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Seneca Growth Capital VCT

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Industry Asset Management - Bonds
Employees 51-200
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FY2020 Annual Report · Seneca Growth Capital VCT
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Seneca Growth Capital VCT Plc

Annual Report  
and Financial Statements

For the year ended 31 December 2020

Company No: 04221489

Contents 

Financial Headlines …………………………………………………………………………………………..... 

Financial Summary …………………………………………………………………………………………….. 

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 …………….... 

Combined Income Statement ………….…………………………………………………………………....... 

Ordinary Share Income Statement (non-statutory analysis) ………………………………………………. 

B Share Income Statement (non-statutory analysis) ………………………………………………………. 

Combined Statement of Changes in Equity ……………………………………….………………………... 

Ordinary Shares – Statement of Changes in Equity ……………………………………………………….. 

B Shares – Statement of Changes in Equity ………………………………………………………………... 

Combined Balance Sheet ……………………………….…………………………………………………….. 

Ordinary Share Balance Sheet (non-statutory analysis) …………………………………………………... 

B Share Balance Sheet (non-statutory analysis) ………………………………………………………….... 

Combined Statement of Cash Flows …………………………………..…………………………………….. 

Ordinary Shares Statement of Cash Flows ……………..…………………………………………………… 

B Shares Statement of Cash Flows ………………………………………………………………………….. 

Notes to the Financial Statements ………………………………………………………………………….... 

Shareholder Information and Contact Details ……………………………………………………………..... 

Directors and Advisers ……………………………………………………………………………………….... 

Notice of Annual General Meeting ………………………………………………………………………….... 

1 

1 

3 

3 

8 

14 

36 

42 

43 

50 

55 

58 

60 

61 

70 

71 

72 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

99 

101 

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Headlines 

Ordinary Shares 

Ordinary share NAV plus cumulative dividends paid at 31 December 2020 (“Total Return”) 

Ordinary share NAV at 31 December 2020 

Interim capital dividends paid per Ordinary share during year 

95.5p 

30.2p 

13.0p 

B Shares 

£2.4m 

Amount raised during the year from the issue of B shares 

£1.36m 

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

97.8p 

91.8p 

3.0p 

B share NAV plus cumulative dividends paid at 31 December 2020 (“Total Return”) 

B share NAV at 31 December 2020  

Interim dividends paid per B share during year 

Financial Summary 

Net assets (£’000s) 
Return on ordinary activities after tax (£’000s) 
Earnings per share (p) 
Net asset value per share (p) 
Dividends paid since inception (p) 
Total return (NAV plus cumulative dividends paid) (p) 

Financial Calendar 

The Company’s financial calendar is as follows: 

Year to  
31 December 
2020 
Ordinary share 
pool 
2,453 
1,045 
12.8 
30.2 
65.25 
95.45 

               Year to  
      31 December             

2020 
              B share  
                    pool 
8,317 
252 
3.5 
91.8 
6.00 
97.8 

Year to  
31 December 
2019 
Ordinary share 
pool 
2,463 
(547) 
(6.7) 
30.4 
52.25 
82.65 

Year to  
31 December 
2019  
B share 
 pool 
5,921 
(168) 
(3.2) 
93.1 
3.0 
96.1 

29 March 2021 

Annual General Meeting (“AGM”) will be a closed meeting as a result of the Covid-19 
(“C-19”) pandemic and will be held at 14:00 at 9 The Parks, Haydock, WA12 0JQ 

July 2021 

Half-yearly results to 30 June 2021 published 

February 2022 

Annual results for the year to 31 December 2021 announced and Annual Report and 
Financial Statements published 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
About Seneca Growth Capital VCT Plc 

Seneca Growth Capital VCT Plc (“the Company” or “Seneca Growth Capital”) is a Venture Capital Trust, 
launched in 2001, which now aims to generate returns from a diverse portfolio of both unquoted and 
AIM/AQSE quoted growth capital investments. Until 23 August 2018 the Company was called Hygea 
vct plc. On 9 May 2018, the Company launched an offer for subscription for a new B share class which 
closed in April 2019. 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.  

