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Seneca Growth Capital VCT

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Employees 51-200
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FY2018 Annual Report · Seneca Growth Capital VCT
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Seneca Growth Capital VCT Plc
(formerly Hygea vct plc)

Annual Report and Financial Statements
For the year ended 31 December 2018

Company No: 04221489

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Contents

Financial Headlines

Financial Summary

Shareholder Information and Contact Details

Strategic Report

          Our Strategy

          Chairman’s Statement

          Investment Manager’s Report

          Business Review

Details of Directors

Directors’ Report

Corporate Governance

Audit Committee Report

Directors’ Remuneration Report and Policy

Directors’ Responsibilities Statement

Report of the Independent Auditor to the Members of Seneca Growth Capital VCT Plc

Income Statement

Ordinary Share Income Statement (non-statutory analysis)

B Share Income Statement (non-statutory analysis)

Statement of Changes in Equity

Ordinary Shares - Statement of Changes in Equity

B Shares - Statement of Changes in Equity

Balance Sheet

Ordinary Share Balance Sheet (non-statutory analysis)

B Share Balance Sheet (non-statutory analysis)

Statement of Cash Flows

Ordinary Shares Statement of Cash Flows

B Shares Statement of Cash Flows

Notes to the Financial Statements

Notice of Annual General Meeting

Directors and Advisers

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About Seneca Growth Capital VCT Plc

Seneca Growth Capital VCT Plc (“the Company” or “Seneca Growth Capital”) is a Venture Capital Trust and 
was launched in 2001. Until 23 August 2018 the Company was called Hygea vct plc, had only one Ordinary 
share class and had raised a total of £7.8m through its initial offer for subscription and its subsequent 
top-up offers. 

On 9 May 2018 the Company launched an offer for subscription for a new B share class to raise, in aggregate, 
up  to  £10  million  with  an  over-allotment  facility  of  up  to  a  further  £10  million  (before  issue  costs)  (the 
“Offer”).

The Company made an initial allotment of B shares on 23 August 2018, at which point Seneca Partners 
Limited (“Seneca”) was appointed as the Company’s Investment Manager and, as at 31 December 2018, the 
Company had allotted a total of 4,036,370 B shares under the Offer, raising £4.0m.

Whilst  Seneca  has  been  appointed  as  the  Company’s  Investment  Manager  and  will  be  responsible  for  the 
management  of  the  Company’s  B  share  pool  investments,  responsibility  for  the  management  of  the  Ordinary 
share pool investments has been delegated to those members of the board of directors who served immediately 
prior to 23 August 2018.

On  19  January  2018,  shareholders  approved  a  change  in  investment  policy  for  the  Company,  expanding  the 
range of qualifying investments that the Company can make, in anticipation of the launch of the Offer and the 
appointment of Seneca as Investment Manager. 

There has however been no change in the way the Ordinary share pool’s assets are managed and the Directors do 
not envisage making any new investments from the assets in this share pool (apart from any follow investments 
in existing portfolio companies), and continue to seek to return to Ordinary shareholders over time the proceeds 
from any realisations in the form of dividends or by means of a return of capital. 

The funds raised from the issue of B shares under the Offer and any subsequent fundraisings will not be limited 
to being invested in any specific sector. Instead, the Company is targeting well managed businesses with strong 
leadership that can demonstrate established and proven concepts, and are seeking an injection of growth capital 
to support their continued development.

Venture Capital Trusts (VCTs)

VCTs were introduced by the UK Government in 1995 to encourage individuals to invest in UK smaller companies. 
The Government achieved this by offering VCT investors a series of tax benefits. 

The Company has been approved as a VCT by HM Revenue & Customs (HMRC). In order to maintain its approval 
the Company must comply with certain requirements on a continuing basis which are discussed further in the 
Business Review. The Company has continued its compliance with these requirements during the year, and prior 
to launching the Offer, received from HMRC confirmation that the issue of B shares by the Company will not affect 
the provisional approval which was previously granted to the company under Chapter 3 Part 6 of the Income Tax 
Act 2007, and that the new B shares, and the existing Ordinary shares in the Company will be eligible shares as 
defined by section 273 ITA 2007.

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Financial Headlines

Ordinary Shares

£2.9m   

Amount realised during the year from sale of Ordinary share pool investment in Hallmarq 
Veterinary Imaging Limited

89.35p   

Ordinary share Net Asset Value (“NAV”) plus cumulative dividends paid at 31 December 2018

Ordinary share NAV at 31 December 2018

Interim capital dividend declared per Ordinary share during year

65.1p 

10.0p 

B Shares

£4.0m   

Amount raised during the year from the issue of B shares

£0.5m   

Amount invested during the year into new investee company by B share pool

99.1p 

B share NAV as at 31 December 2018 (no dividends paid or declared on the B shares at that date)

Financial Summary

Year to 31 
December 
2018 Ordinary 
share pool

Year to 31 
December 2018 
B share pool

Year to 31 
December 2017
(Ordinary share 
pool only)

Net assets (£’000s)

5,282

Return on ordinary activities after tax (£’000s)

102

Earnings per share

Net asset value per share 

Dividends paid since inception

1.3p

65.1p

24.25p

Total return (NAV plus cumulative dividends paid)

89.35p

3,999

(36)

(0.9p)

99.1p

-

99.1p

5,180

(367)

(4.5p)

63.8p

24.25p

88.05p

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Shareholder Information and Contact Details

Financial Calendar

The Company’s financial calendar is as follows:

10 June 2019 

Annual General Meeting will be held at 11.00 a.m. at the Offices of Howard Kennedy LLP, 
1 London Bridge, London SE1 9BG 

September 2019 

Half-yearly results to 30 June 2019 published

April 2020 

Annual results for year to 31 December 2019 announced and
Annual Report and Financial Statements published

Dividends

Dividends will be paid by the Registrar on behalf of the Company. Shareholders who wish to have dividends paid 
directly into their bank account rather than by cheque to their registered address should contact the Company’s 
Registrar, Neville Registrars Limited (“Neville”), whose details can be found on page 75. Other queries relating to 
dividends and shareholdings should also be directed to Neville.

Share Price

The share price of both the Company’s Ordinary shares and B shares are published daily on the London Stock 
Exchange’s  website  (www.londonstockexchange.com),  and  other  financial  websites,  and  can  also  be  accessed 
through the Company’s website (www.senecavct.co.uk). The Ordinary share price may be found using the TIDM/
EPIC code HYG, and the B share price may be found using the TIDM/EPIC code SVCT.

Latest mid-market share price (25 April 2019)   

Ordinary shares 
35.0p per share 

B shares
98.0p per share

Buying and selling shares

The Company’s Ordinary and B shares, which are listed on the London Stock Exchange, can be bought and sold in 
the same way as any other company quoted on a recognised stock exchange via a stockbroker. There may be tax 
implications in respect of all or part of your holdings, so shareholders should contact their independent financial 
adviser if they have any queries.

The Company does not currently operate a share buyback policy for its Ordinary shares, but is authorised to buy 
back its B shares (within approved limits).  If you are considering selling your shares or trading in the secondary 
market, please contact the Company’s Corporate Broker, Panmure Gordon (UK) Limited as follows: 

Chris Lloyd 

020 7886 2716   

chris.lloyd@panmure.com

Paul Nolan 

020 7886 2717   

paul.nolan@panmure.com

Notification of change of address

Communications  with  shareholders  are  mailed  to  the  registered  address  held  on  the  share  register  unless 
shareholders have agreed to be contacted via e-mail. In the event of a change of address or other amendment 
this should be notified to Neville, under the signature of the registered holder. 

Other information for Shareholders

Previously published Annual Reports and Half-yearly Reports are available for viewing on the Company’s website 
at www.senecavct.co.uk, and in line with current trends all future communications will be also be made available 
there.    The  Company  has  introduced  e-communication  for  its  shareholders,  as  many  people  now  prefer  this 
method of contact, and it helps to keep the Company’s cost base down.

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Strategic Report

The Directors are required by the Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2014 
to include a Strategic Report to shareholders.

The following sections form part of the Strategic Report:

•  Our Strategy
•  Chairman’s Statement
• 
•  Business Review

Investment Manager’s Report

Our Strategy 

On 9 May 2018 the Company launched an offer for subscription for a new B share class to raise, in aggregate, up 
to £10 million with an over-allotment facility of up to a further £10 million (before issue costs).  In anticipation of 
the launch of the Offer a revised investment policy was approved by shareholders at the General Meeting on 19 
January 2018 – this is included in full further below.

The  Company  made  an  initial  allotment  of  B  shares  pursuant  to  the  Offer  on  23  August  2018,  at  which  point 
Seneca was appointed as the Company’s Investment Manager.

Whilst  Seneca  has  been  appointed  as  the  Company’s  Investment  Manager  and  will  be  responsible  for  the 
management  of  the  Company’s  B  share  pool  investments,  responsibility  for  the  management  of  the  Ordinary 
share pool investments has been delegated to those members of the board of directors who served immediately 
prior to 23 August 2018.

There has however been no change in the way the Ordinary share pool’s assets are managed and the Directors do 
not envisage making any new investments from the assets in this share pool (apart from any follow on investments 
in existing portfolio companies), and continue to seek to return to Ordinary shareholders over time the proceeds 
from any realisations in the form of dividends or by means of a return of capital.

The funds raised from the issue of B shares under the Offer and any subsequent fundraisings will not be limited 
to being invested in any specific sector. Instead, in line with the revised Investment Policy which was approved by 
shareholders at the General Meeting on 19 January 2018, the Company is targeting well managed businesses with 
strong leadership that can demonstrate established and proven concepts, and are seeking an injection of growth 
capital to support their continued development.

The Directors have controlled the overall risk of the Ordinary share pool investment portfolio by ensuring that the 
Company has exposure to a diversified range of quoted and unquoted companies from the MedTech sector. The 
assets attributable to the B share class will not be restricted to any particular sector. The Directors will continually 
monitor  the  investment  process  and  ensure  compliance  with  both  the  relevant  VCT  regulations  for  qualifying 
investments, summarised below, and the Company’s Investment Policy, included further below.

Qualifying Investments

Compliance with required rules and regulations is considered with all investment decisions made. The Company 
is further monitored on a continual basis to ensure compliance on an ongoing basis. The main criteria to which 
the company must adhere include:

•  At least 70% (80% from 1 January 2020) of investments must be made in qualifying shares or securities;
•  At  least  70%  of  qualifying  investments  must  be  invested  into  ordinary  shares  with  no  preferential  rights 

(investments made before 6 April 2018 from funds raised before 6 April 2011 are excluded);

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•  At  least  30%  of  funds  raised  after  31  December  2018  must  be  invested  in  qualifying  investments  by  the 

anniversary of the end of the accounting period in which those funds were raised;

•  No single investment made can exceed 15% of the total HMRC company value at the time the investment is 

made.

In respect of VCT shares issued on or after 6 April 2014, VCT status will be withdrawn if a dividend is paid (or other 
forms of distribution or payments are made to investors) from the capital received by the VCT from that issue 
within three years of the end of the accounting period in which shares were issued to investors. 

Qualifying  investments  can  only  be  made  in  small  and  medium  sized  trading  companies  which  fall  within  the 
following limits:

•  have fewer than 250 full time equivalent employees (500 if a knowledge intensive company); and
•  have less than £15 million of gross assets at the time of investment and no more than £16 million immediately 

post investment; and

•  be less than seven years old (or 10 years if a knowledge intensive company) if raising State Aided funds for 

the first time; and 

•  have raised no more than £5 million of State Aided funds in the previous 12 months and less than the lifetime 

limit of £12 million (or £20 million if a knowledge intensive company); and

•  produce a business plan to show that its funds are being raised for growth.

Finance  Act  2018  introduced  a  new  “risk-to-capital”  condition  for  qualifying  investments,  designed  to  focus 
investments towards earlier stage, growing businesses, and away from investments which could be regarded as 
lower risk.  The Board is satisfied that the Company’s Investment Policy is in line with this “risk-to-capital” condition.

The  revised  Investment  Policy  as  approved  by  shareholders  on  19  January  2018  is  set  out  below  and  includes 
the  sections  titled  Investment  Policy,  Qualifying  Investments,  Non-Qualifying  Investments,  Risk  Management, 
Borrowing and Changes to the Investment Policy:

Investment Policy

The Company’s objective is to provide shareholders with an attractive income and capital return by investing its 
funds in a portfolio of both unquoted and AIM/NEX quoted UK companies which meet the relevant criteria under 
the VCT rules.

The Company will target well managed businesses with strong leadership that can demonstrate established and 
proven concepts, and are seeking an injection of growth capital to support their continued development.

At least the minimum required percentage of the Company’s assets will be invested in Qualifying Investments as 
required by the VCT rules, with the remainder held in cash and money market securities.

Qualifying Investments

Compliance  with  required  rules  and  regulations  is  to  be  considered  with  all  investment  decisions  made.  The 
Company is further monitored on a continual basis to ensure compliance.

Non-Qualifying Investments

An active approach will be taken to manage any cash held, both prior to its investment in Qualifying Companies 
and to any remaining cash after all investment qualification targets in the VCT rules have been satisfied. All cash 
will be invested in accordance with VCT rules for Non-qualifying Investments. Such Non-qualifying Investments 
may  include  liquid  AIFs,  UCITS  or  other  money  market  funds  including  those  managed  by  Seneca  Investment 
Managers. 

Risk Management 

The Directors control the overall risk of the portfolio by ensuring that the Company has exposure to a diversified 
range of unquoted and AIM/NEX quoted companies. In order to limit concentration risk in the portfolio that is 
derived from any particular investment, at the point of investment or addition to an existing investment no more 
than 15% of the Company by VCT value will be in any one investment. In addition, investments may also be made 
by way of loan stock and/or redeemable preference shares as well as ordinary shares to generate income, whilst 
ensuring compliance with whatever VCT rules apply at the time.

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Borrowing

Whilst the Board does not intend that the Company will borrow funds (other than to manage short term cash 
requirements), the Company is entitled to do so subject to the aggregate principal amount at the time of borrowing 
not  exceeding  25%  of  the  value  of  the  adjusted  capital  and  reserves  of  the  Company  (being,  in  summary,  the 
aggregate of the issued share capital, plus any amount standing to the credit of the Company’s reserves, deducting 
any distributions declared and intangible assets and adjusting for any variations to the above since the date of the 
relevant balance sheet). 

Changes to the Investment Policy

The Company will not make any material changes to its investment policy without Shareholder approval.

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Strategic Report  
Chairman’s Statement 

I am pleased to present the 2018 Annual Report to Shareholders.

Overview

2018 has been a successful year of change for the Company. Following the initial allotment of B Shares under 
the Offer launched on 9 May 2018, we are delighted that Seneca was appointed as the Company’s Investment 
Manager. Funds raised under the Offer totalled £5.5 million and five investments have already been made, details 
of which are set out in the Investment Manager’s report. The Offer is now closed and I would like to take this 
opportunity of welcoming all our new B shareholders. Shareholders may have seen the recent announcement, 
prior to the last allotment, that the NAV at 31 March 2019 of the Ordinary shares is 51.1p per share and of the B 
shares is 98.9p per share.

As intimated in my last Chairman’s Statement accompanying the 2017 accounts, we anticipated a liquidity event 
and were delighted to report that in December 2018 we sold the Company’s Ordinary share portfolio holding in 
Hallmarq Veterinary Imaging Limited (‘Hallmarq’). This realised a profit over cost of £1,807,000 and over carrying 
value of £894,000. As announced at the time of the realisation, it was also possible the Company would receive 
a small amount of further proceeds that had been deferred at completion and I am pleased to confirm that a 
further £37,666 was received in April 2019 and will be accounted for in the 2019 accounts. We are delighted that 
this realisation has allowed us to pay an interim dividend of 10p per Ordinary share and our further intentions 
regarding dividends are detailed below.

Details of the Ordinary share pool’s remaining portfolio companies are included below and also in the Investment 
Manager’s Report.  The Net Asset Value of the Ordinary shares at 31 December 2018 has now increased to 65.1p 
per share and the Total Return is now 89.35p per share.  As Ordinary shareholders will recall, following the raising 
of the minimum subscription of B shares in August 2018, the Ordinary share pool will suffer no running costs until 
July 2021.  In addition, the Company’s bank loan, which was a liability of the Ordinary share pool, has been repaid 
using proceeds from the Hallmarq sale and the debenture released. 

Details  of  the  B  share  investment  made  during  the  year  along  with  details  of  the  B  share  investments  made 
since the year end are included in the Investment Manager’s Report.  The Net Asset Value of the B shares at 31 
December 2018 was 99.1p and at that date no dividends had been paid in relation to the B shares.  

The Board is also encouraged that as of today’s date, the Investment Manager has already invested £2.75m of 
the funds raised under the Offer into 5 companies.  This is in line with their expectations for deploying the capital 
raised under the Offer and indicative of the healthy pipeline of growth capital investment opportunities which 
Seneca maintains as a result of not only their appointment as the Company’s Investment Manager, but also as an 
active growth capital investor through the EIS funds which they manage.   We expect to issue a prospectus for a 
further B share offer shortly and look forward to the Investment Manager continuing to build a portfolio of diverse 
growth capital investments which will be attractive to the VCT investment community.

Results and Dividends

During the year, our revenue return on ordinary activities saw a loss of 0.72p per Ordinary share and a loss of 
0.45p per B share, both principally as a result of the impact of the Company’s running costs. The comparative 
loss for 2017, which related solely to the Ordinary shares, amounted to 1.5p per share. The Company’s running 
expenses are capped at 3% of the B share NAV until July 2021 and as a result, an amount of £18,000 was due to 
the Company from the Investment Manager at 31 December 2018 which will be deducted from future payments 
falling due to Seneca.  

The Capital return on the Ordinary share portfolio amounted to 2p per share driven by the profit generated on 
the disposal of our holding in Hallmarq, details of which I referred to above, net of changes to the valuations of 
some other Ordinary share pool investments. There is no change in the value of the B share portfolio since the 
first investment only completed on 31 December 2018.

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During the year, the nominal value of the Ordinary shares was reduced from 50p per share to 1p per share and 
the majority of the balance standing to the credit of the Company’s share premium account arising on the issue of 
B shares was reduced. Both of these transactions have given rise to a credit to the Special Distributable Reserve 
which may be used for the payment of dividends. Further details are included in note 14 on page 68. Your original 
Ordinary share certificates remain valid.

As previously stated, it is the Board’s intention to distribute the majority of the proceeds generated by the Hallmarq 
exit  to  Ordinary  shareholders,  after  repayment  of  the  bank  loan  and  retention  of  an  appropriate  proportion 
to cover small follow on investments in the existing Ordinary share portfolio and any costs attributable to the 
Ordinary  share  pool.  In  line  with  this  intention,  an  interim  dividend  of  10p  per  Ordinary  share  was  declared 
on 28 December 2018 and it is the current intention of the Board to declare a further interim dividend of 18p 
per Ordinary share in early May (following the filing of the Company’s 2018 accounts at Companies House) for 
payment shortly thereafter. 

In addition the Board was pleased to have declared an interim dividend of 1.5p per B share on 6 March 2019, 
which was paid in April 2019, reducing the NAV of a B share to 97.4p.  The Board hopes to be able to continue to 
declare periodic dividends on the B shares as the B share investment portfolio develops. 

Ordinary Share Investment Portfolio Review

The  remaining  Ordinary  share  portfolio  has  seen  a  reduction  in  value  during  the  period.    As  at  31  December 
2018 the value stood at £2.79m (having been at £3.535m at the end of the prior year excluding Hallmarq) with a 
large proportion of the reduction in the year resulting from the decline in the share price of AIM quoted Scancell 
Holdings plc (“Scancell’) and Omega Diagnostics plc (“Omega”) during the year.  However, in the Board’s opinion, 
the intrinsic values of both Scancell and Omega remain and we are firmly of the view that the potential upside in 
these assets merits their continued presence in the portfolio.  

