Gross loans and advances to customers
Note 21
21,515
21,688
NPLs as % of gross loans
1.8%
3.3%
24. Average equity attributable to owners
This is an average of the equity position of each individual month from December 2023 to December 2024, 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.
31 December
2024
31 December
2023
Source/Cross Reference
€m
€m
Average equity attributable to owners
Table 2 - Financial Review
2,457
2,424
PTSB Group Holdings plc - Annual Report 2024
417
Strategic Report
Governance
Sustainability
Financial Statements
General Information
The following information has not
been subject to audit by the Group’s
Independent Auditor.
ALCo Asset and Liability Committee
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
Abbreviations
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
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.
RAF Risk Appetite Framework
RAS Risk Appetite Statement
RCA Root Cause Analysis
RCSA Risk and Control Self Assessment
ROE Return on Shareholder equity
ROTE Return on Tangible Equity
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
TLTRO Targeted Long-Term Refinancing
Operations
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
PTSB Group Holdings plc - Annual Report 2024
418
The following information has not
been subject to audit by the Group’s
Independent Auditor.
ALCo Asset and Liability Committee
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.
Buy-to-let Residential mortgage
loan provided to purchase residential
investment property to rent it out.
CET 1 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.
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.
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.
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.
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.
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.
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.
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.
Definitions
PTSB Group Holdings plc - Annual Report 2024
419
Strategic Report
Governance
Sustainability
Financial Statements
General Information
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.
HTC Hold to Collect (HTC) non derivative
financial assets held with the objective to
collect contractual cash flows.
HTC&S Hold to Collect and Sell (HTC&S)
are non-derivative financial assets held
with the objective of both collecting
contractual cash flows and selling
financial assets.
Home loan A loan provided by a bank,
secured by a borrower’s primary residence
or second home.
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.
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.
LGD Loss Given Default (LGD) is the share
of an asset that is lost when a borrower
defaults on a loan.
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.
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.
Definitions (continued)
PTSB Group Holdings plc - Annual Report 2024
420
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.
ROE Return on Shareholder equity is
profit after tax less AT1 coupons paid
(before exceptional and non-recurring
items) expressed as a percentage of total
average equity.
ROTE Return on Tangible Equity is profit
after tax less AT1 coupons paid (before
exceptional and non-recurring items)
expressed as a percentage of targeted
CET1 capital.
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.
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.
PTSB Group Holdings plc - Annual Report 2024
421
Strategic Report
Governance
Sustainability
Financial Statements
General Information