Further to the success of the Company’s B Share offers in the last two years under which the Company 
has raised £7.2 million a new offer of B shares was launched on 13 October 2020 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 had raised a further £1.5 million under the Offer as at 31 December 2020.  

The  Company  is  registered  as  a  small  UK  Alternative  Investment  Fund  Manager  (AIFM)  with  a  Board 
comprising of four non-executive directors, three of whom are independent. 

As the Company’s Investment Manager, Seneca are responsible for the management of the Company’s B 
share pool investments, whilst 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, 
namely John Hustler and Richard Roth. 

The  Company  continues  to  manage  both  share  classes  in  accordance  with  its  investment  policy,  having 
expanded the range of qualifying investments in 2018.  

No new investments have been made in the Ordinary share pool during 2020. The Directors 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.  During  the  year,  the  Company  realised  its  remaining  investment  in  Omega 
Diagnostics Group Plc (“Omega”) and sold 8% of its holding in Scancell Plc which enabled the payment of a 
further 13p of dividends per Ordinary share during the year. 

The funds raised from the issue of B shares under the Offer and any subsequent fund raisings are not limited 
to  being  invested  in  any  specific  sector.  Instead,  the  Company’s  B  share  pool  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. Six new investments were made by the B 
share pool during the year, details of which are included on pages 14 to 27. The Company intends to distribute 
a proportion of the net profits it receives from realisations by way of special tax-free dividends. This is intended 
to provide investors with an attractive income stream whilst also maintaining a relatively stable Net Asset Value 
(“NAV”) per B share, subject to the requirements and best interests of the Company.  

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 on pages 39 to 40. The Company has continued its compliance with these 
requirements during the year, and both share classes in the Company are eligible shares as defined by section 
273 ITA 2007. 

2 

 
 
 
 
 
 
 
 
 
 
 
 
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  

Seneca was appointed as the Company’s Investment Manager in August 2018 and is specifically 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 remaining members of the Board of Directors 
who served immediately prior to 23 August 2018, namely John Hustler and Richard Roth.  

There has been no change during the year in the way the Ordinary share pool’s assets are managed. The 
Ordinary share pool made two realisations from its AIM quoted investments in the period, one of which was 
the full realisation of its shares in Omega. The Ordinary share pool’s unquoted investment Exosect Limited 
was dissolved on 24 January 2020. The Directors do not envisage making any new investments from the funds 
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 Company’s latest Offer for new B shares opened on 13 October 2020 seeking to raise up to £10 million 
with an over-allotment facility of up to a further £10 million (before issue costs). The funds raised from the issue 
of B shares will not be limited to being invested in any specific sector. Instead, in line with the Company’s 
investment  policy,  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 Company fosters a culture of innovation, risk mitigation and collaboration supported by policies, practices 
and behaviours to further our purpose as an investment company seeking to provide growth capital to well 
managed leading UK SMEs which share our values, in order to deliver on our investment strategy and objective 
as  described  below.  The  Directors  will  continually  monitor  and  assess  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 through a set of robust internal controls as discussed in 
the Business Review on page 40, the Corporate Governance policy on pages 50 to 54 and within the Audit 
Committee Report on pages 55 to 57. 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Qualifying Investments 

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

●  At least 80% of investments must be made in qualifying shares or securities; 
●  At  least  70%  of  qualifying  investments  must  be  invested  into  ordinary  shares  with  no  prohibited 
preferential rights (investments made before 6 April 2018 from funds raised before 6 April 2011 are 
excluded); 

●  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 
its first commercial sale must be less than seven years old (or ten 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. 

The  Finance  Act  2018  introduced  a  “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 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 investment objective is to provide shareholders with an attractive income and capital return 
by investing its funds in a portfolio of both unquoted and AIM/AQSE 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. 

4 

 
 
 
 
 
 
 
 
 
 
 
 
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 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.  