The value of the quoted and unquoted sections of the remaining Ordinary share portfolio were roughly equal 
at 31 December 2018. Scancell, valued at the bid price of 9p, represented 42% of the Ordinary share portfolio 
as at 31 December 2018. However, by the 31 March 2019 the bid price had reduced to 5.5p and accordingly the 
percentage of the entire Ordinary share portfolio represented by Scancell has fallen to 30.6%. This was the primary 
reason for the reduction in the NAV of an Ordinary share (in addition to the dividend of 10p per share that was 
paid on 25 January 2019) as at 31 March 2019. Details of progress in the Ordinary share pool unquoted portfolio 
are included in the Investment Manager’s Report but the only significant investment, based on the valuations as 
at 31 December 2018, is OR Productivity Limited which continues to report success in its ambitions within the 
hospital operating environment. 

We  have  written  down  the  value  of  Exosect  Limited  (‘Exosect’),  which  was  placed  into  Administration  on  18 
October  2018,  to  nil  and  reduced  the  value  of  Arecor  Limited  (‘Arecor’)  following  their  recent  fund  raising  at  a 
discounted price compared to our carrying value. We continue to hold a full provision against our investment in 
Immunobiology Limited due to share preferences held by other investors. Whilst we are unlikely to recover any 
value from Exosect, we would hope that the opportunities available to both Arecor and Immunobiology have the 
potential to realise further value for the Ordinary share portfolio.

The Board remains confident that, overall, the remaining Ordinary share portfolio has the opportunity to realise a 
significant gain for shareholders but we do not see any immediate opportunities for further realisations.

B Share Investment Portfolio Review

We are delighted to report that the new B share portfolio has now made 5 investments and invested £2.75 million. 
This is a very positive start to the development of the B share investment portfolio and demonstrates that Seneca 
has  access  to  considerable  deal  flow  with  exciting  opportunities.  Full  details  are  included  in  their  Investment 
Manager’s report.

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Annual General Meeting

The Company’s AGM will be held at 11.00 a.m. on Monday 10 June 2019 at the offices of Howard Kennedy LLP, 1 
London Bridge, London SE1 9BG and we look forward to welcoming you to the meeting.

Following  the  appointment  of  Seneca  as  Investment  Manager,  Charles  Breese  has  indicated  that  he  does  not 
wish to  seek  re-election to  the  Board  at  the  AGM.  However  we  are  pleased  that  he  has  agreed  to  continue as 
a  consultant  until  the  end  of  this  year  in  order  to  facilitate  an  orderly  handover  of  the  relationships  with  the 
remaining companies in the Ordinary share portfolio. Charles has been a member of the Company’s Board since 
its inception in 2001 and we thank him very much for his considerable advice and input, especially the benefit of 
his investment experience, during that time.

The Board has reviewed my performance and has asked me to continue as Chairman. A resolution for my re-
election is included in the AGM Notice. A resolution for the re-election of Richard Manley, who was appointed 
during the year as Seneca’s representative, is also included in the AGM Notice.

The Board is currently in the process of identifying a new non-executive Director.   

As the Company has now paid interim dividends in respect of both the Ordinary shares and the B shares and 
is required to pay a further Ordinary share dividend before 12 June 2019 in order to satisfy VCT rules following 
disposal of the Hallmarq investment on 13 December 2018, no resolutions are included in respect of dividends. 

The  Notice  of  the  AGM  includes  resolutions  empowering  the  Directors  to  issue  further  B  shares  and  Ordinary 
shares  which  will  primarily  be  used  to  facilitate  the  launch  of  another  B  share  offer  for  the  2019/2020  and 
2020/2021 tax years referred to above which requires authorisation for the Directors to be able to allot up to a 
further 25,000,000 B Shares. Including these resolutions in the AGM business will avoid the Company having to 
produce and send out a separate circular.

A summary of the resolutions to be proposed by the Company at its Annual General Meeting is included on page 32.

VCT Qualifying Status

Philip Hare & Associates provides the Board with advice on the ongoing compliance with HMRC rules and regulations 
concerning VCTs; they have confirmed that we remain within all the appropriate VCT qualifying regulations as at 
31 December 2018.

Fund Administration

Our administration remains unchanged at present but, as the B share portfolio increases, much of this will migrate 
to Seneca’s Haydock offices, to where we have already moved the Company’s Registered Office. Neville Registrars 
(‘Nevilles’) will continue to maintain the Register. Our website has now changed to www.senecavct.co.uk which 
includes all information in respect of both share classes including Annual Reports and notices of meetings. We 
would remind shareholders who have not opted for electronic communications that this is more  efficient and 
ecologically  friendly  than  receiving  paper  copies  by  post.  If  you  wish  to  take  advantage  of  this  facility,  please 
contact Nevilles whose details are on page 75.

Resignation of Auditor

As already announced, James Cowper Kreston (”JCK”), the Company’s previous auditor, have decided to withdraw 
from auditing Public Interest Entities (which includes VCTs) for the time being due to the increasing regulatory 
landscape and associated costs. As  a  result  JCK have resigned from their role as auditor to the Company. The 
Company carried out a tender process for the appointment of a new auditor, and the Board, on the recommendation 
of the Audit Committee, appointed UHY Hacker Young LLP (“UHY”) to fill the casual vacancy that had arisen. UHY 
have audited the Company’s annual results for the year ending 31 December 2018, and shareholders will be asked 
to reappoint them at the AGM for the audit of the accounts for the year ending 31 December 2019.

12

Future Prospects

As I have previously indicated, we regard the prospects for the remaining Ordinary share portfolio as good but 
once again I need to seek shareholders’ patience following the significant distributions returned (and intended to 
be returned) to them in 2019 whilst we await further realisation opportunities for the remaining investments in 
the Ordinary share portfolio.  

We are pleased with the support we have received from existing and new shareholders in respect of the B share 
fund raising and will be issuing our new prospectus in the near future. Seneca is confident that there remains 
significant  demand  from  potential  investee  companies  for  the  type  of  growth  capital  that  the  Company  can 
provide from its B share pool. As such, the Board remains confident of continuing to increase the  B share fund in 
the 2019/20 tax year and foresees being able to invest these funds profitably well within the time limits imposed 
on VCTs. 

Your Board continues to view the future of our Company with confidence.

John Hustler
Chairman
26 April 2019

13

Investment Manager’s Report

Seneca Partners were delighted to be formally appointed as the Company’s Investment Manager on 23 August 
2018 following the successful first allotment of shares under the B share offer, which was launched on 9 May 2018 
to raise in aggregate up to £10m. 

We are active growth capital investors and since 2012 have invested in excess of £50m of growth capital into more 
than 40 investee companies.

As many of the Company’s B shareholders will know, Seneca are head-quartered in the North West of England 
and as a result of our position as active growth capital investors across the UK we maintain a strong pipeline of 
investment opportunities. From this pipeline of potential investments we have moved quickly to make our first 
investments from the Company’s B share pool and started the process of building a diverse portfolio of growth 
capital investments which we hope will provide attractive returns for the benefit of the Company’s B shareholders.

We are happy to report that a total of £5.5m was raised under the new B share offer in our first year of fundraising 
of which £0.5m had been invested into one investee company as at 31 December 2018. 

This first investment was made into the fast growing e-commerce business, SilkFred Limited, which specialises 
in independent ladies’ fashion brands.  Seneca first invested in this business via EIS funds which we manage in 
March  2018  and  since  that  time  we  have  been  impressed  with  the  progress  it  has  made  and  rate  with  which 
the business is growing.  The December 2018 investment made from the Company’s B share pool was part of a 
larger investment round totalling c.£4m and will provide the working capital the business requires to support its 
continued growth.

Since this first B share pool investment on 31 December 2018 we have also now completed a further 4 investments 
from the B share pool deploying an additional £2.25m and in all of these instances the B share pool has co-invested 
alongside EIS funds also managed by Seneca.  This is a key feature of the B share pool’s early investments and 
brings an ability for the B share pool to participate in larger deals into more established companies than would be 
possible at this point if the Company’s B share pool were to invest on a standalone basis.    

Our  current  investment  portfolio  is  summarised  in  the  table  below  with  additional  detail  in  relation  to  each 
investee company included thereafter.

We  are  very  happy  with  the  diverse  nature  of  these  initial  5  B  share  pool  investee  companies  and  as  it  is  our 
intention that the B share portfolio has exposure to both private and AIM quoted companies we are also particularly 
pleased that we have been able to include an AIM quoted company in these initial investments.

It is our intention to launch another prospectus for a further B share offer in the 2019/2020 tax year in the near 
future and to continue to raise funds to support the ongoing development of the existing portfolio and to fund 
new investments.  
Shareholders  will  recall  that  whilst  Seneca  Partners  are  the  Company’s  Investment  Manager,  responsibility  for 
the management of the Ordinary share pool investments remain with those members of the Board who were 
serving at the point of Seneca’s appointment on 23 August 2018.  During the year to 31 December 2018 a profit 
over  original  cost  of  £1,807k  was  realised  on  the  sale  of  the  Ordinary  share  portfolio’s  holding  in  Hallmarq.  A 
further  £19k  profit  over  cost  was  realised  when  200,000  Scancell  shares  were  sold  for  liquidity  management 
purposes. During the year former Ordinary share pool investee company Glide was dissolved and the carrying 
value of the Ordinary share pool’s investment in Exosect was written down to nil following the company entering 
administration in October 2018.

Further details in relation to both Ordinary share pool and B share pool investee companies are included below.

14

Investment Portfolio – Ordinary shares

Unquoted Investments

Equity 
held 
%

Investment 
at cost 
£’000

Unrealised 
profit/(loss)
£’000

Carrying value at 
31 December 2018 
£’000

OR Productivity plc

Fuel 3D Technologies Limited

Arecor Limited

Insense Limited

Microarray Limited

ImmunoBiology Limited

Exosect Limited

10.3

<1.0

1.3

4.6

1.8

2.0

1.4

765

299

142

509

132

868

270

(101)

(23)

63

(389)

(65)

(868)

(270)

664

276

205

120

67

-

-

Total unquoted investments

2,985

(1,653)

1,332

Movement 
in the year to 
31 December 2018 
£’000

-

-

                         (47)

-

-

-

(120)

(167)

Quoted Investments

Shares 
held

Investment 
at cost 
£’000

Unrealised 
profit/(loss)
£’000

Carrying value at 
31 December 2018 
£’000

Movement 
in the year to 
31 December 2018 
£’000

Scancell plc

13,049,730 789

Omega Diagnostics plc

2,293,868

328

Total quoted investments

Total investments

1,117

4,102

385

(41)

344

(1,309)

1,174

287

1,461

2,793

(482)

(92)

(574)

(741)

Investment Portfolio – B shares

Unquoted Investments

Equity 
held 
%

Investment 
at cost 
£’000

Unrealised 
profit/(loss)
£’000

Carrying value at 
31 December 2018 
£’000

Movement 
in the year to 
31 December 2018 
£’000

Silkfred Limited

<1.0

Total unquoted investments

500

500

-

-

500

500

-

-

15

Ordinary Share Pool – Investment Portfolio – Unquoted Investments

1. OR Productivity Limited

Initial investment 
date:

March 2011

Cost:

£765,000

Valuation:

£664,000

Equity held:

10.3%

Last statutory 
accounts:

31 March 2018

At  the  end  of  2011,  Freehand  2010  (a  Seneca  Growth  Capital 
Ordinary  share  investee)  was  acquired  by  OR  Productivity  plc 
(ORP) in exchange for ORP shares.

Freehand  2010  owns  the  intellectual  property  to  technology 
incorporated in a product, FreeHand, for robotically controlling 
the laparoscope (part of the camera system) used in the growing 
sector that is keyhole surgery. The business model is built upon 
free  placement  of  the  system  with  recurring  revenue  then 
being generated from the subsequent sale of a consumable per 
operation.

Turnover:

£163,000

Progress made by the company in 2018 includes:

Loss before tax:

£762,000

• 

Net assets:

£(1,248,000)

Valuation method:

Price of last 
fundraise

The  publishing  by  Salisbury  Hospital  in  May  2018  of 
information  comparing  the  outcomes  from  surgery  using 
FreeHand  held  cameras  with  the  results  of  surgery  done 
with  a  human  held  camera.  Of  particular  note  was  a  22% 
average  reduction  in  operating  time  of  35  minutes  and 
a  25%  average  reduction  in  post-operative  stay  from  2 
days  to  1.5  days  when  using  FreeHand  held  cameras 
which  are  significant  reductions,  particularly  at  a  time 
when  the  NHS  is  experiencing  staff  and  bed  shortages; 

•  A  strategic  decision  to  focus  sales  efforts  on  accounts 
capable  of  undertaking  c.1,000  operations  p.a.  with 
one  such  account  already  having  been  secured;  and  

•  Progress  being  made  with  the  company’s  Development 
Management  Services  offering  with  the  completion  of  the 
first  stage  of  a  development  project  for  a  medical  device 
delivering  laser  ablation  of  tumors.    The  project  saw  the 
development  of  a  robotic  assistant  (based  on  FreeHand 
technology)  taking  instructions  from  both  MRI  and  CT 
imaging  modalities  and  other  such  projects  are  in  the 
pipeline.

16

2. Fuel 3D Technologies Limited

Initial investment 
date:

March 2010

Cost:

£299,000

Valuation:

£276,000

Equity held:

< 1%

Last statutory 
accounts:

31 December 2017 

Turnover:

£665,000

Loss before tax:

£9.6 million

Net assets:

£4.7 million

Valuation method:

Price of last 
fundraise

3. Arecor Limited

Initial investment 
date:

January 2008

Cost:

£142,000

Valuation:

£205,000

Equity held:

1.3%

Last statutory 
accounts:

31 May 2018

Turnover:

£1,272,000

Loss before tax:

£1,176,000

Net assets:

£679,000

Valuation method:

Price of last 
fundraise

In 2014 Fuel 3D was formed to acquire the computer 3D imaging 
IP of Seneca Growth Capital Ordinary share investee company, 
Eykona.  The  initial  application  for  this  IP  targeted  by  Eykona 
was  measuring  the  volume  of  chronic  wounds,  however  this 
has since developed and the current application focus is on a) 
measuring  tumours  in  animals  used  in  drug  development  via 
a  product  called  BioVolume  and  b)  enabling  the  manufacture 
of products to fit a particular individual eg masks used to treat 
certain medical conditions.

BioVolume is Fuel 3D’s lead product and improves measurement 
accuracy, 
inter-operator  consistency,  animal  welfare,  cost 
efficiencies, compliance and the success of pre-clinical oncology 
research. 

Progress  made  by 

the  company 

in  2018 

includes: 

•  Continued  development  of  BioVolume  by  combining  3D 
imaging  with  thermal  imaging  and  paid  for  trials  are  now 
being undertaken with a number of pharma companies; and  

•  Using its technology in conjunction with 3D printing to make 
products  to  fit  a  particular  individual  and  a  development 
project is now underway with a third party to facilitate the 
manufacture of masks for a medical application.

Arecor  was  a  spin-out  from  Insense  (a  Seneca  Growth  Capital 
Ordinary share investee company – see below) to commercialise 
technology  developed  by  Insense  for  enabling  biologics  to 
maintain  their  integrity  without  the  need  for  refrigeration 
-  this  both  reduces  cost  and  also  helps  supply  chain  logistics 
in  developing  countries  where  temperature  monitored  cold 
storage facilities are in short supply. 

Progress made by the company in 2018 includes:  

• 

• 

In their financial year to 31 May 2018 they invested £2.1m in 
R&D associated with their own product development; and   

The  company  also  raised  £6.0m  of  equity  in  September 
2018  to  fund  the  continued  development  of  Arecor’s  own 
products  for  diabetes  care  and  during  2018,  the  company 
also  filed  a  Clinical  Trial  Application  to  conduct  a  Phase 
I  study  in  Type  1  diabetes  patients  of  Arecor’s  ultra-rapid 
acting insulin product.

17

4. Insense Limited

Initial investment 
date:

Cost:

July 2003

£509,000

Valuation:

£120,000

Equity held:

4.6%

Last statutory 
accounts:

31 December 2017

Turnover:

£18,000

Loss before tax:

£255,000

Net assets:

£322,000

Valuation method:

Price of last 
fundraise

5. Microarray Limited

Initial investment 
date:

January 2011

Cost:

£132,000

Valuation:

£67,000

Equity held:

1.8%

Last statutory 
accounts:

31 December 2017

Turnover:

£58,000

Loss before tax:

£1.1 million

Net assets:

£(2.3 million)

Valuation method: Directors’ valuation

Insense is an innovative, biotechnology company and was spun-
out from Unilever’s R&D laboratory in 2001.  

It  has  since  had  two  successful  spin-outs,  namely  Arecor 
(see  above)  and  Microarray  (see  below)  and  current  Insense 
development activity is concentrated on dermatology products 
for both professional and consumer applications.  

Progress made by the company in 2018 includes: 

•  work continuing in conjunction with a leading microbiologist 
to  prepare  its  leading  dermatology  product  (fungal  nail 
treatment)  for  efficacy  and  usability  tests  with  the  aim  of 
finalising product specification for first-in-man trials.

Microarray Ltd is a UK-based specialist wound healing company. 
Founded in 2000, Microarray was merged with Archimed,a spin-
out  from  Insense  (see  above)  the  company  is  now  privately 
owned.

The  company  has  access  to  wide  ranging  expertise  in  the 
fields of wound dressing product development, marketing and 
sales;  electrochemistry  and  diagnostic  sensor  technologies; 
iodine  chemistry;  enzymology, 
biochemistry,  oxygen  and 
research  and 
immunology  and 
development  activities  are  concentrated  on 
innovative, 
electrochemically-active wound dressings for the treatment of 
chronic wounds and on wound care diagnostics.

inflammation.  Current 

Microarray  owns  and  continues  to  develop  new  intellectual 
property in its specialist fields. It works independently and with 
expert academic and industrial partners.

Progress made by the company in 2018 includes:

•  wound  sample  material  being  obtained  from  a  Wounds 
Innovation  Centre,  where  the  company  is  working  with  a 
world leading wound clinician; and

• 

interim data from a sizeable trial ongoing with data due in 
2019, and the design expected to be frozen in Q3 2019.

18

6. ImmunoBiology Limited

Initial investment 
date:

November 2005

Cost:

 £868,000

Valuation:

 £nil

Equity held:

 2.0%

Last statutory 
accounts:

 31 May 2018

ImmunoBiology  is  a  biotechnology  company  that  is  focused 
on  developing  treatments  for  illnesses  such  as  meningitis, 
tuberculosis, 
influenza  and  hepatitis  C.  The  company’s 
technology is based on the discovery that a group of proteins 
known as ‘heat shock proteins’ has a pivotal role in controlling 
the normal immune response to infections.

The focus is currently on a vaccine for Pneumococcal Disease, 
for which the challenge is that there are >90 strains in circulation 
but present treatments address only a small proportion. In 2016 
a first in human study demonstrated safety in adults. 

Turnover:

 £nil

Progress made by the company in 2018 includes:

Loss before tax:

 £665,000

Net assets:

 £532,000

•  Preparation  for  a  significant  fundraise  to  finance  a 
PnuBioVax  Phase  II  clinical  trial,  with  the  objective  of  a 
successful  outcome  leading  to  a  shareholder  exit  and  in 
early 2019 also concluded a regional licensing agreement.

Valuation method: Directors’ valuation

7. 

Exosect Limited

Initial investment 
date:

January 2010

Cost:

£270,000

Valuation:

Equity held:

Last statutory 
accounts:

£nil

1.4%

31 December 2017

Turnover:

£83,000

Loss before tax:

£2.4 million

Net assets:

£(370,000)

Valuation method:

Investment fully 
written down

Exosect  was  spun-out  of  Southampton  University  in  2001  to 
commercialise  innovative  pest  control  technology  and  reduce 
the use of insecticides. 