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/AQSE 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. 

Key Information Document 

New EU PRIIPs regulations came into effect in January 2018. The intent of the regulations is to increase 
customer protection by improving the functioning of financial markets and in this instance through the Key 
Information Document (KID) to provide shareholders with more information about the risks, potential returns 
and charges within VCTs. The regulation requires the Company to publish a KID. Retail investors must now 
be directed to this before buying shares in the Company. The KID is published on the Company website 
https://senecavct.co.uk/key-documents/. The KID has been prepared using the methodology prescribed in 
the PRIIPS regulation. Although well intended, there are widespread concerns about the application of some 
aspects of the prescribed methodologies to VCTs. Specifically, there are concerns that: 

1.  the risk score may be understating the level of risk; and 
2.  investment  performance  scenarios  may  indicate  future  returns  for  shareholders  that  are  too 

optimistic. 

The Association of Investment Companies (AIC) has engaged on this matter and it is hoped that these issues 
will be resolved in the future. In the meantime, the Board recommends shareholders continue to classify VCTs 
as a high-risk investment. 

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). The Company did not borrow any funds in 2020. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Changes to the Investment Policy 

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

Section 172(1) Statement  

The Directors discharge their duties under section 172 of the Companies Act 2006 to act in good faith and to 
promote the success of the Company for the benefit of shareholders as a whole as set out in the Business 
Review from page 36. As an investment company, Seneca Growth Capital has no employees. The Directors 
assessed the impact of the Company’s activities on other stakeholders, in particular shareholders and our 
third-party advisers, as well as the portfolio of companies.  

The  Board’s  decision-making  process  incorporates,  as  part  of  the  Company’s  investment  policy  and 
investment  objectives  as  set  out  on  page  4,  considerations  for  supporting  the  Company’s  business 
relationships  with  the  Investment  Manager,  shareholders,  advisers  and  registrar,  independent  financial 
advisers and the impact of the Company’s operations on the community and the environment, which by nature 
of the business, only extends to the holdings in portfolio companies.  

Key stakeholders 

Investors 
Outside  of  general  meetings,  the  Company  engages  with  shareholders  through  regulatory  news  service 
announcements, interim and annual reports as well as regular correspondence with shareholders and their 
advisers to address any queries that arise.  

the  answers 

forward  by  shareholders, 

The Company has also introduced regular shareholder presentations in addition to the AGM in order to engage 
directly with shareholders and to date have successfully completed our first Shareholder Update Presentation 
in  September  2020  following  the  June  2020  interim  results.  At  the  September  2020  Shareholder  Update 
Presentation, we had exceptional attendance from shareholders and had the opportunity to address ten queries 
to  which  are  available  on  our  website  at 
put 
https://senecavct.co.uk/shareholder-qa/. It was a great opportunity to engage directly with shareholders and 
have subsequently made some  changes to address the minor concerns raised, particularly around shareholder 
communications. Steps have been taken and changes implemented to improve shareholder communications 
as a result of the presentation and feedback provided throughout the year from shareholders. These and any 
other views which may arise are discussed by the Board and factored into any decision-making and disclosed 
in annual and interim reports as appropriate. The Board uses a number of measures to assess the Company’s 
success  in  meeting  its  strategic  objectives  with  regard  to  shareholder  interests  as  detailed  in  the  Key 
Performance Indicators on pages 37 to 38.  

Investment Manager 
The Company’s most important business relationship is with the Investment Manager. There is regular contact 
with the Investment Manager, and all members of the Investment Manager’s Growth Capital investment team 
attend all of the Company’s Board meetings. There is also an annual timetable agreed with the Investment 
Manager and the Company for matters related to the annual timetable which are discussed at each Board 
Meeting. The Company and Investment Manager also work together to maintain efficient operation of the VCT 
as detailed in the Key Performance Indicators on pages 37 to 38.  