Until  2015,  it  sought  to  develop  its  own  pesticide  products. 
However, following a change of CEO, the strategy was changed 
whereby  the  company  regarded  its  technology  as    a  platform 
for helping pesticide manufacturers target their products more 
accurately and thereby achieve environmental benefits (through 
enabling  a  50%  reduction  in  active  ingredients  required  as 
currently more than 50% of applied agrochemicals do not reach 
their intended target) with resulting cost savings. 

Unfortunately  this  change  in  strategy  ultimately  proved  to 
be  unsuccessful  and  administrators  were  appointed  to  the 
company on 18 October 2018, with no return being anticipated 
to shareholders.

19

Ordinary Share Pool – Investment Portfolio - AIM Quoted Investments

1. Scancell plc

Initial investment 
date:

December 2003

Cost:

£789,000

Valuation:

£1,174,000

Equity held:

3.4%

Last statutory 
accounts:

30 April 2018

Turnover:

£nil

Loss before tax:

£4.9 million

Net assets:

£13.9 million

Valuation method:

Bid price of 9.0p  per  
share

Scancell  is  an  AIM  listed  biotechnology  company  that  is 
developing a pipeline of therapeutic vaccines to target various 
types of cancer, with the first target being melanoma. 

The  Immunobody  platform  technology,  in  effect,  educates 
the  immune  system  how  to  respond  –  this  means  that  the 
technology can also be licensed to pharmaceutical companies 
to  assist  the  development  of  their  own  therapeutic  vaccines, 
which is an area of emerging importance for which a number of 
big pharmas do not have in-house technology. 

In  addition,  in  2012  a  second  platform  technology,  Moditope, 
was announced and is based on exploiting the normal immune 
response  to  stressed  cells,  and  is  complementary  to  the 
Immunobody platform.

Progress made by the company in 2018 includes: 

• 

• 

• 

• 

The  announcement  of  a  Clinical  Development  Partnership 
with Cancer Research UK (CRUK) to develop SCIB2, for the 
treatment  of  patients  with  solid  tumours,  including  non-
small  cell  lung  cancer.    CRUK  will  fund  and  sponsor  a  UK-
based Phase I/II clinical trial of SCIB2 in combination with a 
checkpoint inhibitor;

The  announcement  of  a  collaboration  with  BioNTech  for 
the Moditope product being developed for the treatment of 
lung, triple-negative breast cancer, ovarian and endometrial 
cancers. BioNTech is one of Europe’s new immuno-oncology 
power-houses; 

The appointment of a new CEO in January 2018. He was VP 
Business Development at Arana when it acquired Scancell’s 
monoclonal antibody business in 2006; and

The  initiation  of  preparations  for  a)  a  SCIB1-  checkpoint 
inhibitor  Phase  II  US  combination  study  in  late  stage 
melanoma (the study is expected to start in H2 2019), and 
b) a First-in-Human study with Modi-1 in patients with triple 
negative breast cancer, ovarian cancer and sarcoma.

20

2. Omega Diagnostics plc

Initial investment 
date:

August 2007

Cost:

£328,000

Valuation:

£287,000

Equity held:

1.8%

Last statutory 
accounts:

31 March 2018

Turnover:

£13.6 million

Loss before tax:

£6.9 million (incl £5.9 
million exceptional 
charge)

Net assets:

£17.1 million

Omega  Diagnostics  plc  (“Omega”)  is  quoted  on  AIM  and 
specialises in Food Intolerance Testing, Allergy Testing and HIV 
Point-of-Care (POC) Testing. 

Progress made by the company in 2018:

• 

In  December  2017  the  founding  CEO  stepped  down  and 
was replaced by the COO who had joined in August 2015, 
having  previously  been  Managing  Director  of  Axis-Shield 
Diagnostics. Following a strategic review by the new CEO, a 
restructuring took place in order to position the group with 
a  profitable  core  business  with  attractive  organic  growth 
potential  (Food  Intolerance  Testing),  and  two  products 
under  development  with  significant  growth  potential 
(Allergy  Testing,  and  HIV  POC  Testing).    The  restructuring 
involved the closure of the manufacturing site in India and 
the  manual  allergy  testing  business,  eliminating  EBITDA 
losses of c.£800,000 in 2017/18 in addition to the sale of the 
low growth/low margin infectious diseases business; and

Valuation method:

Bid price of 12.5p 
per share

• 

In addition to the completion of the restructuring, the first 
sales  have  been  achieved  in  relation  to  the  automated 
allergy  tests  project  and  the  first  sales  have  also  been 
achieved with regard to the HIV POC Testing CD4 350 test 
(on which development started in 2012 and CE marking was 
achieved in 2017).  CE marking of the second test, CD4 200 
(which is anticipated to have the greater market potential) 
was achieved in March 2019.

21

B Share Pool – Investment Portfolio – Unquoted Investments as at 31 December 2018

1. SilkFred Limited

Initial investment 
date:

December 2018

Cost:

£500,000

Valuation:

£500,000

Equity held:

<1%

Last statutory 
accounts:

31 December 2017

Turnover:

Not disclosed

Loss before tax:

Not disclosed

Net assets:

£3.5 million

Valuation method:

At cost

Silkfred  is  an  online  marketplace  for  independent  ladies’ 
fashion  brands.  The  business  was  founded  in  2011  with  the 
aim  of  creating  an  efficient  marketplace  for  emerging  fashion 
designers to bring products to market and establish their brand 
in the sector. The business now works with c.600 independent 
brands, selling to over 500k customers. 

Silkfred acts as a central marketing and sales platform for these 
brands,  charging  commission  in  exchange  for  these  services, 
and  as  a  result  the  business  itself  takes  minimal  inventory  / 
working capital risk on new brands, lines or products. 

The  business  model  revolves  around  a  market  leading  and 
scalable  customer  service  platform,  and  as  such  Silkfred  are 
continually  investing  in  core  infrastructure  and  constantly 
the  customer 
seeking 
experience.

innovative  methods 

to  enhance 

B Share Pool – Investment Portfolio – Additional Unquoted Investments as at 26 April 2019

1. Fabacus Holdings Limited

Initial investment 
date:

February 2019

Cost:

£500,000

Equity held:

2.2%

Last statutory 
accounts:

31 December 2018

Turnover:

Not disclosed

Loss before tax:

Not disclosed

Net assets:

£4.6 million

is  an 

independent  software  company  that  has 
Fabacus 
developed  a  Complete  Product  Lifecycle  Solution:  Xelacore, 
aimed at bringing transparency to supply chain networks, with 
an  initial  focus  on  resolving  the  interaction  and  information 
flow between global licensors and their licensees.

Currently, there is a fundamentally flawed data capture process 
between  licensors  and  licensees;  and  a  disconnection  from 
the framework of retail standards that have underpinned and 
continue to enable the retail value chain. This has resulted in an 
inability to correctly address known shortcomings in respect to 
data management and hinder the needed digital transformation 
of licensors in the digitally evolving retail landscape.

Fabacus’s solution, Xelacore, is a modular, Software as a Service 
(“SaaS”)  solution  with  an  intuitive  interface  and  proprietary 
data  aggregation  and  management  engine  that  allows  all 
stakeholders  to  operate  on  a  single  unified  and  collaborative 
platform. It bridges the gaps in an inefficient process within the 
current  retail  ecosystem  by  creating  authenticated,  enriched 
universal  records  that  unlock  opportunities,  reduce  risk  and 
drive performance for both licensors and licensees. 

22

2. Old St Labs Limited

Initial investment 
date:

March 2019

Cost:

£500,000

Equity held:

3.44%

Last statutory 
accounts:

31 March 2018

Turnover:

Not disclosed

Loss before tax:

Not disclosed

Net assets:

(£0.7) million

3. Qudini Limited

Initial investment 
date:

April 2019

Cost:

£500,000

Equity held:

2.22%

Last statutory 
accounts:

31 December 2018

Turnover:

Not disclosed

Loss before tax:

Not disclosed

Net assets:

£1.7 million

Old St Labs is a provider of cloud based, supplier collaboration 
tools for large, blue chip customers, enabling them to manage 
key supplier relationships and strategic project work. The core 
product,  Vizibl,  seeks  to  make  supplier  collaboration  much 
more straight forward, with key focus on compliance, savings / 
efficiency and driving growth across the business. 

Vizibl  is  the  only  SaaS  workspace  that  supports  collaborative 
supplier  relationships,  bringing  all  points  of  contact  together 
in  one  place,  providing  visibility  across  the  company  and 
eliminating  duplication  of  efforts.  Vizibl’s  real-time  reporting 
speeds  up  decision  making,  drawing  on  and  sharing  the 
expertise  of  the  community  in  the  process.  The  offering  taps 
into a growing trend in supplier collaboration, having moved on 
from the initial focus on compliance, to an increased emphasis 
on savings / efficiency, and recent developments highlighting the 
benefits in terms of wider growth strategy for large customers. 

Vizibl  provides  the  infrastructure,  governance  and  reporting 
capabilities to optimise present supplier performance and acts 
as a springboard for those collaborative supplier relationships. 
The product is CRM / ERP agnostic, working alongside all major 
software  providers  to  ensure  the  collaboration  software  is 
insightful and informative.

Founded  in  2012,  Qudini  is  a  B2B  software  company  that 
provides customer experience SaaS solutions to organisations 
in retail, hospitality, the public sector and healthcare. 

Qudini provides a software solution for appointment bookings, 
queue management, event management and task management 
–  enabling  businesses  to  improve  shop  floor  operations  by 
managing  staff  activity,  breaks  and  performance,  and  by 
assigning tasks at store or head office level.

Qudini is aiming to revolutionise digital queue and appointment 
management. It achieves this through deployment of its data-
centric,  cloud-based  (Amazon  Web  Services),  cross-platform 
service, which improves a business’ ability to manage the flow 
of  customers  awaiting  service,  using  algorithms  to  provide 
accurate,  live  data,  such  as  estimated  wait  times.  Wait  times 
are relayed to the customer typically via an SMS/text sent from 
the Qudini platform. Through integration with various software 
platforms and compatible with wide variety of hardware, Qudini 
enables  detailed  analytics  focused  on  customer  trends,  and 
provides a unique insight into areas such as customer footfall, 
peak demand times, and wait times. 

23

B Share Pool – Investment Portfolio – Additional Quoted Investments as at 26 April 2019

1. SkinBioTherapeutics Plc

Initial investment 
date:

February 2019

Cost:

£750,000

Equity held:

Last statutory 
accounts:

3.7%
- 4,677,107 shares

30 June 2018

Turnover:

Nil

Loss before tax:

£0.9 million

Net assets:

£3.4 million

SkinBioTherapeutics  is  a  life  science  company  focused  on 
skin  health.  The  Company’s  proprietary  platform  technology, 
SkinBiotix®, is  based  upon discoveries  made  by  CEO  Dr.  Cath 
O’Neill and Professor Andrew McBain.

SkinBioTherapeutics’  platform  applies  research  discoveries 
made  on  the  activities  of  lysates  derived  from  probiotic 
bacteria  when  applied  to  the  skin.  The  Company  has  shown 
that  the  SkinBiotix®  platform  can  improve  the  barrier  effect 
of  skin  models,  protect  skin  models  from  infection  and  repair 
skin  models.  Proof  of  principle  studies  have  shown  that  the 
SkinBiotix®  platform  has  beneficial  attributes  applicable  to 
each of these areas. 

The aim of the Company is to develop its SkinBiotix® technology 
into  commercially  successful  products  supported  by  a  strong 
scientific  evidence  base.  SkinBioTherapeutics’  commercial 
strategy is to engage health and wellbeing and/or pharmaceutical 
companies  in  early  dialogue  to  build  up  relationships  and 
maintain  communication  on  technical  progress  until  one  or 
more commercial deals can be secured.

24

Business Review

Company Performance

The Board is responsible for the Company’s investment strategy and performance.

The graph below compares the NAV return (rebased to 100) of the Company’s Ordinary shares over the period 
from October 2001 to December 2018, with the total return from a notional investment (rebased to 100) in the 
FTSE  All-Share  index  over  the  same  period.  This  index  is  considered  to  be  the  most  appropriate  broad  equity 
market index for comparative purposes. However, the Directors wish to point out that VCTs have very restrictive 
investment criteria in their observance of the VCT rules.  A graph making a similar comparison for the NAV return 
of  the  Company’s  B  shares  has  not  been  included  as  the  first  B  share  pool  investment  was  only  completed  in 
December 2018. 

* Based on notional investment on 1 October 2001

AIC methodology: The NAV Total Return to the investor, including the original amount invested (rebased to 100p) from 
launch, assuming the dividends paid were re-invested at the NAV of the Company at the time the shares were quoted.

Results

Year ended
31 December 2018

Year ended
31 December 2017

Net return attributable to Ordinary shareholders

Net return attributable to B shareholders

Total

25

£’000

102

(36)

66

£’000

(367)

-

(367)

Key Performance Indicators (KPIs)

The  Board  uses  a  number  of  measures  to  assess  the  Company’s  success  in  meeting  its  objectives.  The  KPIs  it 
monitors are:

• 
• 

Total Return (NAV plus cumulative dividends paid) per share for both share classes; and 
The total expenses of the Company as a proportion of shareholders’ funds.

The Total Return for the Ordinary shares and B Shares are included in the Financial Summary on page 5.

For a three year period with effect from 1 July 2018, expenses of the Company are capped at 3% of the weighted 
average  net  asset  value  of  the  B  shares,  including  the  management  fee  (but  excluding  any  performance  fee).   
Accordingly Seneca reduced its management fee by £42,000 in the year to 31 December 2018 (2017: n/a) to keep 
expenses in line with this cap.  

Viability Statement

In accordance with provision C.2.2 of The UK Corporate Governance Code 2014 the Directors have assessed the 
prospects of the Company over a longer period than the 12 months required by the “Going Concern” provision.  
The Board regularly considers the Company’s strategy, including investor demand for the Company’s shares, and 
a three year period is considered to be a reasonable time horizon for this.

The Board has carried out a robust assessment of the principal risks facing the Company and its current position, 
including those which may adversely impact its business model, future performance, solvency or liquidity. The 
principal risks faced by the Company and the procedures in place to monitor and mitigate them are set out below. 

The Board has also considered the Company’s cash flow projections and found these to be realistic and reasonable.

Based on the above assessment the Board confirms that it has a reasonable expectation that the Company will be 
able to continue in operation and meet its liabilities as they fall due over the three year period to 31 December 2021.

Principal risks, risk management and regulatory environment 

The Board carries out a regular review of the risk environment in which the Company operates. The main areas of 
risk identified by the Board are as follows: 

VCT qualifying status risk: the Company is required at all times to observe the conditions laid down in the Income 
Tax Act 2007 for the maintenance of approved VCT status: these rules have subsequently been updated on several 
occasions.  The loss of such approval could lead to the Company losing its exemption from corporation tax on 
capital gains, to investors being liable to pay income tax on dividends received from the Company and, in certain 
circumstances, to investors being required to repay the initial income tax relief on their investment.  

The Board keeps the Company’s VCT qualifying status under regular review.  The Board has also engaged Philip 
Hare & Associates LLP as VCT Status advisor. 

The main specific regulations that must have been met, and which the Directors are confident have been complied 
with, are: 

a)  The Company’s income in the period has been derived wholly or mainly (70% plus) from shares or securities.

b)  The Company has not retained more than 15% of its income from shares and securities.

c)  At  least  70%  (80%  from  1  January  2020)  by  value  of  the  Company’s  investments  has  been  represented 
throughout the period by shares or securities comprised in qualifying holdings of the company. New funds 
raised  are  included  in  this  requirement  from  the  beginning  of  the  accounting  period  in  which  the  third 
anniversary of the share issue date falls. As at the end of December 2018 the percentage is 100%.

26

d)  At least 70% by value of the Company’s qualifying holdings has been represented throughout the period by 
holdings of eligible shares (investments made before 6 April 2018 from funds raised before 6 April 2011 are 
excluded).

e)  At  least  30%  of  funds  raised  after  31  December  2018  must  be  invested  in  qualifying  investments  by  the 

anniversary of the accounting period in which those funds were raised.

f)  No holding in any company has at any time in the period represented more than 15% by value of the Company’s 

investments at the time of investment or when the holding is added to.

g)  The Company’s ordinary capital has throughout the period been listed on a regulated European market.

h)  No investment made by the VCT has caused the investee company to receive more than £5m (or £10m for 
knowledge intensive companies) of State Aid investment in the year ended on the date of the VCT’s investment, 
nor more than the lifetime limit of £12m (or £20m for knowledge intensive companies). Furthermore the use 
of funds has not been contrary to the EU State Aid guidelines.

Investment risk: the majority of the Company’s investments are in smaller quoted and unquoted companies which 
are VCT qualifying holdings, which by their nature entail a higher level of risk and lower liquidity than investments 
in large quoted companies.  The Directors aim to limit the risk attached to the portfolio as a whole by careful 
selection and timely realisation of investments, by carrying out due diligence procedures and by maintaining a 
spread of holdings in terms of financing stage.  The Board reviews the investment portfolio on a regular basis.

Financial risk: by its nature, as a VCT, the Company is exposed to market price risk, credit risk, liquidity risk, fair 
value and cash flow risks. All of the Company’s income and expenditure is denominated in sterling and hence the 
Company has no direct foreign currency risk. The indirect risk results from investees doing business overseas. The 
Company is financed through equity. The Company does not use derivative financial instruments.

Cash flow risk:  the risk that the Company’s available cash will not be sufficient to meet its financial obligations is 
managed by frequent budgeting and close monitoring of available cash resources.  

Liquidity risk: the Company’s investments may be difficult to realise. The spread between the buying and selling 
price of shares may be wide and thus the price used for the valuation may not be achievable.  

Regulatory risk: the Company is required to comply with the Companies Acts, the rules of the UK Listing Authority 
and United Kingdom Accounting Standards. Breach of any of these might lead to suspension of the Company’s 
Stock Exchange listing, financial penalties or a qualified audit report.

Reputational risk: inadequate or failed controls might result in breaches of regulation or loss of shareholder trust.

Internal  control  risk:  the  Board  reviews  annually  the  system  of  internal  controls,  financial  and  non-financial, 
operated by the Company. These include controls designed to ensure that the Company’s assets are safeguarded 
and that proper accounting records are maintained.

The Board seeks to mitigate the internal risks by setting policy, regular review of performance, enforcement of 
contractual  obligations  and  monitoring  progress  and  compliance.  In  the  mitigation  and  management  of  these 
risks, the Board applies rigorously the principles detailed in the Financial Reporting Council’s Guidance on Risk 
Management, Internal Controls and Related Financial and Business Reporting. Details of the Company’s internal 
controls are contained in the Corporate Governance section starting on page 34.

Due to the nature of the Company, environmental, social, employee and human rights’ issues do not apply and 
therefore no disclosures in respect of these have been included in the Directors’ report.

Further  details  of  the  Company’s  financial  risk  management  policies  are  provided  in  note  16  to  the  Financial 
Statements.

27

Gender and Diversity 

The  Board  currently  comprises  four  male  Non-Executive  Directors  with  considerable  experience  of  the  VCT 
industry. The gender and diversity of the constitution of the Board will continue to be reviewed on an annual basis.   

28

Details of Directors

John Hustler (Non-Executive Chairman – Age 72) 

John joined Peat Marwick, now KPMG, in 1965 and became a Partner in 1983. Since leaving KPMG in 1993 to form 
Hustler Venture Partners Limited, he has advised and been a director of a number of growing companies. He is 
presently Chairman of Octopus Titan VCT plc. He was also a member of the Council of The Institute of Chartered 
Accountants  in  England  and  Wales  and  Chairman  of  its  Corporate  Finance  Faculty  from  1997-2000,  and  was  a 
member of the Council of the British Venture Capital Association from 1989-1991.

John has a beneficial interest in Scancell. 