Portfolio Companies 
The  Company  holds  minority  investments  in  its  portfolio  companies  and  it  has  appointed  the  Investment 
Manager to manage the B share portfolio. While the Board has little direct contact with the B share portfolio, 

6 

 
 
 
 
 
 
 
 
 
 
the Investment Manager provides updates on the B share portfolio at least quarterly. There were six additions 
to the portfolio in the period and the Company completed four exits as detailed in the Chairman’s Statement 
on pages 8 to 13 and the Investment Manager’s Report on pages 14 to 27. The Board and Investment Manager 
believe that the full realisations and partial realisations from each share pool was in the best interests for all 
key  stakeholders.  Responsibility  for  the  management  of  the  Ordinary  share  pool  investments  has  been 
delegated to those remaining members of the Board of Directors who served immediately prior to 23 August 
2018, namely John Hustler and Richard Roth who also provide updates on the Ordinary Share portfolio at least 
quarterly. 

Environment and Community  
The Company seeks to ensure that its business is conducted in a manner that is responsible to the environment 
as far as is practicable given the nature of the business as an investment company. The management and 
administration of the Company is undertaken by the Investment Manager, who recognises the importance of 
its environmental responsibilities, monitors its impact on the environment and implements policies to reduce 
any damage that might be caused by its activities. Initiatives of the Investment Manager designed to minimise 
its and the Company’s impact on the environment include recycling and reducing energy consumption. More 
details of the work that the Investment Manager has done in this area are set out on pages 45 to 46.  

7 

 
 
 
 
 
Strategic Report   

Chairman’s Statement 

I am pleased to present the 2020 Annual Report on behalf of the Board to shareholders. 

Overview 

As  shareholders  will  recall,  Seneca  have  assumed  the  investment  and  accounting  responsibilities  of  the 
Company with effect from August 2018, following which £8.7 million has been raised for the B share pool to 31 
December 2020. Since this represents the active investment portfolio, I am reporting on the B share portfolio 
first and then will give the results of the legacy Ordinary share portfolio. 

I am pleased to say that, despite the unprecedented circumstances which we are all facing due to the C-19 
global pandemic, I am able to report that both the B share and Ordinary share investment portfolios have stood 
up well to the challenges that they have faced. The Total Return (NAV per share plus cumulative dividends per 
share) for each share class increased during the year with the B share increasing by 1.8% to 97.8p and the 
Ordinary share increasing by 15.5% to 95.5p. 

I am also pleased to be able to report that Seneca continued the development of the B share pool during the 
year both in terms of fundraising and investment activity. In October 2020, the Company launched its third offer 
for B shares and allotted an additional £1.5 million of shares in December 2020 taking to £8.7 million the total 
raised by the B share pool from launch in May 2018 to 31 December 2020. I would like to welcome all new 
shareholders and thank both existing and new shareholders for their support. The share offer will remain open 
until 28 May 2021 unless it reaches the target of £10 million with an over-allotment facility of £10 million before 
then. 

The Company made six new B share pool investments in the year in addition to achieving one full exit and one 
partial exit and as a result the Company’s B share pool closed the year with ten investments, an increase of 
five on the prior year.  

There were two full, and one partial disposal from the Ordinary share pool. The Ordinary share pool now has 
just seven investments remaining with AIM quoted Scancell Holdings Plc (“Scancell”) (which encouragingly 
secured £48 million of new investment in the year) accounting for 66% of the Ordinary share pool’s NAV at the 
year end. Recent press coverage regarding Scancell’s involvement in a potential C-19 vaccine has led to a 
significant rise in its share price, which stood at 24.5p at 19 February 2021 compared to our year end value of 
13.5p. Further details and an updated unaudited NAV per Ordinary share and B share are included below. 

With 54% of the B share pool’s NAV as at 31 December 2020 represented by cash and more than 20% of the 
Ordinary  share  pool’s  NAV,  the  Company  has  ended  the  year  well  placed  to  face  the  challenges  and 
opportunities presented by the ongoing C-19 pandemic and to deliver on the key objectives of continuing to 
build an attractive portfolio of growth capital investments in the Company’s B share pool whilst also continuing 
to realise investments in the Ordinary share pool when the opportunity arises. 