Charles Breese (Non-Executive Director – Age 72) 

Charles  has  over  30  years  of  experience  of  investing  in  start-up,  early  stage  and  quoted  smaller  companies 
harnessing technology to derive competitive advantage.   He worked for KPMG from 1969 until 1982.  He joined 
Larpent Newton Holdings Limited in 1982 and was appointed Managing Director in 1986. Larpent Newton provides 
the resources required to assist technology-based companies seeking to develop from being unquoted through 
to an AIM listing, and ultimately to achieving a trade sale. He has developed an Investment Template which has 
proved successful in identifying early stage companies which have delivered attractive long-term returns. 

Charles has a beneficial interest in OR Productivity, Scancell, and Omega Diagnostics.

Richard Roth (Non-Executive Director – Age 55) 

Richard  is  a  director  of  all  the  Oxford  Technology  Venture  Capital  Trusts  and  Chairman  of  Oxford  Technology 
2 Venture Capital Trust Plc. He is a Chartered Management Accountant and worked in the airline industry for a 
number of companies including easyJet and was CFO of RoyalJet. He has subsequently had a number of consulting 
assignments, in particular helping companies determine their strategy, and implementing business improvements. 
Richard has been a VCT investor for nearly 20 years. He has invested in a number of small (mainly unquoted) 
companies and has also advised several potential start-up businesses – mainly travel-related. 

Richard has a beneficial interest in Scancell, and Fuel3D.

Richard Manley (Non-Executive Director – Age 39)

Richard is CEO of Seneca Partners Limited. He qualified as a chartered accountant with KPMG in 2004, joined NM 
Rothschild’s Leveraged Finance team in Manchester in 2007 before joining Cenkos Fund Managers in 2008. 

Richard  joined  Seneca  on  launch  in  2010  and  has  been  involved  in  the  development  of  all  areas  of  Seneca’s 
business and played a key role in its journey from start up to managing more than £100m by end December 2018. 
He has been a continuous member of Seneca’s investment and credit committees and has been involved in all of 
Seneca’s EIS and VCT growth capital investments to date. Richard became Managing Partner of Seneca Partners 
Limited in 2016 and CEO in 2017.

Richard has a beneficial interest in Scancell. 

29

Directors’ Report

The Directors present their Report and the audited Financial Statements for the year ended 31 December 2018.

The Directors consider that the Annual Report and Financial Statements, taken as a whole are fair, balanced and 
understandable and provides the information necessary for shareholders to assess the Company’s performance, 
business model and strategy.

Review of Business Activities

The Directors are required by s417 of the Companies Act 2006 to include a Business Review to shareholders.  This 
is set out on page 25 and forms part of the Strategic Report. The Chairman’s Statement on page 10 to 13, and the 
Investment Manager’s Report on pages 14 to 24 also form part of the Strategic Report.

The purpose of this review is to provide shareholders with a snapshot summary setting out the business objectives 
of the Company, the Board’s strategy to achieve those objectives, the risks faced, the regulatory environment and 
the key performance indicators used to measure performance.

Directors’ Shareholdings – Ordinary shares

The Directors of the Company during the period and their interests (in respect of which transactions are notifiable 
under Disclosure and Transparency Rule 3.1.2R) in the issued Ordinary shares of 1p (2017: nominal value 50p) are 
shown in the table below:

John Hustler

Charles Breese

Richard Roth

Richard Manley

31 December 2018
Number of Shares

31 December 2017
Number of Shares

190,000

105,000

209,612

-

190,000

105,000

209,612

-

All of the Directors’ shares were held beneficially. There have been no changes in the Directors’ Ordinary share 
interests between 31 December 2018 and the date of this report.

Directors’ Shareholdings – B Shares

The Directors of the Company during the period and their interests (in respect of which transactions are notifiable 
under Disclosure and Transparency Rule 3.1.2R) in the issued B shares of 1p are shown in the table below:

John Hustler

Charles Breese

Richard Roth

Richard Manley

31 December 2018
Number of Shares

31 December 2017
Number of Shares

-

-

15,000

24,750

-

-

-

-

All of the Directors’ shares were held beneficially. There have been no changes in the Directors’ B share interests 
between 31 December 2018 and the date of this report.

Directors’ and Officers’ Liability Insurance

The  Company  has  maintained  directors’  and  officers’  liability  insurance  cover  on  behalf  of  the  Directors  and 
Company Secretary.  

30

Whistleblowing

The Board has approved a Whistleblowing Policy for the Company, its directors and any employees, consultants 
and contractors, to allow them to raise concerns, in confidence, in relation to possible improprieties in matters of 
financial reporting and other matters.

Bribery Act

The Board has approved an Anti-Bribery Policy to ensure full compliance with the Bribery Act 2010 and to ensure 
that the highest standards of professional and ethical conduct are maintained.

Management

On 23 August 2018 Seneca was appointed as the Company’s Investment Manager.

Whilst  Seneca  has  been  appointed  as  the  Company’s  Investment  Manager  and  will  be  responsible  for  the 
management  of  the  Company’s  B  share  pool  investments,  responsibility  for  the  management  of  the  Ordinary 
share pool investments has been delegated to those members of the board of directors who served immediately 
prior to 23 August 2018.

Share Issues 

During the year, the Company did not issue any Ordinary shares (2017: nil).  During the year, the Company issued 
4,036,370  B  shares  raising  £4.0m  (2017:  nil).  Subsequently  an  additional  1,351,294  B  shares  have  been  issued 
under the Offer.

Share Capital

The Company’s issued Ordinary share capital as at 31 December 2018 was 8,115,376 Ordinary shares of 1p each 
(31 December 2017: 8,115,376 of 50p each) and 4,036,370 B shares of 1p each (31 December 2017: nil). 

Directors

Biographical details of the Directors are shown on page 29. 

In accordance with the Articles, John Hustler who has been a director for more than nine years will retire and offer 
himself for re-election at the forthcoming AGM. Richard Manley has been appointed since the last AGM and will 
therefore retire and offer himself for re-election at the forthcoming AGM.

The Board is satisfied that, following individual performance appraisals, both the Chairman and Richard Manley, 
who  are  retiring,  continue  to  be  effective  and  demonstrate  commitment  to  their  roles  and  therefore  offer 
themselves for re-election with the support of the Board.

Following  the  appointment  of  Seneca  as  Investment  Manager,  Charles  Breese  has  indicated  that  he  does  not 
wish to  seek  re-election to  the  Board  at  the  AGM.  However  we  are  pleased  that  he  has  agreed  to  continue as 
a  consultant  until  the  end  of  this  year  in  order  to  facilitate  an  orderly  handover  of  the  relationships  with  the 
remaining companies in the Ordinary share portfolio.

The  Board  is  cognisant  of  shareholders’  preference  for  Directors  not  to  sit  on  the  boards  of  too  many  listed 
companies (“over-boarding”).  As part of their assessment as to his suitability, the Directors considered Richard 
Roth’s other directorships at the time of his appointment, given that he also sits on the boards of the four Oxford 
Technology (“OT”) VCTs.  The Directors noted that those four funds have a common board, and there is an element 
of overlap in the workload across the four entities, such that the time required is less than would be necessary 
for four totally separate and listed companies. They also note that Seneca Growth Capital has a number of shared 
portfolio companies with the OT VCTs. The Board was satisfied that Richard Roth had the time to focus on the 
requirements of the Company, and this has proven to be the case.

31

International Financial Reporting Standards

As the Company is not part of a group it is not mandatory for it to comply with International Financial Reporting 
Standards.    The  Company  does  not  anticipate  that  it  will  voluntarily  adopt  International  Financial  Reporting 
Standards.  The  Company  has  adopted  Financial  Reporting  Standard  102  –  The  Financial  Reporting  Standard 
Applicable in the United Kingdom and Republic of Ireland.

Environmental Policy

The Company always makes a full effort to conduct its business in a manner that is responsible to the environment. 

Going Concern

The Company’s business activities and the factors likely to affect its future performance and position are set out in 
the Chairman’s Statement and Investment Manager’s Report on pages 10 to 13 and pages 14 to 24. Further details 
on the management of financial risk may be found in note 16 to the Financial Statements.

The Board receives regular reports from the Administration Manager and the Directors believe that, as no material 
uncertainties leading to significant doubt about going concern have been identified, it is appropriate to continue 
to adopt the going concern basis in preparing the Financial Statements.

As  at  31  December  2018  the  Company  had  more  than  £6m  of  cash  and  in  addition,  the  other  assets  of  the 
Company consist mainly of securities, some of which are readily realisable.  As such, the Company has adequate 
financial resources to continue in operational existence for the foreseeable future. 

Substantial Shareholdings

At 31 December 2018, two disclosures of major shareholdings had been made to the Company under Disclosure 
and Transparency Rule 5 (Vote Holder and Issuer Notification Rules).

• 

James Leek has disclosed a shareholding of 4.57% (555,340 shares). 

•  David Blundell has disclosed a shareholding of 3.04% (369,900 shares). 

Annual General Meeting

The  Notice  convening  the  2019  Annual  General  Meeting  (“AGM”)  of  the  Company  is  set  out  at  the  end  of  this 
document (and a form of proxy in relation to the meeting is enclosed separately). Part of the business of the AGM 
will be to consider resolutions in relation to the following matters:

Resolution 6 will seek the re-appointment of UHY Hacker Young LLP as Independent Auditor to the Company.

Resolution  8  will  authorise  the  Directors  to  allot  further  B  Ordinary  shares  and  Ordinary  shares.  This  would 
enable the Directors until the next AGM to allot up to 31,000,000 B Ordinary shares in connection with any offer(s) 
for subscription (and any subsequent top up offer of B Ordinary shares) and up to 405,800 Ordinary shares (for 
any miscellaneous offers of such shares), representing approximately 575% of the Company’s issued B Ordinary 
share capital and approximately 5% of its issued Ordinary share capital as at 25 April 2019. 

Resolution 9 will, under sections 570 of the Act, disapply pre-emption rights in respect of any allotment of the B 
Ordinary shares and/or Ordinary shares authorised under Resolution 8.  

Resolution 10 will authorise the Board, pursuant to the Act, to make one or more market purchases of up to 
14.99% of the issued B Ordinary share capital of the Company from time to time. The price paid must not be less 
than 1p per B Ordinary share, nor more than 5% above the average middle market price of a B Ordinary share 
for the preceding five business days. Any B Ordinary shares bought back under this authority may be cancelled 
by the Board.  

Resolution 11 will authorise the cancellation of the share premium account of the Company.  This share premium 
account will arise on the issue of further B Ordinary Shares pursuant to any offer for subscription. All of the share 

32

 
premium account at the date of the order made by the Court confirming such cancellation will be cancelled, and 
will be used to establish a new reserve which may be treated as distributable and which can be used, among other 
things, to fund the Company’s buy-back of shares and the payment of future dividends. In accordance with the 
VCT Rules, such distributable reserves cannot, however, be utilised for such purposes until after three years from 
the end of the accounting period in which the relevant shares were issued. 

The Directors intend to use the authorities in Resolutions 8 and 9 for the purposes of a further offer for subscription 
of B Ordinary Shares, though may also subsequently utilise the authorities for further offer(s) for subscription 
or issue of B Ordinary Shares. The Directors have no current intention to utilise the authority in relation to the 
Ordinary Shares.  

By Order of the Board

Craig Hunter
Company Secretary
26 April 2019

33

 
Corporate Governance 

The Board has considered the principles and recommendations of the AIC Code of Corporate Governance (AIC 
Code) by reference to the AIC Corporate Governance Guide for Investment Companies (AIC Guide), as applied to 
companies reporting as at 31 December 2018. 

The AIC Code, as explained by the AIC Guide, addresses all the principles set out in The UK Corporate Governance 
Code, as well as setting out additional principles and recommendations on issues that are of specific relevance to 
the Company. 

The Board will report against the updated AIC Code at the end of the current financial year.

Board of Directors

The Company has a Board of four non-executive Directors. They meet on a regular basis to review the investment 
performance and monitor compliance with the investment policy laid down by the Board as set out in the Strategic 
Report on page 7.

The Board has a formal schedule of matters specifically reserved for its decision which include:

• 

• 
• 
• 

• 

the consideration and approval of future developments or changes to the investment policy, including risk 
and asset allocation;
consideration of corporate strategy;
approval of the appropriate dividend to be paid to the shareholders;
the  appointment,  evaluation,  removal  and  remuneration  of  the  Investment  Manager  and  Administration 
Manager;
the performance of the Company, including monitoring of the discount of the share price to net asset value; 
and

•  monitoring shareholder profiles and considering shareholder communications.

The Chairman leads the Board in the determination of its strategy and in the achievement of its objectives.  The 
Chairman is responsible for organising the business of the Board, ensuring its effectiveness and setting its agenda. 
He facilitates the effective contribution of the Directors and ensures that they receive accurate, timely and clear 
information and that the Company communicates effectively with shareholders.

The Company Secretary is responsible for advising the Board through the Chairman on all governance matters.  
All  of  the  Directors  have  access  to  the  advice  and  services  of  the  Company  Secretary,  who  has  administrative 
responsibility for the meetings of the Board and its Committees.  Directors may also take independent professional 
advice at the Company’s expense where necessary in the performance of their duties.

The Company’s Articles of Association and the schedule of matters reserved to the Board for decision provide that 
the appointment and removal of the Company Secretary is a matter for the full Board.  

34

Attendance at Board, Audit Committee and Management meetings during the year were as follows:

Board 
meetings attended 
(13 held in year)

Audit Committee 
meetings attended 
(3 held in year)

Management 
meetings attended 
(3 held in year)

John Hustler

Charles Breese

Richard Roth

Richard Manley*

13

13

13

5

3

3

3

-

3

3

3

-

*Richard  Manley  was  appointed  to  the  Board  on  23  August  2018.    He  attended  all  meetings  following  his 
appointment.

In  addition  to  formal  Management  meetings,  the  Board  communicates  on  a  regular  basis  in  carrying  out  its 
responsibilities in managing the Company.

Performance Evaluation 

In accordance with the AIC Code and guidance (“the Guide to Performance Appraisals for Non-executive directors 
of Investment Companies”) each year a formal performance evaluation is undertaken of the Board as a whole, its 
Committees and the directors in the form of one-to-one meetings between the Chairman and each director.  The 
directors were made aware of the annual performance evaluation on their appointment.  The Chairman provides 
a summary of the findings to the Board, which are discussed at the next meeting and an action plan agreed. The 
performance of the Chairman was evaluated by the other Directors.  

Audit Committee 

The Board has appointed an Audit Committee to make recommendations to the Board in line with its terms of 
reference.  

The committee is chaired by Richard Roth and consists of all four Directors. The Audit Committee believes Mr Roth 
possesses appropriate and relevant financial experience as per the requirements of the AIC Code.  The Board 
considers that the members of the Committee have collectively the skills and experience required to discharge 
their duties effectively.

The Audit Committee’s terms of reference, and how it discharges its duties are listed on pages 37 and 38.

Internal Control

The Directors have overall responsibility for keeping under review the effectiveness of the Company’s systems of 
internal controls. The purpose of these controls is to ensure that proper accounting records are maintained, the 
Company’s assets are safeguarded and the financial information used within the business and for publication is 
accurate and reliable; such a system can only provide reasonable and not absolute assurance against material 
misstatement or loss. The system of internal controls is designed to manage rather than eliminate the risk of failure 
to achieve the business objectives.  The Board continually reviews financial results and investment performance.

Pennywise  Accounting  Limited  continued  their  role  as  Administration  Manager  during  the  year  having  been 
appointed  by  the  Board  on  1  April  2017.  Following  the  appointment  of  Seneca  as  Investment  Manager,  City 
Partnership, who also acted as receiving agent in relation to the B share Offer during the year, will become the 
custodian of the documents of title relating to the Company’s unquoted investments, taking over from Larpent 
Newton & Co Ltd.

The Directors confirm that they have established a continuing process throughout the year and up to the date of 
this report for identifying, evaluating and managing the significant potential risks faced by the Company and have 
reviewed the effectiveness of the internal control systems. As part of this process an annual review of the internal 
control systems is carried out in accordance with the FRC’s Guidance on Risk Management, Internal Control and 
Related Financial and Business Reporting.   

35

The risk management and internal control systems include the production and review of monthly bank statements 
and quarterly management accounts. All outflows made from the Company’s accounts require the authority of 
signatories from the Board or Administration Manager. The Company is subject to a full annual audit. Further to 
this, the Audit Partner has open access to the Directors of the Company.  

Financial Risk Management Objectives and Policies

The Company is exposed to the risks arising from its operational and investment activities. Further details can be 
found in note 16 to the Financial Statements. 

Relations with Shareholders

Shareholders have the opportunity to meet the Board at the AGM.  In addition the Board is available to answer 
any questions a shareholder may have and is also happy to respond to any written queries made by shareholders 
during the course of the year and can be contacted at the Company’s registered office:  12 The Parks, Haydock, 
Newton-Le-Willows WA12 0JQ.

Compliance Statement

As previously indicated, the Board considers that reporting against the principles and recommendations of the 
AIC Code, and by reference to the AIC Guide (which incorporates the UK Corporate Governance Code), will provide 
better information to shareholders.  

The Company has complied with the recommendations of the AIC Code and the relevant provisions of the UK 
Corporate Governance Code, except as set out below:

1.  The Company does not have a Chief Executive Officer or a senior independent Director. The Board does not 

consider this necessary as it does not have any executive directors. 

2.  New  Directors  do  not  receive  a  full,  formal  and  tailored  induction  on  joining  the  Board.  Such  matters  are 

addressed on an individual basis as they arise. 

3.  The Company conducts a formal review as to whether there is a need for an internal audit function. However, 
the Directors do not consider that an internal audit would be an appropriate control for this VCT at this time. 

4.  The Company does not have a Remuneration Committee as it does not have any executive directors. 

5.  The Company does not have a Nomination Committee as these matters are dealt with by the Board. 

For  the  reasons  set  out  in  the  AIC  Guide,  and  as  explained  in  the  UK  Corporate  Governance  Code,  the  Board 
considers the above provisions are not relevant to the position of the Company, being an investment company 
managed by the Board. In particular, all of the Company’s day-to-day administrative functions are outsourced to 
third parties. As a result the Company has no executive directors, employees or internal operations.  

By Order of the Board

Craig Hunter
Company Secretary
26 April 2019

36

Audit Committee Report 

This report is submitted in accordance with The UK Corporate Governance Code in respect of the year ended 31 
December 2018 and describes the work of the Audit Committee in discharging its responsibilities.

The Committee’s key objective is the provision of effective governance of the appropriateness of the Company’s 
financial reporting, the performance of the auditor and the management of the internal control and business risks 
systems.  The Directors forming the Audit Committee can be found on page 35. 

The Audit Committee’s terms of reference include the following responsibilities:

• 

• 

• 

• 

reviewing  and  making  recommendations  to  the  Board  in  relation  to  the  Company’s  published  Financial 
Statements and other formal announcements relating to the Company’s financial performance;
advising the Board on whether the Annual Report and Financial Statements, taken as a whole, is fair, balanced 
and understandable;
advising the Board on whether the Annual Report and Financial Statements provides necessary information 
for shareholders to assess performance, business model and strategy;
reviewing and making recommendations to the Board in relation to the Company’s internal control (including 
internal financial control) and risk management systems;

•  periodically considering the need for an internal audit function;
•  making recommendations to the Board in relation to the appointment, re-appointment and removal of the 

• 

external auditor and approving the remuneration and terms of engagement of the external auditor;
reviewing and monitoring the external auditors’ independence and objectivity and the effectiveness of the 
audit process, taking into consideration relevant UK professional regulatory requirements; and

•  monitoring the extent to which the external auditor is engaged to supply non-audit services.

As part of the process of working with the Board to maximise effectiveness, meetings of the Committee usually 
take place immediately prior to a Board meeting when appropriate and a report is provided on relevant matters 
to enable the Board to carry out its duties.