I have set out below the progress made by each of the Company’s share classes during the year.  

B Share Pool 

B Shares - Results 
The key items to impact the NAV of the B share pool during the year were as follows:   

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
•  Two dividends paid during the year totalling 3.0p per B share.  
•  The full realisation of one B share pool AIM quoted investment generating a 2.1x return. 
•  The partial exit of one B share pool AIM quoted investment generating a 1.6x return. 
•  An increase in the valuation of two of the B share pool’s remaining three AIM quoted holdings. 
•  A reduction in fair value of one of the B share pool’s seven unquoted company investments as a 

result of the impact of C-19. 
•  The Company’s running costs.  

The net result of the above was an overall increase in the Total Return per B share to 97.8p as at 31 December 
2020 (2019: 96.1p), consisting of a modest reduction in the NAV per B share to 91.8p as at 31 December 2020 
(2019: 93.1p), a positive capital return of 5.7p per B share (2019: negative 0.7p) and a negative revenue return 
of 2.2p per B share (2019: negative 2.5p).   

Whilst the negative revenue return of 2.2p per B share is principally a result of the impact of the Company’s 
running costs on the B share pool, shareholders will recall that the Company’s running expenses are capped 
at 3% of the B share NAV until July 2021 (thereafter the total running costs will continue to be capped at 3% 
with  general  expenses  being  allocated  to  the  Ordinary  share  pool  and  the  B  share  pool  pro-rata  to  their 
respective NAVs). As a result, Seneca reduced their annual management fee for 2020 from £127k to £41k to 
ensure the Company’s annual running expenses stayed within this 3% limit.  

The positive capital return of 5.7p per B share noted above was principally due to increases in the share prices 
of the B share pool’s AIM quoted investments during the year and some harvesting of profit via partial sales of 
these AIM quoted investments offset by a reduction in the carrying value of one of the B share pool’s unquoted 
company investments. Full details are disclosed in the Investment Manager’s Report on pages 14 to 27. 

B Shares - Investment Portfolio Review 
As at 31 December 2020, the B share portfolio comprised ten companies, three of which are quoted on AIM, 
at a total net investment cost of £3,794k. As at 31 December 2020 this portfolio was valued at £3,982k. 

In  January  2021,  the  Company  sold  1,750,000  shares  in  SkinBioTherapeutics  Plc  (“SkinBio”)  which 
represented  37%  of  the  original  holding  of  4,677,107  shares,  reducing  the  remaining  holding  to  2,752,107 
shares. These were sold at a net average price of 35.5p per share providing a return in the region of 2.2x on 
original cost.  

B Shares – Update and Outlook  
Taking into account further proceeds realised since 31 December 2020 as detailed above and in note 17 on 
page 97 and an overall increase in AIM quoted investment bid prices, the Company is pleased to announce an 
updated unaudited NAV per B share of 99.4p per B share at 19 February 2021, an increase of 7.6p per B share 
from the audited NAV of 91.8p per B share as at 31 December 2020 and an overall increase in the Total Return 
per B share to 105.4p as at 19 February 2021.  

Shareholders will be pleased to know the Board declared an interim B share dividend of 1.5p per B share on 
18 February 2021 to be paid on 14 May 2021 to shareholders on the B share register on 30 April 2021, with 
an ex-dividend date of 29 April 2021. 

Seneca continue to work closely with the investee companies in the B share portfolio with the aim of ensuring 
that the potential impact of C-19 is mitigated and that each investee company has sufficient funds to support 
their  working  capital  requirements  until  normal  trading  and  economic  conditions  return.  Seneca  remain 
confident that the portfolio retains its potential to provide attractive returns for B shareholders over the medium 
term. 

9 

 
 
  
 
   
 
 
 
 
 
The  Board  is  pleased  with  the  progress  that  Seneca  have  made  since  their  appointment  as  Investment 
Manager in 2018, in terms of funds raised, new investments made and relationships with brokers offering new 
quoted securities and now, exits achieved.  

Seneca  expect  to  increase  the  funds  raised  under  the  current  B  share  Offer  and  add  new  growth  capital 
investments to the B share portfolio during the course of 2021 from, inter alia, the investments they currently 
have in the later stages of due diligence.  

Ordinary Share Pool 

Ordinary Shares - Results 
Whilst the NAV per Ordinary share decreased by 0.2p from 30.4p to 30.2p during the year, this was after the 
payment of dividends per Ordinary share totalling 13.0p. A better understanding of the underlying performance 
of  the  Company’s  Ordinary  share  portfolio  during  the  year  is  therefore  provided  by  considering  the  NAV 
movement per Ordinary share during the year before dividends which shows an increase of some 12.8p (a 
42% increase compared to 31 December 2019).       

This increase was principally driven by the increase in value of the Ordinary share portfolio’s two AIM quoted 
investments during the year. The quoted bid price of Scancell shares increased from 7.0p to 13.5p from the 
start of the financial year to the financial year end. During this period, it was decided to harvest a modest portion 
of our shareholding and we now hold 12 million shares. Omega benefited from its involvement in a partnership 
to develop a C-19 antibody test and the share price rose significantly; the Board, therefore, decided it was 
appropriate to take advantage of this and we sold our entire holding for £987k, generating a profit over original 
cost of £659k and over our holding value at 31 December 2019 of £666k. 

As a result of the realisations noted above, your Board were very pleased to be able to pay dividends totalling 
13p per Ordinary share during the year with no material adverse impact on the Ordinary pool’s NAV. The Total 
Return  in  relation  to  the  Ordinary  shares  is  now  95.5p  comprising  cumulative  distributions  of  65.25p  per 
Ordinary share and a residual NAV per Ordinary share of 30.2p as at 31 December 2020. 

As previously reported, the Board remains focused on identifying exit opportunities for the remainder of the 
Ordinary share pool investment portfolio, and it was particularly pleasing to have been able to distribute 13p 
per Ordinary share to shareholders this year with no material adverse impact on the Ordinary share pool’s 
NAV. Realisations in the last three years have enabled the payment of a total of 41p per Ordinary share in 
dividends to Ordinary shareholders, representing 64.3% of the NAV per Ordinary share as at 31 December 
2017 and we still retain net assets of 30.2p per Ordinary share as at 31 December 2020. Notwithstanding this 
success, we remain confident that, overall, there remains the opportunity to realise further value for Ordinary 
shareholders in due course (particularly in relation to our Scancell holding): indeed as noted below, earlier this 
month we realised a further portion of our Scancell holding. For the time being, we do not currently consider it 
appropriate  to  liquidate  any  further  Scancell  shares  and  do  not  see  any  other  immediate  opportunities  for 
realisations, but we continue to monitor the situation closely. 

Ordinary Shares - Investment Portfolio 
The remaining Ordinary share portfolio now comprises one AIM quoted holding, Scancell, as referred to above, 
which has a carrying value of £1,620k as at 31 December 2020, and six unquoted holdings – the carrying value 
of three of which have been reduced to zero with the combined carrying value of the other three being £521k 
as at 31 December 2020. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
Shareholders will note therefore that Scancell represented more than 75% of the value of the Ordinary share 
portfolio as at 31 December 2020 and as a result the NAV per Ordinary share now fluctuates largely in line 
with the movement in the Scancell share price. Whilst the Scancell share price showed volatility during 2020, 
it is not our policy to update the market following each of these fluctuations unless there are considered to be 
abnormal  events  (e.g.  sale  of  a  significant  holding  –  see  below).  Your  Board  therefore  recommends  that 
shareholders or prospective shareholders keep the Scancell share price under review and consider its impact 
on the Ordinary share NAV per share before taking any action in relation to an existing or prospective holding 
in the Company’s Ordinary shares.   