The Committee reviews its terms of reference and its effectiveness periodically and recommends to the Board any 
changes required as a result of the review. The terms of reference are available on request from the Company 
Secretary.  The  Committee  meets  at  least  twice  each  year  and  on  an  ad  hoc  basis  as  necessary.  It  has  direct 
access to the Company’s external auditor. In October 2018, James Cowper Kreston tendered their resignation as 
auditors, as they had decided to withdraw from auditing Public Interest Entities (which includes VCTs) for the time 
being due to the increasing regulatory landscape and associated costs. Following a competitive tender instigated 
by the Committee, the Board appointed UHY Hacker Young LLP to fill the casual vacancy to audit the accounts 
for  the  year  to  31  December  2018,  and  is  happy  to  recommend  UHY  Hacker  Young  LLP  for  reappointment  at 
the AGM in relation to the audit for the year ending 31 December 2019. UHY Hacker Young LLP do not provide 
any other non-audit services and as such, the Committee does not believe there is any risk that these-non audit 
services  can  influence  their  independence  or  objectivity  due  to  the  associated  fee.  When  considering  whether 
to recommend the reappointment of the external auditor the Committee takes into account the tenure of the 
current auditor in addition to comparing the fees charged by similar sized audit firms. Once the Committee has 
made a recommendation to the Board in relation to the appointment of the external auditor, this is then ratified 
at the AGM through an Ordinary Resolution.

The effectiveness of the external audit is assessed as part of the Board evaluation conducted annually and by 
the quality and content of the Audit Plan and Report provided to the Committee by the Auditor and the resultant 
discussions on topics raised. The Committee also challenges the Auditor when present at a Committee meeting 
if appropriate. 

The Company does not have an independent internal audit function as it is not deemed appropriate given the size 
of the Company and the nature of the Company’s business. However, the Committee considers annually whether 
there is a need for such a function and if so would recommend this to the Board. 

37

The Committee will monitor the significant risks at each meeting and the Administration Manager will work closely 
with the Auditors to mitigate the risks and the resultant impact.

During the period ended 31 December 2018, the Audit Committee discharged its responsibilities by:

• 

• 

• 

• 
• 
• 
• 

reviewing and approving the external auditor’s terms of engagement and remuneration including appointing 
a new audit firm following a competitive tender after the resignation of the James Cowper Kreston;
reviewing  the  external  auditor’s  plan  for  the  audit  of  the  Company’s  Financial  Statements,  including 
identification of key risks and confirmation of auditor independence;
reviewing Pennywise’s statement of internal controls in relation to the Company’s business and assessing the 
effectiveness of those controls in minimising the impact of key risks;
reviewing the appropriateness of the Company’s accounting policies;
reviewing the Company’s draft Annual Financial and Interim results statements prior to Board approval; 
reviewing the Company’s going concern status as referred to on page 32; and
reviewing the external auditor’s Audit Findings Report to the Committee on the annual Financial Statements.

The Committee has considered the Report and Financial Statements for the year ended 31 December 2018 and 
has  reported  to  the  Board  that  it  considers  them  to  be  fair,  balanced  and  understandable  and  providing  the 
information necessary for shareholders to assess the Company’s performance, business model and strategy.

Significant Risks

The Audit Committee is responsible for considering and reporting on any significant risks that arise in relation to 
the audit of the Financial Statements.  The Committee and the Auditors have identified the most significant risks 
for the Company as:

•  Valuation and ownership of investment portfolio: The Auditors give special audit consideration to the valuation 
and  ownership  of  investments  and  the  supporting  data  provided  by  Pennywise  and  the  Board  of  Seneca 
Growth Capital.  The impact of this risk could be a large movement in the Company’s net asset value.  The 
valuations  are  supported  by  investee  company  audited  Financial  Statements  and/or  third  party  evidence. 
These give comfort to the Audit Committee.

•  Management override of financial controls:  The Auditors specifically review all significant accounting estimates 
that  form  part  of  the  Financial  Statements  and  consider  any  material  judgements applied by  the  Board  or 
Investment Manager during the preparation of the Financial Statements.

•  Compliance  with  HMRC  conditions  for  maintenance  of  approved  VCT  status:  Philip  Hare  &  Associates  LLP 
provide the Company with advice on the on-going compliance with the HMRC rules and regulations concerning 
VCTs. 

•  Recognition of revenue from investments: Revenue is recognised when the Company’s right to the return is 
established in accordance with the Statement of Recommended Practice.  The Company had no revenue in 
2018, and Pennywise has confirmed this to the Audit Committee. 

These issues were discussed with Pennywise, the Board of Seneca Growth Capital and the Auditor at the conclusion 
of the audit of the Financial Statements.

The  Audit  Committee  is  also  responsible  for  considering  and  reporting  on  any  significant  issues  that  arise  in 
relation to the audit of the Financial Statements.  The Audit Committee can confirm that there were no significant 
issues  to  report  to  the  shareholders  in  respect  of  the  audit  of  the  Financial  Statements  for  the  year  ended  31 
December 2018.

Richard Roth
Audit Committee Chairman
26 April 2019 

38

Directors’ Remuneration Report and Policy 

Introduction

This report is submitted in accordance with the requirements of s420-422 of the Companies Act 2006, in respect of 
the year ended 31 December 2018. A resolution to approve the Directors’ Remuneration Policy and the Directors’ 
Remuneration Report will be proposed at the Annual General Meeting on 10 June 2019. The statement of Directors’ 
Remuneration Policy was last approved by shareholders at the Annual General Meeting on 2 June 2016, with the 
Directors’ Remuneration Report approved at last year’s AGM.

The Company’s independent auditor, UHY Hacker Young LLP, is required to give its opinion on certain information 
included in this report as indicated below. Their report on these and other matters is set out on pages 42 to 46.

Consideration by the Directors of Matters Relating to Directors’ Remuneration

The  Board  as  a  whole  considers  Directors’  remuneration  and  has  not  appointed  a  separate  committee  in  this 
respect.  

Statement of the Company’s policy on Directors’ Remuneration  

The Board manages the Company and consists of four Directors, who meet formally as a Board at least four times 
a year and on other occasions as necessary, to deal with the important aspects of the Company’s affairs.  Seneca 
was appointed as the Company’s Investment Manager on 23 August 2018 and are responsible for the management 
of  the  investments  made  from  the  B  share  pool,  although  management  of  the  investments  in  the  Company’s 
Ordinary share pool has been delegated to the members of the Board of the Company serving immediately prior 
to the appointment of Seneca (the Commercial Advisory Committee or “CAC”). Directors are appointed with the 
expectation that they will serve for a period of at least three years.  All Directors retire at the first general meeting 
after election and thereafter one third of all Directors are subject to retirement by rotation at subsequent Annual 
General Meeting. Directors who have served for more than nine years are subject to annual re-election in line with 
practices recommended in the AIC Corporate Governance Code. Re-election will be recommended by the Board 
but is dependent upon a shareholder vote. 

Each Director has received a letter of appointment. A Director may resign by notice in writing to the Board at any 
time. With effect from 7 October 2015, the Directors who served prior to that date are entitled to compensation 
payable upon early termination of their contract in respect of any unexpired notice period and a pro rata proportion 
of any performance fees payable to the Commercial Advisory Committee accruing at the date of resignation up to 
five years from the date of resignation.

Each Director’s annual fee is currently £12,750 per annum inclusive of all expenses. It is intended that Directors’ 
fees will be reviewed contemporaneously with the appointment of at least one more new Director.

The performance incentive fee relevant to those Directors serving up to 7 October 2015 were revised under an 
agreement dated 7 October 2015. The new arrangements froze the sum due to those Directors serving up to 7 
October 2015 at £702,000 (the accrued liability as disclosed in the 2014 audited Financial Statements) which will 
only start to become payable once a further 55.75p of dividends have been paid in respect of each share (such that 
original subscribing shareholders will have received 80p per share in dividends): of this 55.75p of dividends, 10p 
was paid on 25 January 2019 and the Board has indicated its intention to approve a further dividend of 18p in the 
near future. This liability will then be paid at the rate of 25% of subsequent dividends until a liability of £702,000 
has been discharged; this is in keeping with the original approved arrangement. No liability will be payable to any 
relevant Director after five years from his resignation from the Company. Following the payment of this liability, 
any further performance fee in the future will be payable at the reduced rate of 10% of total distributions above 
the audited total return at 31 December 2014, with the outstanding balance subject to a hurdle rate of 6% per 
annum, and will be split between the CAC based on a formula driven by relative length of service starting from 7 
October 2015. Further details of the revised arrangements are set out in note 6 to the Financial Statements.

39

The  Directors  may  at  their  discretion  pay  additional  sums  in  respect  of  specific  tasks  carried  out  by  individual 
Directors on behalf of the Company. In this context, an additional one off payment has been made to Richard 
Roth of £5,000 as compensation for work undertaken in relation to the setting up of the new B share pool and 
preparation  of  the  prospectus  associated  with  the  offer  for  subscription  for  new  B  shares  launched  on  9  May 
2018. Half of this was charged directly to the Company, and half was paid by Seneca.

Company Performance 

The  Board  is  responsible  for  the  Company’s  investment  strategy  and  performance.  The  performance  table  on 
page 25 shows the performance of the Company.

Directors’ Emoluments (Information Subject to Audit)

Amount of each Director’s emoluments:

Directors’ fees

John Hustler (Chairman)

Charles Breese

Richard Roth

Richard Manley

Total

Year ended
31 December 2018
£

Year ended
31 December 2017
£

12,750

12,750

15,250

-

40,750

12,750

12,750

12,750

-

38,250

Richard Manley, a director of the Investment Manager, has elected to waive his Director’s fee, until the operating 
costs are less than the expenses cost cap.

The Directors did not receive any other form of emoluments in addition to the directors’ fees during the year. 
John Hustler, Charles Breese and Richard Roth, as members of the CAC, may be entitled to performance fees in 
the future as referred to above. Directors may be entitled to fees from investee companies when acting on the 
Company’s behalf as Director, Observer or Consultant to those investees.

By order of the Board

Craig Hunter
Company Secretary
26 April 2019

40

Directors’ Responsibilities Statement 

The Directors are responsible for preparing the Annual Report and the Financial Statements in accordance with 
applicable laws and regulations. 

Company  law  requires  the  Directors  to  prepare  Financial  Statements  for  each  financial  year.  Under  that  law 
the  Directors  have  elected  to  prepare  the  Financial  Statements  in  accordance  with  United  Kingdom  Generally 
Accepted Accounting Practice (United Kingdom Accounting Standards and applicable laws). Under company law 
the Directors must not approve the Financial Statements unless they are satisfied that they give a true and fair 
view of the state of affairs and profit or loss of the Company for that period. 

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 UK Accounting Standards have been followed, subject to any material departures 
disclosed and explained in the Financial Statements; and

•  prepare the Financial Statements on the going concern basis unless it is inappropriate to presume that the 

Company will continue in business.

The Directors are responsible for keeping adequate accounting records that are sufficient to show and explain the 
Company’s transactions and disclose with reasonable accuracy at any time the financial position of the Company 
and  enable  them  to  ensure  that  the  Financial  Statements  comply  with  the  Companies  Act  2006. They  are  also 
responsible for safeguarding the assets of the Company and hence for taking reasonable steps for the prevention 
and detection of fraud and other irregularities.

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

Each of the Directors confirms that, to the best of their knowledge:

• 
• 

• 

• 

there is no relevant audit information of which the Company’s auditor is unaware;
the Directors have taken all steps that they ought to have taken to make themselves aware of any relevant 
audit information and to establish that the auditor is aware of that information;
the Financial Statements, prepared in accordance with the applicable set of accounting standards, give a true 
and fair view of the assets, liabilities, financial position and profit or loss of the Company; and
the  Investment  Manager’s  Report  Business  Review  and  Directors’  Report  includes  a  fair  review  of  the 
development and performance of the business and the position of the Company, together with a description 
of the principal risks and uncertainties that it faces.

On behalf of the Board

John Hustler
Chairman
26 April 2019

41

Report of the Independent Auditor to the Members of 
Seneca Growth Capital VCT Plc 

Opinion

We have audited the Financial Statements of Seneca Growth Capital VCT Plc for the year ended 31 December 2018 
which comprise the Statement of Comprehensive Income, the Balance Sheet, the Statement of Changes in Equity, 
the Cash Flow Statement and the related notes to the Financial Statements, including a summary of significant 
accounting policies. The financial reporting framework that has been applied in their preparation is applicable law 
and United Kingdom Accounting Standards, including Financial Reporting Standard 102 “The Financial Reporting 
standard applicable in the UK and Republic of Ireland”.

In our opinion the Financial Statements:

• 

give a true and fair view of the state of the Company’s affairs as at 31 December 2018 and of the Company’s 
return for the year then ended;

•  have been properly prepared in accordance with United Kingdom generally Accepted Accounting Practice; and
•  have been prepared in accordance with the requirements of the Companies Act 2006.

Basis for opinion

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

Conclusions relating to principal risks, going concern and viability statement

We have nothing to report in respect of the following information in the Annual Report, in relation to which the 
ISAs (UK) require us to report to you whether we have anything material to add or draw attention to:

• 

• 

• 

the disclosures in the Annual Report set out on pages 26 to 27 that describe the principal risks and explain 
how they are being managed or mitigated;
the  Directors’  confirmation  set  out  on  page  26  in  the  Annual  Report  that  they  have  carried  out  a  robust 
assessment of the principal risks facing the Company, including those that would threaten its business model, 
future performance, solvency or liquidity;
the Directors’ statement set out on page 32 in the Financial Statements about whether the Directors considered 
it appropriate to adopt the going concern basis of accounting in preparing the Financial Statements and the 
Directors’  identification  of  any  material  uncertainties  to  the  Company’s  ability  to  continue  to  do  so  over  a 
period of at least twelve months from the date of approval of the Financial Statements;

•  whether the Directors’ statement relating to going concern required under the Listing Rules in accordance 

• 

with Listing Rule 9.8.6R(3) is materially inconsistent with our knowledge obtained in the audit; 
the Directors’ explanation set out on page 32 in the Annual Report as to how they have assessed the prospects 
of the Company, over what period they have done so and why they consider that period to be appropriate, 
and  their  statement  as  to  whether  they  have  a  reasonable  expectation  that  the  Company  will  be  able  to 
continue in operation and meet its liabilities as they fall due over the period of their assessment, including any 
related disclosures drawing attention to any necessary qualifications or assumptions.

42

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit 
of  the  Financial  Statements  of  the  current  period  and  include  the  most  significant  assessed  risks  of  material 
misstatement (whether or not due to fraud) we identified, including those which had the greatest effect on: the 
overall audit strategy, the allocation of resources in the audit; and directing the efforts of the engagement team. 

These matters were addressed in the context of our audit of the Financial Statements as a whole, and in forming 
our opinion thereon, and we do not provide a separate opinion on these matters.

We identified the following risks that we believe had the greatest impact on our audit strategy and scope:

Key risks

Approach taken for the assessed risks

The  carrying  value  of  the  investments  and  the 
recognition  of  realised  and  unrealised  gains  and 
losses.  The  investment  portfolio  and  associated 
realised and unrealised gains and losses are the key 
driver to the financial performance of the Company 
and  have  the  greatest  impact  on  both  the  income 
statement and balance sheet.

Compliance  with  the  VCT  rules  is  necessary  to 
maintain the VCT status and associated tax benefits.

For quoted shares, we tested the value of the year-
investments  by  reference  to  market  price 
end 
information at the year-end.

Measurement of the value of unquoted investments 
included significant assumptions and judgement. 

Our  audit  work  included,  but  was  not  restricted  to, 
obtaining  an  understanding  of  how  the  valuations 
were  performed,  consideration  of  whether  they 
were made in accordance with published guidance, 
discussions  with  management,  and 
reviewing 
and  challenging  the  basis  and  reasonableness  of 
assumptions  made  by  management  in  conjunction 
with available supporting information.

The  purchase  and  sale  of  investments  were  agreed 
to contract notes and cash movements on a sample 
basis.  The  realised  gains  and  losses  on  the  sale 
of  investments  were  re-calculated  for  both  the 
individual transactions on a sample basis and for the 
total portfolio. 

Our  audit  work  in  respect  of  the  compliance  with 
the  VCT  rules  involved  testing  the  conditions  for 
maintaining approval as a VCT as set out by HMRC. 
Each of the conditions was tested in turn in order to 
assess whether it had been met as at the year-end.

Our application of materiality

We apply the concept of materiality in planning and performing our audit, in evaluating the effect of misstatements 
on our audit and on the Financial Statements. We define financial statement materiality as the magnitude by which 
misstatements, including omission, could influence the economic decisions taken on the basis of the Financial 
Statements by reasonable users.

43

 
We also determine a level of performance materiality which we use to determine the extent of testing needed 
to  reduce  to  an  appropriately  low  level  the  probability  that  the  aggregate  of  uncorrected  and  undetected 
misstatements exceeds materiality for the Financial Statements as a whole.

We determine materiality for the Financial Statements as a whole to be £190,000. In determining this we based 
our assessment on an average of four key indicators, being turnover, the return before tax, the net assets and 
gross assets of the Company. On the basis of our risk assessment, together with our assessment of the Company’s 
control environment, our judgement is that performance materiality for the Financial Statements should be 75% 
of materiality, being £142,500.

We agreed with the Audit Committee that we would report to them all uncorrected audit differences in excess 
of £9,500 which is set at 5% of planning materiality, as well as differences below that threshold that, in our view, 
warranted reporting on qualitative grounds. We evaluate any uncorrected misstatements against both quantitative 
measures of materiality discussed above and in light of other relevant qualitative considerations in forming our 
opinion.

An overview of the scope of our audit

As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the 
Financial Statements. In particular, we looked at where the Directors made subjective judgements, for example in 
respect of significant accounting estimates that involved making assumptions and considering future events that 
are inherently uncertain. 

We tailored the scope of our audit to ensure that we performed sufficient work to be able to give an opinion on 
the Financial Statements as a whole, taken into account an understanding of the structure of the Company, its 
activities, the accounting processes and controls, and the industry in which it operates. Our planned audit testing 
was directed accordingly and was focused on areas where we assessed there to be the highest risk of material 
misstatement. During the audit we reassessed and re-evaluated audit risks and tailored our approach accordingly.

The audit testing included substantive testing on significant transactions, balances and disclosures, the extent of 
which was based on various factors such as our overall assessment of the control environment, the effectiveness 
of controls and the management of specific risks.

We  communicated  with  those  charged  with  governance  regarding,  among  other  matters,  the  planned  scope 
and timing of the audit and significant findings, including any significant deficiencies in internal control that we 
identified during the audit. 

Other information

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

In connection with our audit of the Financial Statements, our responsibility is to read the other information and, 
in doing so, consider whether the other information is materially inconsistent with the Financial Statements or 
our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material 
inconsistencies or apparent material misstatements, we are required to determine whether there is a material 
misstatement of the Financial Statements or a material misstatement of the other information. If, based on the 
work we have performed, we conclude that there is a material misstatement of this other information; we are 
required to report that fact. We have nothing to report in this regard. 

In this context, we also have nothing to report in regard to our responsibility to specifically address the following 
items  in  the  other  information  and  to  report  as  uncorrected  material  misstatements  of  the  other  information 
where we conclude that those items meet the following conditions:

44

• 

Fair, balanced and understandable set out on page 30 – the statement given by the Directors that they 
consider the Annual Report and Financial Statements taken as a whole is fair, balanced and understandable 
and  provides  the  information  necessary  for  shareholders  to  assess  the  Company’s  performance,  business 
model and strategy, is materially inconsistent with our knowledge obtained in the audit; or

•  Audit  Committee  reporting  set  out  on  pages  37  and  38  –  the  section  describing  the  work  of  the  Audit 

Committee does not appropriately address matters communicated by us to the Audit Committee; or

•  Directors’ statement of compliance with the UK Corporate Governance Code set out on page 36 – the 
parts of the Directors’ statement required under the Listing Rules relating to the Company’s compliance with 
the UK Corporate Governance Code containing provisions specified for review by the auditor in accordance 
with Listing Rule 9.8.10R (2) do not properly disclose a departure from a relevant provision of the UK Corporate 
Governance Code.

Opinions on other matters prescribed by the Companies Act 2006

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

• 

• 

• 

the part of the Directors’ Remuneration Report to be audited has been properly prepared in accordance with 
the Companies Act 2006; and
the information given in the Strategic Report and the Directors’ Report for the financial year for which the 
Financial Statements are prepared is consistent with the Financial Statements; and
the  Strategic  Report  and  the  Directors’  Report  have  been  prepared  in  accordance  with  applicable  legal 
requirements.

Matters on which we are required to report by exception

In the light of the knowledge and understanding of the Company and its environment obtained in the course of 
the audit, we have not identified material misstatements in the Strategic Report or the Directors’ Report. 

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

• 

• 

adequate accounting records have not been kept, or returns adequate for our audit have not been reviewed 
from branches not visited by us; or
the financial statements and the part of the Directors’ Remuneration Report to be audited are not in agreement 
with the accounting records and returns; or
• 
certain disclosures of Directors’ remuneration specified by law are not made; or
•  we have not received all the information and explanations we require for our audit.

Responsibilities of Directors

As explained more fully in the Directors’ Responsibilities Statement set out on page 41, the Directors are responsible 
for the preparation of the Financial Statements and for being satisfied that they give a true and fair view, and for 
such internal control as the Directors determine is necessary to enable the preparation of Financial Statements 
that are free from material misstatement, whether due to fraud or error. 

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

Auditor’s responsibilities for the audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the Financial Statements as a whole are free 
from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our 
opinion. 

Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance 
with  ISAs  (UK)  will  always  detect  a  material  misstatement  when  it  exists.  Misstatements  can  arise  from  fraud 

45

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 further description of our responsibilities for the audit of the Financial Statements is located on the Financial 
Reporting  Council’s  website  at:  www.frc.org.uk/auditors/audit-assurance.  This  description  forms  part  of  our 
auditor’s report.

Other matters which we are required to address

We were appointed by Seneca Growth Capital VCT Plc on 16 November 2018. The non-audit services prohibited 
by the FRC’s Ethical Standard were not provided to the Company and we remain independent of the Company in 
conducting our audit.

Our audit opinion is consistent with the additional report to the Audit Committee. 

Use of our report

This report is made solely to the Company’s members, as a body, in accordance with Chapter 3 of Part 16 of the 
Companies Act 2006. Our audit work has been undertaken so that we might state to the Company’s members 
those matters we are required to state to them in an auditors’ 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.

Daniel Hutson (Senior Statutory Auditor)
For and on behalf of 
UHY Hacker Young
Chartered Accountants
Statutory Auditors

Quadrant House
4 Thomas More Square
London, E1W 1YW

26 April 2019

46

 
Income Statement

Combined Year to 31 
December 2018

Combined Year to 31 
December 2017

Revenue Capital

Total Revenue Capital

Total

Note

£’000

£’000

£’000

£’000

£’000

£’000

Gain on disposal of fixed asset investments 

Loss on valuation of fixed asset investments 

Income

Performance fee

Investment management fee net of cost cap

Other expenses

Return on ordinary activities before tax

Taxation on return on ordinary activities

10

10

2

6

3

4

7

-

-

-

-

903

903

(716)

(716)

-

-

 (26)

(26)

36

(18)

18

-

-

-

-

-

(113)

-

(113)

(118)

19

19

(359)

(359)

-

91

-

-

-

91

-

(118)

(77)

143

-

-

66

-

66

(118)

(249)

(367)

-

-

-

(118)

(249)

(367)

Return  on ordinary activities after tax

(77)

143

Return on ordinary activities after tax 
attributable to:
Owners of the fund

(77)

143

66

(118)

(249)

(367)

There was no other Comprehensive Income recognised during the year

• 

The ‘Total’ column of the income statement and statement of comprehensive income is the profit and loss 
account of the Company; the supplementary revenue return and capital return columns have been prepared 
under guidance published by the Association of Investment Companies.

•  All revenue and capital items in the above statement derive from continuing operations.
• 

The Company has only one class of business and derives its income from investments made in shares and 
securities and from bank and money market funds.

The Company has no recognised gains or losses other than the results for the year as set out above.

The accompanying notes are an integral part of the Financial Statements.

47

Ordinary Share Income Statement 
(non-statutory analysis)

Ordinary shares
Year to 31 December 2018

Ordinary shares
Year to 31 December 2017

Revenue Capital

Total Revenue Capital

Total

Note

£’000

£’000

£’000

£’000

£’000

£’000

Gain on disposal of fixed asset investments 

 10

Loss on valuation of fixed asset investments 

10

Income

Performance fee

Investment management fee

Other expenses

Return on ordinary activities before tax

Taxation on return on ordinary activities

2

6

3

4

7

-

-

-

-

-

(59)

(59)

903

903

(716)

(716)

-

-

 (26)

(26)

-

-

-

(59)

(118)

-

-

-

-

-

19

19

(359)

(359)

-

91

-

-

-

91

-

(118)

161

102

(118)

(249)

(367)

-

-

-

-

-

-

Return  on ordinary activities after tax

(59)

161

102

(118)

(249)

(367)

Return on ordinary activities after tax 
attributable to:
Owners of the fund

(59)

161

102

(118)

(249)

(367)

Earnings per share – basic and diluted

8

(0.7)p

2.0p

1.3p

(1.5)p

(3.0)p

(4.5p)

48

B Share Income Statement (non-statutory analysis)

B shares
Year to 31 December 2018

B shares
Year to 31 December 2017

Revenue Capital

Total Revenue Capital

Total

Note

£’000

£’000

£’000

£’000

£’000

£’000

Gain on disposal of fixed asset investments 

 10

Loss on valuation of fixed asset investments 

10

Income

Performance fee

Investment management fee net of cost cap

Other expenses

Return on ordinary activities before tax

Taxation on return on ordinary activities

2

6

3

4

7

-

-

-

-

-

-

-

 -

-

-

-

-

36

(18)

18

(54)

-

(54)

(18)

(18)

(36)

-

-

-

Return  on ordinary activities after tax

(18)

(18)

(36)

Return on ordinary activities after tax 
attributable to:
Owners of the fund

(18)

(18)

(36)

Earnings per share – basic and diluted

8

(0.45)p (0.45)p

(0.9)p

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

49

Statement of Changes in Equity

Share 
capital
£’000

Share
premium  
£’000

Special 
distributable 
reserve
£’000

Capital 
redemption 
reserve
£’000

Capital 
reserve 
gains/
(losses)
£’000

Capital 
reserve  
holding 
gains/
(losses)
£’000

Revenue 

reserve Total
£’000 £’000

3,397

38

(121)

(53)

(1,772) 5,547

As at 1 January 2017

4,058

Revenue return on 
ordinary activities after 
tax

-

-
Performance fee allocated 
as capital expenditure

Current period gains on 
disposal

Current period losses on 
fair value of investments

Prior years’ unrealised 
losses now realised

-

-

-

Balance as at 31 
December 2017

4,058

-

-

-

-

-

-

-

B share issue

40

3,995

Capital restructuring

(3,977)

-

-

-

-

-

-

3,397

-

-

Capital reduction

Revenue return on 
ordinary activities after 
tax

Expenses charged to 
capital

-

-

-

-
Performance fee allocated 
as capital expenditure

Current period gains on 
disposal

Current period losses on 
fair value of investments

Prior years’ unrealised 
losses now realised

-

-

-

(3,427)

7,442

-

-

-

-

-

-

-

-

-

-

-

-

Balance as at 31 
December 2018

121

568

10,839

-

-

-

-

-

38

-

3,977

(4,015)

-

-

-

-

-

-

-

-

91

19

-

-

-

-

(359)

(421)

421

(118)

(118)

-

-

-

-

91

19

(359)

-

(432)

9

(1,890) 5,180

-

-

-

-

(18)

(26)

903

-

-

-

-

-

-

-

-

(716)

602

(602)

- 4,035

-

-

-

-

(77)

(77)

-

-

-

-

-

(18)

(26)

903

(716)

-

1,029

(1,309)

(1,967) 9,281

Refer to note 14 for details of the share restructure and capital reduction undertaken in the year. 

The accompanying notes are an integral part of the Financial Statements. 

50

Ordinary Shares - Statement of Changes in Equity

Share 
capital
£’000

Share
premium  
£’000

Special 
distributable 
reserve
£’000

Capital 
redemption 
reserve
£’000

Capital 
reserve 
gains/
(losses)
£’000

Capital 
reserve  
holding 
gains/
(losses)
£’000

Revenue 

reserve Total
£’000 £’000

As at 1 January 2017

4,058

Revenue return on 
ordinary activities after 
tax

-

-
Performance fee allocated 
as capital expenditure

Current period gains on 
disposal

Current period losses on 
fair value of investments

Prior years’ unrealised 
losses now realised

-

-

-

Balance as at 31 
December 2017

4,058

Capital restructuring

(3,977)

Capital reduction

Revenue return on 
ordinary activities after 
tax

Expenses charged to 
capital

-

-

-

-
Performance fee allocated 
as capital expenditure

Current period gains on 
disposal

Current period losses on 
fair value of investments

Prior years’ unrealised 
gains now realised

Balance as at 31 
December 2018

-

-

-

81

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

3,397

38

(121)

(53)

(1,772) 5,547

-

-

-

-

-

-

-

-

-

-

-

91

19

-

-

-

-

(359)

(421)

421

(118)

(118)

-

-

-

-

91

19

(359)

-

3,397

38

(432)

9

(1,890) 5,180

-

-

-

-

(26)

903

-

-

-

-

-

-

-

(716)

602

(602)

-

-

-

-

(59)

(59)

-

-

-

-

-

-

(26)

903

(716)

-

1,047

(1,309)

(1,949) 5,282

-

4,015

3,977

(4,015)

-

-

-

-

-

-

-

-

-

-

-

-

-

7,412

51

B Shares - Statement of Changes in Equity

Share 
capital
£’000

Share
premium  
£’000

Special 
distributable 
reserve
£’000

Capital 
redemption 
reserve
£’000

Capital 
reserve 
gains/
(losses)
£’000

Capital 
reserve  
holding 
gains/
(losses)
£’000

Revenue 

reserve Total
£’000 £’000

As at 1 January 2018

B share issue

Capital reduction

Revenue return on 
ordinary activities after 
tax

Expenses charged to 
capital

Balance as at 31 
December 2018

-

40

-

-

-

-

3,995

(3,427)

-

-

-

-

 3,427

-

-

40

568

3,427

-

-

-

-

-

-

-

-

-

-

(18)

(18)

-

-

-

-

-

-

-

-

- 4,035

-

-

(18)

(18)

-

(18)

(18) 3,999

52

Balance Sheet 

Fixed asset investments* 

Current assets:

Debtors

Cash at bank and in hand/(Bank overdraft)

Creditors: amounts falling due within one 
year

Combined as at
31 December 2018

Combined as at
31 December 2017

£’000

5,564

Note

£’000

£’000

£’000

3,293

10

11

12

23

6,446

(291)

7

(160)

(67)

Net current assets

6,178

(220)

Creditors: amounts falling due after more 
than one year

12

(190)

(164)

Net assets

Called up equity share capital

Share premium

Special distributable reserve

Capital redemption reserve

Capital reserve – realised gains and losses

                            – holding gains and losses

Revenue reserve

Total equity shareholders’ funds

*At fair value through profit and loss

13

14

14

14

14

14

14

9,281

121

568

10,839

-

1,029

(1,309)

(1,967)

9,281

5,180

4,058

-

3,397

38

(432)

9

(1,890)

5,180

The accompanying notes are an integral part of the Financial Statements.

The statements were approved by the Directors and authorised for issue on 26 April 2019 and are signed on their 
behalf by:

John Hustler
Chairman
Company No: 04221489

53

Ordinary Share Balance Sheet (non-statutory analysis) 

Fixed asset investments* 

Current assets:

Debtors

Cash at bank and in hand/(Bank overdraft)

Creditors: amounts falling due within one 
year

Ordinary shares as at
31 December 2018

Ordinary Shares as at
31 December 2017

£’000

5,564

Note

£’000

£’000

£’000

2,793

10

11

12

-

2,738

(59)

7

(160)

(67)

Net current assets

2,679

(220)

Creditors: amounts falling due after more 
than one year

12

(190)

(164)

5,282

81

-

7,412

-

1,047

(1,309)

(1,949)

5,282

65.1p

5,180

4,058

-

3,397

38

(432)

9

(1,890)

5,180

63.8p

Net assets

Called up equity share capital

Share premium

Special distributable reserve

Capital redemption reserve

Capital reserve – realised gains and losses

                            – holding gains and losses

Revenue reserve

Total equity shareholders’ funds

Net asset value per share

*At fair value through profit and loss

13

14

14

14

14

14

14

9

54

B Share Balance Sheet (non-statutory analysis)

B shares as at
31 December 2018

B shares as at
31 December 2017

Note

£’000

£’000

£’000

£’000

Fixed asset investments* 

Current assets:

Debtors

Cash at bank and in hand

Creditors: amounts falling due within one 
year

Net current assets

Creditors: amounts falling due after more 
than one year

Net assets

Called up equity share capital

Share premium

Special distributable reserve

Capital redemption reserve

Capital reserve – realised gains and losses

                            – holding gains and losses

Revenue reserve

Total equity shareholders’ funds

Net asset value per share

*At fair value through profit and loss

23

3,708

(232)

-

500

3,499

3,999

40

568

3,427

-

(18)

-

(18)

3,999

99.1p

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

10

11

12

12

13

14

14

14

14

14

14

9

55

Statement of Cash Flows 

Combined Year to 
31 December  2018

Combined Year to 
31 December  2017

Note

£’000

£’000

Cash flows from operating activities

Return on ordinary activities before tax

66

(367)

Adjustments for:

Increase in debtors

Increase/(Decrease) in creditors

Gain on disposal of fixed assets

Loss on valuation of fixed asset investments

Cash from operations

Income taxes paid

Net cash used in operating activities

Cash flows from investing activities

Purchase of fixed asset investments

Sale of fixed asset investments

Total cash flows from investing activities

Cash flows from financing activities

Issue of B shares

Awaiting B share issue

Total cash flows from financing activities

Increase in cash and cash equivalents

Opening cash and cash equivalents

Closing cash and cash equivalents

11

12

10

10

7

10

10

(16)

31

(903)

716

(106)

-

(106)

(500)

2,958

2,458

4,035

219

4,254

6,606

(160)

6,446

(3)

(79)

(19)

359

(109)

-

(109)

-

134

134

-

-

-

25

(185)

(160)

The accompanying notes are an integral part of the Financial Statements.

56

Ordinary Shares Statement of Cash Flows

Ordinary shares
Year to 
31 December  2018

Ordinary shares 
Year to 
31 December  2017

Note

£’000

£’000

Cash flows from operating activities

Return on ordinary activities before tax

102

(367)

Adjustments for:

Decrease/(Increase) in debtors

Increase/(Decrease) in creditors

Gain on disposal of fixed assets

Loss on valuation of fixed asset investments

Cash from operations

Income taxes paid

Net cash used in operating activities

Cash flows from investing activities

Purchase of fixed asset investments

Sale of fixed asset investments

Total cash flows from investing activities

Cash flows from financing activities

Total cash flows from financing activities

Increase in cash and cash equivalents

Opening cash and cash equivalents

Closing cash and cash equivalents

11

12

10

10

7

10

10

7

18

(903)

716

(60)

-

(60)

-

2,958

2,958

-

2,898

(160)

2,738

(3)

(79)

(19)

359

(109)

-

(109)

-

134

134

-

25

(185)

(160)

57

B Shares Statement of Cash Flows

B shares
Year to 
31 December  2018

B shares 
Year to 
31 December  2017

Note

£’000

£’000

Cash flows from operating activities

Return on ordinary activities before tax

Adjustments for:

Increase in debtors

Increase/(Decrease) in creditors

Gain on disposal of fixed assets

Loss on valuation of fixed asset investments

Cash from operations

Income taxes paid

Net cash used in operating activities

Cash flows from investing activities

Purchase of fixed asset investments

Sale of fixed asset investments

Total cash flows from investing activities

Cash flows from financing activities

Issue of B shares

Awaiting B share issue

Total cash flows from financing activities

Increase in cash and cash equivalents

Opening cash and cash equivalents

Closing cash and cash equivalents

11

12

10

10

7

10

10

58

(36)

(23)

13

-

-

(46)

-

(46)

(500)

-

(500)

4,035

219

4,254

3,708

-

3,708

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

Notes to the Financial Statements 

1. Principal Accounting Policies

Basis of preparation

The Financial Statements have been prepared under the historical cost convention, except for the measurement 
at fair value of certain financial instruments, and in accordance with UK Generally Accepted Accounting Practice 
(“GAAP”), including FRS 102 and with the Companies Act 2006 and the Statement of Recommended Practice (SORP) 
‘Financial Statements of Investment Trust Companies and Venture Capital Trusts (revised 2014)’.

The principal accounting policies have remained materially unchanged from those set out in the Company’s 2017 
Annual Report and Financial Statements,  apart from an addition to the policy on allocating expenses partly to 
capital as a result of the introduction of an investment management fee for the B shares, and clarifying the split of 
costs between the two share pools. A summary of the principal accounting policies is set out below.

The Company held all fixed asset investments at fair value through profit or loss. Accordingly, all interest income, 
fee income, expenses and gains and losses on investments are attributable to assets held at fair value through 
profit or loss.

The most important policies affecting the Company’s financial position are those related to investment valuation 
and require the application of subjective and complex judgements, often as a result of the need to make estimates 
about  the  effects  of  matters  that  are  inherently  uncertain  and  may  change  in  subsequent  periods.  These  are 
discussed in more detail below. 

Going Concern

After reviewing the Company’s forecasts and expectations, the Directors have a reasonable expectation that the 
Company has adequate resources to continue in operational existence for the foreseeable future. The Company 
therefore continues to adopt the going concern basis in preparing its Financial Statements.

Key judgements and estimates

The preparation of the Financial Statements requires the Board to make judgements and estimates regarding the 
application of policies affecting the reported amounts of assets, liabilities, income and expenses. Estimates and 
assumptions mainly relate to the fair valuation of the fixed asset investments particularly unquoted investments. 
Estimates are based on historical experience and other assumptions that are considered reasonable under the 
circumstances. The estimates and the assumptions are under continuous review with particular attention paid to 
the carrying value of the investments.

Investments are regularly reviewed to ensure that the fair values are appropriately stated. Unquoted investments 
are valued in accordance with current International Private Equity and Venture Capital Valuation (IPEV) guidelines, 
which can be found on their website at www.privateequityvaluation.com, although this does rely on subjective 
estimates such as appropriate sector earnings multiples, forecast results of investee companies, asset values of 
investee companies and liquidity or marketability of the investments held. 

Although the Directors believe that the assumptions concerning the business environment and estimate of future 
cash flows are appropriate, changes in estimates and assumptions could result in changes in the stated values. 
This could lead to additional changes in fair value in the future.

Functional and presentational currency

The Financial Statements are presented in Sterling (£). The functional currency is also Sterling (£).

59

Cash and cash equivalents

Cash and cash equivalents includes cash in hand, deposits held at call with banks, other short-term highly liquid 
investments with original maturities of three months or less and bank overdrafts. 

Fixed asset investments

The Company’s principal financial assets are its investments and the policies in relation to those assets are set out 
below.  

Purchases  and  sales  of  investments  are  recognised  in  the  Financial  Statements  at  the  date  of  the  transaction 
(trade date).

These investments will be managed and their performance evaluated on a fair value basis and information about 
them is provided internally on that basis to the Board.  Accordingly, as permitted by FRS 102, the investments are 
measured as being fair value through profit or loss on the basis that they qualify as a group of assets managed, 
and whose performance is evaluated, on a fair value basis in accordance with a documented investment strategy.  
The Company’s investments are measured at subsequent reporting dates at fair value.  