Further  details  in  relation  to  the  Ordinary  share  pool’s  investment  portfolio  are  included  in  the  Investment 
Manager’s Report on pages 28 to 35. 

Ordinary Shares – Update and Outlook 
As referred to above, and following recent press coverage, the share price of Scancell has risen significantly 
from 13.5p at 31 December 2020 and was 24.5p at 19 February 2021. We are pleased that the market is 
recognising the continuing developments at Scancell and have taken the opportunity to realise a further modest 
part of our holding by selling 1 million shares at 21.7p per Scancell share. Our current holding is 11 million 
shares and we continue to believe that there is further upside in this holding. 

This increase in the share price has given rise to a significant rise in the NAV per Ordinary share. Based on 
the NAV at 31 December 2020, adjusted solely for the uplift in valuation of our Scancell shares , the Ordinary 
share unaudited NAV per share was 44.0p at 19 February 2021. 

The Ordinary share pool retained a cash balance of £527k as at 31 December 2020 in order to make follow-
on investments into existing Ordinary share portfolio companies where the Board believes this will protect the 
Ordinary share pool’s existing investment and/or improve the overall prospects of a timely exit from the investee 
company. This has been increased to £744k following the recent sale of Scancell shares. Despite several of 
the Ordinary share pool portfolio companies seeking further funds during the year, we did not consider the 
terms attractive nor likely to improve the overall prospects for a timely realisation from the investee company 
and therefore no further Ordinary share pool investments were made.  

Ordinary shareholders will recall that, following the appointment of Seneca as Investment Manager in August 
2018, the Ordinary share pool incurs no running costs until July 2021.  

Fund Raising  
During the year the Company has allotted 2,701,500 B shares raising gross proceeds of £2,403k in the process. 
The current B share Offer will remain open until May 2021.  

Annual General Meeting  
The Company’s AGM will be held as a closed meeting at 14.00 on Monday, 29 March 2021 at the Company’s 
registered  address  9  The  Parks,  Haydock,  WA12  0JQ  in  accordance  with  the  provisions  of  the  Corporate 
Insolvency and Governance Act 2020. In light of the unprecedented restrictions on movement and gatherings 
due to the C-19 pandemic, shareholders will not be permitted to attend this year’s AGM and the meeting will 
take  place  with  either  two  Directors  who  hold  shares  in  the  Company  or  one  Director  and  an  investment 
manager from Seneca Partners, who is also a shareholder, present only, to constitute the minimum quorum 
for  the  AGM  to  take  place  under  the  Company's  articles  of  association  and  company  law  requirements. 
Shareholders should note that only the formal business set out in the Notice of AGM will be considered at the 
AGM. 

Although shareholders will not be permitted to attend the AGM this year there will be a shareholder update 
presentation by the Investment Manager and a question and answer (“Q&A”) session at 10:00 on 8 March 

11 

 
 
 
 
 
 
 
 
 
2021,  further  details  of  which  are  included  below  and  on  https://senecavct.co.uk/march-2021-shareholder-
presentation/.  

Shareholders wishing to vote on any of the matters of business are urged to do so through completion of a 
proxy form appointing the Chairman of the AGM, which can be submitted to the Company’s Registrar. Proxy 
forms should be completed and returned in accordance with the instructions thereon and the latest time for the 
receipt of proxy forms is 14.00 on Saturday, 27 March 2021. Proxy votes can be also be submitted by CREST.  

All resolutions will be decided by a poll and therefore it is essential that shareholders wishing to vote submit 
their proxy forms by 14.00 on Saturday, 27 March 2021.  

Shareholders will have the opportunity to ask questions prior to submitting their proxy votes at the shareholder 
update presentation on 8 March 2021 as detailed below.  

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. Resolutions for the re-election of Alex Clarkson, Richard Manley and 
Richard Roth are also included in the AGM Notice. 