In the case of investments quoted on a recognised stock exchange, fair value is established by reference to the 
closing bid price on the relevant date or the last traded price, depending upon convention of the exchange on 
which the investment is quoted. In the case of AIM quoted investments this is the closing bid price. In the case of 
unquoted investments, fair value is established by using measures of value such as the price of recent transactions, 
earnings multiple, discounted cash flows and net assets.  These are consistent with the IPEV guidelines.

Gains and losses arising from changes in fair value of investments are recognised as part of the capital return 
within the Income Statement and allocated to the capital reserve - holding gains/(losses).    

In the preparation of the valuations of assets the Directors are required to make judgements and estimates that 
are reasonable and incorporate their knowledge of the performance of the investee companies.

Fair value hierarchy
Paragraph 34.22 of FRS 102 regarding financial instruments that are measured in the balance sheet at fair value 
requires disclosure of fair value measurements dependent on whether the stock is quoted and the level of the 
accuracy in the ability to determine its fair value. The fair value measurement hierarchy is as follows:

For quoted investments:
Level  1:  quoted  prices  in  active  markets  for  an  identical  asset.  The  fair  value  of  financial  instruments  traded 
in  active  markets  is  based  on  quoted  market  prices  at  the  balance  sheet  date.  A  market  is  regarded  as  active 
if  quoted  prices  are  readily  and  regularly  available,  and  those  prices  represent  actual  and  regularly  occurring 
market transactions on an arm’s length basis. The quoted market price used for financial assets held is the bid 
price at the Balance Sheet date. 

Level 2: where quoted prices are not available (or where a stock is normally quoted on a recognised stock exchange 
that no quoted price is available), the price of a recent transaction for an identical asset, providing there has been 
no significant change in economic circumstances or a significant lapse in time since the transaction took place. 
The Company holds no such investments in the current or prior year. 

For investments not quoted in an active market:
Level  3:  the  fair  value  of  financial  instruments  that  are  not  traded  in  an  active  market  is  determined  by  using 
valuation techniques. These valuation techniques maximise the use of observable data (eg: the price of recent 
transactions, earnings multiple, discounted cash flows and/or net assets) where it is available and rely as little as 
possible on entity specific estimates.

60

There have been no transfers between these classifications in the year (2017: none). The change in fair value for 
the current and previous year is recognised through the profit and loss account.

Current asset investments

No current asset investments were held at 31 December 2018 or 31 December 2017.  Should current assets be 
held, gains and losses arising from changes in fair value of investments are recognised as part of the capital return 
within the Income Statement and allocated to the capital reserve - gains/(losses) on disposal.  

Income

Investment  income  includes  interest  earned  on  bank  balances  and  from  unquoted  loan  note  securities,  and 
dividends.  Fixed returns on debt are recognised on a time apportionment basis so as to reflect the effective yield, 
provided it is probable that payment will be received in due course.

Expenses

All expenses are accounted for on an accruals basis.  Expenses are charged wholly to revenue with the exception 
of the performance fee, which is charged 100% to the capital reserve. In addition, the investment management fee 
charged to the B shares has been split 25% revenue and 75% capital, in line with industry practice and to reflect 
the Board’s estimated split of investment returns which will be achieved by the company’s B shares over the long 
term. Expenses and liabilities not specific to a share class are allocated to the B share pool for a period of three 
years from 1 July 2018 in line with the Articles of Association.

Revenue and capital

The revenue column of the Income Statement includes all income and revenue expenses of the Company.  The 
capital  column  includes  gains  and  losses  on  disposal  and  holding  gains  and  losses  on  investments,  as  well  as 
those  expenses  that  have  been  charged  as  capital  costs.    Gains  and  losses  arising  from  changes  in  fair  value 
of  investments  are  recognised  as  part  of  the  capital  return  within  the  Income  Statement  and  allocated  to  the 
appropriate capital reserve on the basis of whether they are realised or unrealised at the balance sheet date.

Taxation

Current tax is recognised for the amount of income tax payable in respect of the taxable profit for the current or 
past reporting periods using the current tax rate. The tax effect of different items of income/gain and expenditure/
loss is allocated between capital and revenue return on the “marginal” basis as recommended in the SORP.

Deferred tax is recognised on an undiscounted basis in respect of all timing differences that have originated but 
not reversed at the balance sheet date, except as otherwise indicated. 

Deferred tax assets are only recognised to the extent that it is probable that they will be recovered against the 
reversal of deferred tax liabilities or other future taxable profits.  

Financial instruments

The  Company’s  principal  financial  assets  are  its  investments  and  its  cash  and  the  policies  in  relation  to  those 
assets are set out above.  Financial liabilities and equity instruments are classified according to the substance of 
the contractual arrangements entered into. An equity instrument is any contract that evidences a residual interest 
in the assets of the entity after deducting all of its financial liabilities. Where the contractual terms of share capital 
do not have any terms meeting the definition of a financial liability then this is classed as an equity instrument. 

Capital  management  is  monitored  and  controlled  using  the  internal  control  procedures  set  out  on  page  35  of 
this report.  The capital being managed includes equity and fixed-interest investments, cash balances and liquid 
resources including debtors and creditors.

The Company does not have any externally imposed capital requirements.

61

Reserves

Called up equity share capital – represents the nominal value of shares that have been issued.

Share  premium  account  –  includes  any  premiums  received  on  issue  of  share  capital.  Any  transaction  costs 
associated with the issuing of shares are deducted from share premium.

Special distributable reserve – includes cancelled share premium and capital redemption reserves available for 
distribution.

Capital reserve – holding gains and losses – when the Company revalues the investments still held during the 
period with any gains or losses arising being credited/ charged to the Capital reserve – holding gains and losses.

Capital reserve – gains and losses on disposal – when an investment is sold any balance held on the Capital reserve 
– holding gains and losses is transferred to the Capital reserve – gains and losses on disposal, as a movement in 
reserves.

Revenue reserve – represents the aggregate value of accumulated realised profits, less losses and dividends.

Dividends Payable

Dividends  payable  are  recognised  as  distributions  in  the  Financial  Statements  when  the  Company’s  liability  to 
make payment has been established.  This liability is established for interim dividends when they are declared by 
the Board, and for final dividends when they are approved by the shareholders.

2. Income

Dividends received

Loan note interest receivable

3. Investment Management Fee for B shares

Gross Investment management fee

Cost cap refund from Seneca

Investment management fee net 
of cost cap

Year to 
31 December 2018
£’000

Year to 
31 December 2017
£’000

-

-

-

-

-

-

Year to 
31 December 2018
£’000

Year to 
31 December 2017
£’000

24

(42)

(18)

-

-

-

Following its appointment on 23 August 2018, Seneca has received a fee of 2% of the weighted average net asset 
value of the B shares (2017: n/a).  Seneca will also be entitled to certain monitoring fees from investee companies 
and the Board reviews the amounts.

Seneca are entitled to receive a performance incentive fee in relation to the B share pool of an amount equal to 
20%  of  the  Shareholder  Proceeds  arising  in  respect  of  any  performance  period,  provided  that  the  payment  of 
such a fee shall also be conditional upon (i) a return being generated on the B share pool for B Shareholders in 
respect of that performance period of more than 5% per annum (pro-rated if that period is less than a year) and 
(ii) that such a return calculated for the period from 23 August 2018 to the end of the relevant performance period 
exceeds 5% per annum.

62

Shareholder Proceeds are, in relation to the B shares and calculated on a per share basis in relation to the relevant 
share, all amounts paid by way of dividend or other distributions, share buy backs, proceeds on a sale or liquidation 
of the Company and any other proceeds or value received or deemed to be received by the holders of the relevant 
shares (excluding any income tax relief on subscription).

For a three year period with effect from 1 July 2018, expenses are capped at 3% of the weighted average net asset 
value of the B shares, including the management fee (but excluding any performance fee).   (Following this initial 
period, expenses are capped at 3% of the Company’s total net asset value, including the assets in the Ordinary share 
pool). Accordingly Seneca reduced its management fee by £42,000 in the year to 31 December 2018 (2017: n/a).  

Expenses are charged wholly to revenue with the exception of the (gross) investment management fee which has 
been charged 75% to the capital reserve in line with industry practice. 

4. Other Expenses

Directors’ remuneration

Fees payable to the Company’s auditor for the audit of the 
Financial Statements

Fees payable to the Company’s auditor for other services – 
tax compliance

Legal and professional expenses

Accounting and administration services

Other expenses

Year to 
31 December 2018
£’000

Year to 
31 December 2017
£’000

41

14

-

38

9

11

113

38

8

1

41

14

16

118

All  expenses  were  charged  to  the  Ordinary  shares  for  the  period  to  30  June  2018.  In  line  with  the  offer  for 
subscription for B shares, and following the initial allotment of B shares on 23 August 2018, all the Company’s 
general expenses are chargeable to the B share pool for a period of three years from 1 July 2018 (subject to the 
cost cap discussed in note 3). Any expenditure related specifically to assets in one pool is chargeable to that pool.

5. Directors’ Remuneration

Directors’ emoluments:

John Hustler (Chairman)

Charles Breese

Richard Roth

Richard Manley

Year to 
31 December 2018
£

Year to 
31 December 2017
£

12,750

12,750

15,250

-

40,750

12,750

12,750

12,750

-

38,250

Richard Manley, a director of the Investment Manager, has elected to waive his Director’s fee, until the Company’s 
operating costs are less than the expenses cost cap.

Included in the figure above for Richard Roth is £2,500 for work undertaken in relation to the setting up of the new 
B share structure and preparation of the offer for subscription as detailed in the Directors’ Remuneration Report.  
Apart from this, none of the Directors received any other remuneration from the Company during the year.

63

Certain Directors may become entitled to receive a share of the Performance Incentive Fee related to the Ordinary 
share pool as detailed in the Directors’ Remuneration Report on page 39 and in note 6. 

The  Company  has  no  employees  other  than  non-executive  Directors.    The  average  number  of  non-executive 
Directors in the year was three (2017: three). Richard Manley joined the Board on 23 August 2018 which increased 
the number of directors for the remainder of the year from 3 to 4.

6. Performance fees for Ordinary shares

The Commercial Advisory Committee took over management of the Company’s investments on 30 July 2007, and 
at that time, a revised Performance Incentive Scheme was implemented, such that its members would be entitled 
to 20% of all cash returns above the initial net cost to subscribing shareholders of 80p.

On 7 October 2015, this scheme was varied such that any returns above the 31 December 2014 levels would be 
subject to a hurdle, and the share to the CAC reduced from 20% to 10%. The hurdle is a compound 6% per annum 
on any amounts below the latest hurdle still due to be paid to shareholders (i.e. in recognition of dividends paid, 
actual returns to shareholders will be subtracted from the compounding threshold in the year these are paid).

The Total Gross Return at 31 December 2014 on which the performance fee liability of £702,000 was calculated 
was 123.3p, resulting in the quoted net asset value of 114.6p. For the purposes of this note 6, Total Gross Return 
is defined as the total return made by the fund, before the deduction of any dividend payments or accruals and/
or payments made relating to any potential (or actual) performance incentive fee. 

Any dividends paid above  80p will be  split  80%  to  shareholders and 20% to the members of the CAC as at 31 
December  2014  (i.e.  25%  of  all  dividends  paid  to  shareholders),  until  shareholders  have  received  dividends 
totalling 114.6p. 

A performance fee may be payable on any further dividends above this level, but only if the hurdle applicable at 
that time has been met. 

As at 31 December 2018, the Total Gross Return is 91.68p, and so 2.34p per share totalling £190,000 has been 
accrued (31 December 2017, 90.1p, 2.02p and £164,000).

Assuming the only dividends paid on the Ordinary shares in the year are the 10p dividend per share paid on 25 
January 2019, and the 18p per share expected to be declared soon after this Annual Report has been submitted 
to Companies House, the Total Gross Return would need to exceed 152.9p at 31 December 2019 before any fee 
above £702,000 could be due, and at that time, it would be 10% of any cash payments made above this threshold.  
If such a performance fee is not triggered (as it has not been in this financial year) the hurdle, net of dividends 
paid, increments by a compound annual growth rate of 6%, applied quarterly.

64

7. 

Tax on Ordinary Activities

The corporation tax charge for the period was £nil (2017: £nil).
The current rate of tax is the small companies’ rate of corporation tax at 19% (2017: 19.25 %)

Current tax reconciliation:

Return on Ordinary activities before tax

Current tax at 19% (2017: 19.25%)  

Gains/losses not subject to tax

Excess management expenses carried forward

Total current tax charge and tax on results of ordinary activities

Year to 
31 December 2018
£’000

Year to 
31 December 2017
£’000

66

13

(36)

23

-

(367)

(71)

65

6

-

The  company  has  excess  management  expenses  of  £2,741,000  (2017:  £2,619,000)  to  carry  forward  to  offset 
against future taxable profits.

Approved VCTs are exempt from tax on capital gains within the Company.  Since the Directors intend that the 
Company will continue to conduct its affairs so as to maintain its approval as a VCT, no current deferred tax has 
been provided in respect of any capital gains or losses arising on the revaluation or disposal of investments.

8. Earnings per Share 

The earnings per Ordinary share is based on 8,115,376 (31 December 2017: 8,115,376) shares, being the weighted 
average  number  of  Ordinary  shares  in  issue  during  the  year,  and  a  return  for  the  year  totalling  £102,000  (31 
December 2017: (£367,000)).

The  earnings  per  B  share  is  based  on  3,412,545  (31  December  2017:  nil)  shares,  being  the  weighted  average 
number of B shares in issue since 23 August 2018, and a return for the year totalling (£36,000) (31 December 2017: 
nil).

There are no potentially dilutive capital instruments in issue and, therefore, no diluted returns per share figures 
are relevant. The basic and diluted earnings per share are therefore identical.

9. Net Asset Value per Share  

The calculation of NAV per Ordinary share as at 31 December 2018 is based on 8,115,376 Ordinary shares in issue 
at that date (31 December 2017: 8,115,376).

The calculation of NAV per B share as at 31 December 2018 is based on 4,036,370 B shares in issue at that date 
(31 December 2017: nil).

65

10. 

Fixed Asset Investments

Ordinary shares

Valuation and net book amount:

Book cost as at 1 January 2018

Cumulative revaluation

Valuation at 1 January 2018

Movement in the year:

Purchases at cost

Disposal proceeds

Gain/(loss) on disposal

Revaluation in year

Valuation at 31 December 2018

Book cost at 31 December 2018

Revaluation to 31 December 2018

Valuation at 31 December 2018

B Shares

Valuation and net book amount:

Book cost as at 1 January 2018

Cumulative revaluation

Valuation at 1 January 2018

Movement in the year:

Purchases at cost

Disposal proceeds

Gain/(loss) on disposal

Revaluation in year

Valuation at 31 December 2018

Book cost at 31 December 2018

Revaluation to 31 December 2018

Valuation at 31 December 2018

Level 1:
AIM-quoted 
investments
£’000

Level 3:
Unquoted
 investments
£’000

Total 
investments
£’000

1,129

906

2,035

-

(31)

6

(549)

1,461

1,117

344

1,461

4,426

(897)

3,529

-

(2,927)

897

(167)

1,332

2,985

(1,653)

1,332

5,555

9

5,564

-

(2,958)

903

(716)

2,793

4,102

(1,309)

2,793

Level 1:
AIM-quoted 
investments
£’000

Level 3:
Unquoted
 investments
£’000

Total 
investments
£’000

-

-

-

-

-

-

-

-

-

-

-

-

-

500

-

-

-

500

500

-

500

-

-

-

500

-

-

-

500

500

-

500

Further details of the fixed asset investments held by the Company are shown within the Investment Manager’s 
Report on pages 14 to 24.

66

All  investments  are  initially  measured  at  fair  value  through  profit  or  loss,  and  all  capital  gains  or  losses  on 
investments  are  so  measured.  The  changes  in  fair  value  of  such  investments  recognised  in  these  Financial 
Statements are treated as unrealised holding gains or losses. 

11. Debtors

Prepayments and accrued income

12. Creditors

Amounts falling due within one year

Accruals

Trade creditors

Awaiting B share issue

Other creditors

Total amounts falling due within one year

Amounts falling due after one year

Accruals

Total amounts falling due after one year

31 December 2018
£’000

31 December 2017
£’000

23

23

7

7

31 December 2018
£’000

31 December 2017
£’000

43

-

219

29

291

190

190

34

4

-

29

67

164

164

The amount falling due after more than one year relates to the potential liability for a performance fee on the 
Ordinary share portfolio. More details are in note 6.

13. Share Capital

Allotted and fully paid up:

8,115,376 Ordinary shares of 1p (2017: 8,115,376 shares of 50p)

4,036,370 B Ordinary shares of 1p (2017 : nil)

31 December 2018
£’000

31 December 2017
£’000

81

40

121

4,058

-

4,058

The capital of the Company is managed in accordance with its investment policy with a view to the achievement of 
its investment objective as set on page 8. During the year, the Company did not issue, nor buy back, any Ordinary 
shares. On 5 April 2018, following approval at the Company’s annual general meeting, the nominal value of the 
Ordinary shares was reduced from 50p to 1p. More details are included in the Chairman’s Statement on page 10 
and in note 14.

The Company issued a total of 4,036,370 B Ordinary shares at prices between 99.7p and 105.8p per B Ordinary 
share. pursuant to an offer for subscription for B shares launched on 9 May 2018 to raise, in aggregate, up to £10 
million with an over-allotment facility of up to a further £10 million (before issue costs). The Company has not 
bought back any B Ordinary shares.

67

14. Movement in Shareholders’ Funds

Shareholders’ funds at start of year

Return on ordinary activities after tax

Increase due to issue of B shares

Shareholders’ funds at end of year

Year ended 
31 December 2018
£’000

Year ended 
31 December 2017
£’000

5,180

66

4,035

9,281

5,547

(367)

-

5,180

The analysis of changes in equity by the various reserves are shown in the Statement of Changes in Equity on page 50.  

When the Company revalues its investments during the period, any gains or losses arising are credited/charged 
to the Income Statement. Changes in fair value of investments held are then transferred to the capital reserve - 
holding gains/(losses). When an investment is sold any balance held on the capital reserve - holding gains/(losses) 
reserve is transferred to the capital reserve – gains/(losses) on disposal as a movement in reserves.  

The purpose of the special distributable reserve was to create a reserve which will be capable of being used by 
the Company to pay dividends and for the purpose of making repurchases of its own shares in the market with 
a view to narrowing the discount at which the Company’s shares trade to net asset value, providing shareholder 
authority has been granted.

During  2010,  the  Company  revoked  investment  company  status  in  order  to  allow  payment  of  dividends  from 
distributable  reserves.  During  2018,  the  Company  effected  a  capital  reduction  exercise,  whereby  the  nominal 
value of its Ordinary shares was reduced from 50p to 1p, creating a capital redemption reserve. The Company 
also issued 4,036,370 B shares at a premium. On 7 December 2018, following shareholder approval, the Company 
sought, and received approval from the High Court to the reduction of the amount standing to the credit of the 
Capital Redemption Reserve of the Company by £4,014,135 and of the Share Premium Account of the Company 
by  £3,427,184,  thereby  creating  additional  distributable  reserves  of  £7,441,319.  Distributable  reserves  are 
represented by the special distributable reserve, the capital reserve gains/(losses) on disposal and the revenue 
reserve  reduced  by  negative  holding  reserves  (if  any)  which  total  £8,592,000  as  at  31  December  2018  (2017: 
£1,075,000).  Although  the  distributable  reserves  total  £8,592,000  as  at  31  December  2018,  only  £5,181,000  is 
actually able to be distributed as the reserves contain £ 3,427,000 from the cancellation of the share premium 
account on the newly issued B shares, which cannot be distributed until the beginning of 2022 without breaching 
VCT rules.

An interim capital dividend of 10 pence per Ordinary share for the year to 31 December 2018 was paid on 25 
January 2019, reducing shareholder funds by £811,537.60.

68

 
15. Financial Instruments 

The Company’s financial instruments comprise equity investments, cash balances and liquid resources including 
debtors and creditors. 

Classification of financial instruments
The Company held the following categories of financial instruments, all of which are included in the balance sheet 
at fair value, at 31 December 2018 and 31 December 2017: 

31 December 2018
£’000

31 December 2017
£’000

Financial assets at fair value through profit or loss

Fixed asset investments

Total

Financial assets measured at amortised cost

Cash at bank and in hand

Debtors

Total

Financial liabilities measured at amortised cost

Bank Overdraft

Creditors

Total

3,293

3,293

6,446

23

6,469

-

(29)

(29)

5,564

5,564

-

7

7

(160)

(33)

(193)

Fixed asset investments (see note 10) are valued at fair value. Unquoted investments are carried at fair value as 
determined by the Directors in accordance with current venture capital industry guidelines. The fair value of all 
other  financial  assets  and  liabilities  is  represented  by  their  carrying  value  in  the  balance  sheet.    The  Directors 
believe that the fair value of the assets held at the year end is equal to their book value.

The  Company’s  creditors  and  debtors  are  recognised  at  fair  value  which  is  usually  the  transaction  cost  or  net 
realisable value if lower.  

As at 31 December 2017, the Company had an overdraft facility of £200,000 with the Royal Bank of Scotland, which 
was converted into a loan in April 2018, both of which were secured by a debenture. The loan was a liability of the 
Ordinary share pool and was repaid at the end of August 2018 once the company had access to the funds from 
the initial allotment of B shares, and the debenture was released. The funds in the B share pool have since been 
replenished from the proceeds from the Ordinary share pool’s sale of its investment in Hallmarq.

16. Financial Risk Management 

In carrying on its investment activities, the Company is exposed to various types of risk associated with the financial 
instruments  and  markets  in  which  it  invests.  The  most  significant  types  of  financial  risk  facing  the  Company 
are market risk, credit risk and liquidity risk. The Company’s approach to managing these risks is set out below 
together with a description of the nature and amount of the financial instruments held at the balance sheet date. 

Market risk
The Company’s strategy for managing investment risk is determined with regard to the Company’s investment 
objective, as outlined on page 8. The management of market risk is part of the investment management process. 
The Company’s portfolio is managed with regard to the possible effects of adverse price movements and with the 
objective of maximising overall returns to shareholders in the medium term. Investments in unquoted companies, 
by their nature, usually involve a higher degree of risk than investments in companies quoted on a recognised 

69

stock exchange, though the risk can be mitigated to a certain extent by diversifying the portfolio across business 
sectors and asset classes. The overall disposition of the Company’s assets is regularly monitored by the Board.

Details of the Company’s investment portfolio at the balance sheet date are set out on page 15.

19.7% (2017: 68.1%) by value of the Company’s net assets comprise investments in unquoted companies held at 
fair value.  The valuation methods used by the Company include the application of a price/earnings ratio derived 
from listed companies with similar characteristics, and consequently the value of the unquoted element of the 
portfolio can be indirectly affected by price movements on the London Stock Exchange. A 10% overall increase in 
the valuation of the unquoted investments at 31 December 2018 would have increased net assets and the total 
return for the year by £183,000 (2017: £353,000) disregarding the impact of the performance fee; an equivalent 
change in the opposite direction would have reduced net assets and the total return for the year by the same 
amount.  

15.7%  (2017:  39.3%)  by  value  of  the  Company’s  net  assets  comprises  equity  securities  quoted  on  AIM.  A  10% 
increase in the bid price of these securities as at 31 December 2018 would have increased net assets and the total 
return for the year by £146,000 (2017: £204,000) disregarding the impact of the performance fee; a corresponding 
fall would have reduced net assets and the total return for the year by the same amount.

Credit risk
There were no significant concentrations of credit risk to counterparties at 31 December 2018 or 31 December 
2017. 

Credit risk is the risk that a counterparty to a financial instrument will fail to discharge an obligation or commitment 
that it has entered into with the Company. The Board carries out a regular review of counterparty risk. The carrying 
values of financial assets represent the maximum credit risk exposure at the balance sheet date.  

Liquidity risk
The  Company’s  financial  assets  include  investments  in  unquoted  equity  securities  which  are  not  traded  on  a 
recognised  stock  exchange  and  which  generally  are  illiquid.  They  also  include  investments  in  AIM-quoted 
companies,  which,  by  their  nature,  involve  a  higher  degree  of  risk  than  investments  on  the  main  market.    As 
a  result,  the  Company  may  not  be  able  to  realise  some  of  its  investments  in  these  instruments  quickly  at  an 
amount close to their fair value in order to meet its liquidity requirements, or to respond to specific events such 
as deterioration in the creditworthiness of any particular issuer.  

The Company’s liquidity risk is managed and monitored on a continuing basis by the Board in accordance with 
policies and procedures laid down by the Board.

17. Events After the Balance Sheet Date

Since 31 December 2018:

Pursuant to the Offer, the Company has made the following allotments of B shares:

Date

7 March 2019

3 April 2019

5 April 2019

25 April 2019

Number of shares allotted

Allotment price range

643,278

442,148

241,485

24,383

99.1p to 102.2p per share

99.1p to 104.9p per share

97.6p to 103.3p per share

102.5p per share

As at 26 April 2019, the Company had a total of 5,387,664 B shares in issue

70

 
 
 
The Company has also made the following new investments from the B share pool

Company Name

Date of Investment

Amount subscribed

Fabacus Holdings 
Limited

15 February 2019

£500,000

SkinBioTherapeutics Plc

21 February 2019

£750,000

Old St Labs Limited

28 March 2019

£500,000

Qudini Limited

4 April 2019

£500,000

18. Contingencies, Guarantees and Financial Commitments

There were no contingencies, guarantees or financial commitments as at 31 December 2018 (2017: £nil).

19. Related Party Transactions

The Board acted as the investment manager of the Company until Seneca were appointed on 23 August 2018.  
No  remuneration  has  been  paid  to  the  Board  during  the  year  in  its  capacity  as  investment  manager.    Certain 
Directors  are  entitled  to  participate  in  a  performance  bonus  as  detailed  in  note  6.  Seneca  have  earnt  £24,000 
in management fees since 23 August 2018 (2% of the weighted average net assets of the B share portfolio). No 
payment has been made to Seneca, as £42,000 is recoverable from Seneca as a result of the cost cap, as detailed 
in note 3. Therefore at the year end, £18,000 was due from Seneca, which will be deducted from fees to be paid 
to them for services in 2019 (2017: nil).

Seneca accrued £19,997 (2017: £nil) transaction fees and directors’ fees from investee companies. Seneca may also 
become entitled to a performance fee. See note 3 to the financial statements for more information on these fees.

As  detailed  in  the  offer  for  subscription  document  dated  9  May  2018,  Seneca  (as  promoters  of  the  offer)  are 
entitled to charge the Company up to 5.5% of investors’ subscriptions. A total of £40,596 has been paid to Seneca, 
based on the allotments of £4,035,000 as at 31 December 2018 (2017: n/a).

Charles  Breese  is  a  director  of  OR  Productivity  and  received  £nil  from  OR  Productivity  in  fees  for  his  support 
during the year (2017: £nil). 

71

 
 
Notice of Annual General Meeting

Notice is hereby given that the Annual General Meeting of Seneca Growth Capital VCT Plc (“the Company”) will be held at the 
offices of Howard Kennedy LLP, No 1 London Bridge, London SE1 9BG on Monday 10 June 2019 at 11.00 am for the following 
purposes:

To consider and if thought fit, pass the following as Ordinary Resolutions:

1.  THAT  the  Directors’  Annual  Report  and  Financial  Statements  and  the  auditors’  report  thereon  for  the  year  ended  31 

December 2018 be received.

2.  THAT  the  Remuneration  Policy  set  out  on  pages  39  and  40  of  the  2018  Annual  Report  which  will  take  effect  from  the 

conclusion of the Meeting be received and approved. 

3.  THAT the Directors’ Remuneration Report in respect of the year ended 31 December 2018 be approved.

4.  THAT John Hustler aged 72, be re-elected as a Director of the Company.

5.  THAT Richard Manley aged 39, be re-elected as a Director of the Company.

6.  THAT UHY Hacker Young LLP be re-appointed as auditors of the Company until the conclusion of the next Annual General 

Meeting of the Company at which accounts are laid before the Members.

7.  THAT the Directors be authorised to determine the auditor’s remuneration.

8.  AUTHORITY TO ALLOT RELEVANT SECURITIES 

THAT, in addition to existing authorities, the Directors be and are hereby generally and unconditionally authorised in 
accordance with section 551 of the Companies Act 2006 (the “Act”) to exercise all the powers of the Company to allot: 

a)  B ordinary shares of 1p each in the capital of Company (“B Ordinary Shares”) up to an aggregate nominal amount of 

£250,000 in connection with offer(s) for subscription;

b)  B  Ordinary  Shares  for  cash  and  otherwise  than  pursuant  to  sub-paragraph  a.  above,  up  to  an  aggregate  nominal 

amount of £60,000; and 

c)  ordinary shares of 1p each in the capital of Company (“Ordinary Shares”) for cash, up to an aggregate nominal amount 

of £4,058

provided that  this authority shall expire at the later of the conclusion of the Company’s Annual General Meeting next 
following the passing of this resolution and the expiry of 15 months from the passing of this resolution (unless previously 
revoked, varied or extended by the Company in a general meeting) but so that such authority shall allow the Company to 
make offers or agreements before the expiry thereof which would or might require relevant securities to be allotted after 
the expiry of such authority and the Directors shall be entitled to allot shares pursuant to any such offers or agreements 
as if the authority conferred by this resolution had not expired.

To consider and, if thought fit, pass the following as Special Resolutions:

9.  EMPOWERMENT TO MAKE ALLOTMENTS OF EQUITY SECURITIES

THAT, in addition to existing authorities, the Directors pursuant to section 570(1) of the Act be and are hereby empowered 
to allot or make offers or agreements to allot equity securities (as defined in section 560(1) of the Act) for cash pursuant 
to the authority referred to in Resolution 8 as if section 561 (1) of the Act did not apply to any such allotments and so that:

a) 

reference to allotment in this resolution shall be construed in accordance with section 560(2) of the Act; and

b) 

the power conferred by this resolution shall enable the Company to make any offer or agreement before the expiry 
of the said power which would or might require equity securities to be allotted after the expiry of the said power and 
the Directors may allot equity securities in pursuance of such offer or agreement notwithstanding the expiry of such 
power

and  this  power,  unless  previously  varied,  revoked  or  renewed,  shall  come  to  an  end  at  the  conclusion  of  the  Annual 
General Meeting of the Company next following the passing of this resolution or, if earlier, on the expiry of 15 months 
from the passing of this resolution.

10.  AUTHORITY TO PURCHASE RELEVANT SECURITIES

THAT the Company be and is hereby generally and unconditionally authorised within the meaning of section 701 of the Act 
to make one or more market purchases (within the meaning of section 693(4) of the Act) of B Ordinary Shares provided that:

a) 

the maximum number of B Ordinary Shares hereby authorised to be purchased is an amount equal to 14.99% of the 
issued B Ordinary Share capital of the Company from time to time;

b) 

the minimum price which may be paid for a B Ordinary Share is 1 pence per share, the nominal amount thereof;

72

 
c) 

d) 

e) 

the maximum price which may be paid for a B Ordinary Share is an amount equal to the higher of: 
(i) 105% of the average of the middle market prices shown in the quotations for a B Ordinary Share in The London  
 Stock Exchange Daily Official List for the five business days immediately preceding the day on which that share is  
 purchased; and  
(ii) the amount stipulated by Article 5(6) of Market Abuse Regulation (596/2014/EU); 

the authority hereby conferred shall (unless previously renewed or revoked) expire on the earlier of the conclusion of 
the Company’s Annual General Meeting next following the passing of this resolution and the date which is 15 months 
after the date on which this resolution is passed; and

the Company may make a contract or contracts to purchase its own B Ordinary Shares under this authority before the 
expiry of the authority which will or may be executed wholly or partly after the expiry of the authority, and may make 
a purchase of its own B Ordinary Shares in pursuance of any such contract or contracts as if the authority conferred 
hereby had not expired.

11.  CANCELLATION OF THE SHARE PREMIUM ACCOUNT 

THAT, subject to the approval of the High Court of Justice, the amount standing to the credit of the share premium 
account of the Company, at the date the Court Order is made confirming such cancellation, be and is hereby cancelled. 

By order of the Board 
Craig Hunter 
Company Secretary 
26 April 2019 

NOTES:

Registered Office:
12 The Park
Haydock
Newton-Le-Willows
WA12 0JQ

i) 

Pursuant  to  Regulation  41  of  the  Uncertificated  Securities  Regulations  2001,  entitlement  to  attend  and  vote  at  the  meeting  (and  the 
number of votes that may be cast thereat), will be determined by reference to the Register of Members of the Company at the close of 
business on the day which is two days before the day of the meeting or of the adjourned meeting. Changes to the Register of Members of 
the Company after the relevant deadline shall be disregarded in determining the rights of any person to attend and vote at the meeting.

ii)  A member entitled to attend and vote at the meeting is entitled to appoint a proxy or proxies to attend, speak and vote on his or her 
behalf.  A  proxy  need  not  also  be  a  member  but  must  attend  the  meeting  to  represent  the  appointer.  Details  of  how  to  appoint  the 
chairman of the meeting or another person as a proxy using the Form of Proxy are set out in the notes on the Form of Proxy. If the 
member wishes his or her proxy to speak on their behalf at the meeting then the member will need to appoint their own choice of proxy 
(not the chairman) and give their instructions directly to the proxy.

iii)  A member may appoint more than one proxy provided each proxy is appointed to exercise rights attached to different shares. A member 
may not appoint more than one proxy to exercise rights attached to any one share. To appoint more than one proxy, a member may 
copy the proxy form, clearly stating on each copy the shares to which the proxy relates, or alternatively contact the Company’s registrars, 
Neville Registrars Limited, on 0121 585 1131 to request additional copies of the proxy form. For legal reasons Neville Registrars Limited 
will be unable to give advice on the merits of the proposals or provide financial, legal, tax or investment advice. The member will need 
to indicate in the box next to the proxy holder’s name the number of shares in relation to which they are authorised to act as proxy, and 
will also need to indicate on the form (by ticking the box provided) if the proxy instruction is one of multiple instructions being given. All 
forms must be signed and returned together in the same envelope.

iv)  Any person to whom this notice is sent who is a person nominated under section 146 of the Act to enjoy information rights (a “Nominated 
Person”) may, under an agreement between him/her and the member by whom he/she was nominated, have a right to be appointed 
(or to have someone else appointed) as a proxy for the meeting. If a Nominated Person has no such proxy appointment right or does 
not wish to exercise it, he/she may, under any such agreement, have a right to give instructions to the shareholder as to the exercise of 
voting rights. 

v) 

vi) 

The  statement  of  the  rights  of  members  in  relation  to  the  appointment  of  proxies  in  paragraphs  (ii)  to  (iii)  above  does  not  apply  to 
Nominated Persons. The rights described in these paragraphs can only be exercised by members of the Company.

If the recipient of this document has been nominated to receive general shareholder communications directly from the Company, it is 
important to remember that the member’s main contact in terms of their investment remains as it was (being the registered shareholder, 
or perhaps custodian or broker, who administers the investment on their behalf). Therefore, any changes or queries relating to a member’s 
personal details and holding (including any administration thereof) must continue to be directed to that member’s existing contact at 
their investment manager or custodian. The Company cannot guarantee that it will deal with any matters that are directed to it in error. 
The only exception to this is where the Company, in exercising one of its powers under the Act, writes to a member directly for a response.

vii)  A reply-paid Form of Proxy is enclosed with this document. To be valid, the enclosed Form of Proxy for the meeting, together with the 
power of attorney or other authority, if any, under which it is signed or a notarially certified or office copy thereof, must be deposited at 
the offices of the Company’s registrar, Neville Registrars Limited, Neville House, Steelpark Road, Halesowen B62 8HD so as to be received 
not later than 11.00 a.m. on 8 June 2019 or 48 hours before the time appointed for any adjourned meeting or, in the case of a poll taken 
subsequent to the date of the meeting or adjourned meeting, so as to be received no later than 24 hours before the time appointed for 
taking the poll.

viii)  Appointment of a proxy will not preclude a member from subsequently attending and voting at the meeting should he or she subsequently 
decide to do so. A member can only appoint a proxy using the procedure set out in these notes and the notes to the Form of Proxy.

ix)  As at 26 April 2019 (being the last business day prior to the publication of this notice), the Company’s issued share capital comprised 
8,115,376 Ordinary Shares and 5,387,664 B Ordinary Shares, all of which carry one vote each. Therefore, the total voting rights in the 
Company as at 26 April 2019 was 13,503,040.

x)  Copies of the directors’ letters of appointment, the Register of Directors’ Interests in shares of the Company and copies of the Articles 
will be available for inspection at the registered office of the Company during usual business hours on any weekday (Saturday and Public 
Holidays excluded) from the date of this notice, until the end of the Annual General Meeting and at the place of the Annual General 
Meeting for at least 15 minutes prior to and during the meeting.

73

 
 
 
xi) 

If  a  corporate  shareholder  has  appointed  a  corporate  representative,  the  corporate  representative  will  have  the  same  powers  as 
the corporation could exercise if it were an individual member of the Company. If more than one corporate representative has been 
appointed, on a vote on a show of hands on a resolution, each representative will have the same voting rights as the corporation would 
be entitled to. If more than one authorised person seeks to exercise a power in respect of the same shares, if they purport to exercise 
the power in the same way, the power is treated as exercised; if they do not purport to exercise the power in the same way, the power is 
treated as not exercised.

xii)  At the meeting, Shareholders have the right to ask questions relating to the business of the meeting and the Company is obliged under 
section 319A of the Act to answer such questions, unless; to do so would interfere unduly with the preparation of the meeting or would 
involve the disclosure of confidential information, if the information has been given on the Company’s website, www.hygeavct.com in the 
form of an answer to a question, or if it is undesirable in the interests of the Company or the good order of the meeting that the question 
be answered.

xiii)  Further information, including the information required by section 311A of the Act, regarding the meeting is available on the Company’s 

website, www.senecavct.co.uk.     

74

Directors and Advisers

Board of Directors

John Hustler (Chairman)
Charles Breese
Richard Manley
Richard Roth

Company Number

Registered in England & Wales
No 04221489

Secretary and Registered Office

Craig Hunter
12 The Parks, Haydock, 
Newton-Le-Willows
WA12 0JQT

Administration Manager

Pennywise Accounting Ltd
Dickhurst House 
Rodgate Lane
Haslemere
GU27 2EW

Corporate Broker

Panmure Gordon (UK) Limited
One New Change
London
EC4M 9AF
Tel: 020 7886 2500

Investment Manager

Seneca Partners Limited
12 The Parks
Haydock
WA12 0JQ
Tel: 01942 271746

Independent Auditor

UHY Hacker Young LLP
Quadrant House
4 Thomas More Square
London 
E1W 1YW

VCT Adviser

Philip Hare & Associates LLP
Suite C – First Floor, 4-6 Staple Inn, Holborn 
London WC1V 7QH 

Bankers

The Royal Bank of Scotland plc
62/63 Threadneedle Street
London
EC2R 8LA

Registrars

Neville Registrars Limited
Neville House
Steelpark Road
Halesowen
B62 8HD
Tel: 0121 585 1131
www.nevilleregistrars.co.uk

Financial Adviser

Beaumont Cornish Limited
2nd Floor, Bowman House
29 Wilson Street
London
EC2M 2SJ

75

12 The Parks
Haydock WA12 0JQ

01942 271 746
www.senecavct.co.uk