The Notice of the AGM includes resolutions empowering the Directors to issue further B shares following the 
date of the AGM, which will primarily be used for the issue of B shares under a further Offer which we intend 
to launch for the 2021/2022 tax year. This requires authorisation for the Directors to be able to allot up to a 
further 35,000,000 B shares. Including these resolutions in the AGM business will avoid the Company having 
to produce and send out a separate circular to convene a separate general meeting. 

The  Notice  of  the  AGM  also  includes  a  resolution  to  adopt  amended  Articles  of  Association  which  are 
substantially in the same form as the Company’s current Articles of Association but will allow, inter alia, the 
holding  of  partially  virtual  AGMs  and  to  increase  the  total  remuneration  of  the  Directors  to  allow  for  the 
recruitment of a new non-executive Director. Further details of the differences between the two sets of Articles 
are set out in the Directors’ Report on pages 48 to 49. 

A summary of the resolutions to be proposed by the Company at the AGM is included on pages 48 to 49. 

Shareholder Update Presentation 
Due to government restrictions impacting shareholders’ ability to attend the 2021 AGM as a result of the C-19 
pandemic,  a  virtual  shareholder  update  presentation  will  take  place  at  10:00  on  Monday,  8  March  2021. 
Shareholders can register to attend the presentation by visiting:  

•  https://zoom.us/webinar/register/WN_UyGALLGCQCusM0gYuvud0A.  

Further details about the shareholder event can be found on https://senecavct.co.uk/march-2021-shareholder-
presentation/.  

A Q&A session will take place where shareholders will have the opportunity to submit questions directly which 
we  will  seek  to  answer  during  the  presentation.  Questions  can  be  submitted  by  emailing  them  to 
enquiries@senecavct.co.uk.  Both  the  questions  and  answers  will  be  published  on  the  Company’s  website 
following the presentation.  

VCT Qualifying Status 
Philip Hare & Associates LLP provides the Board with advice on the ongoing compliance with HMRC rules and 
regulations concerning VCTs; they have confirmed that the Company remains within all the appropriate VCT 
qualifying regulations as at 31 December 2020. In respect of the 80% Qualifying Holdings test, as at the end 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
of December 2020 the percentage is 100% by virtue of a disregard of disposal proceeds, of which there have 
been £1.1m of relevant share sales (exit proceeds that occurred in the prevailing 12-month period are deducted 
from the total investments balance). Note, these exit proceeds are only deducted to the point that the test 
reaches 100% but without these the Company was still well above the 80% qualifying requirement. As at 31 
December  2020  39%  of  funds  raised  in  the  year  to  31  December  2019  had  been  invested  in  qualifying 
investments for the 30% minimum requirement. 

Fund Administration 
Our administration is conducted by Seneca at the Company’s registered address. Neville Registrars Limited 
(“Neville”)  continue  to  maintain  the  shareholder  register.  All  information  in  respect  of  both  share  classes 
including Annual Reports and notices of meetings can be found on our website www.senecavct.co.uk. 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 and therefore encourage you to contact Neville, whose 
details are on page 101, to advise them of your wish to switch to electronic communication. 

Auditor 
UHY Hacker Young LLP have audited the Company’s annual results for the year ending 31 December 2020, 
and shareholders will be asked to reappoint them at the AGM for the audit of the accounts for the year ending 
31 December 2021. 

Future Prospects 
We are pleased that Seneca have continued to develop the portfolio of B share pool investee companies during 
the  year.  The  B  share  portfolio  includes  a  mix  of  both  unquoted  and  AIM  quoted  investments  and  whilst 
progress of these investments to date has been generally positive, the Board and Seneca remain acutely aware 
of the need to continue to work at close quarters with all B share portfolio companies as they navigate the 
challenges ahead resulting from the C-19 pandemic. 

We also note that Seneca expect to see an increase in the number of businesses seeking investment to support 
their growth plans over the next 12 months as a result of the C-19 pandemic. With over £4.5 million of cash on 
the B share pool balance sheet at 31 December 2020. Seneca believe they are very well placed to continue to 
support the existing B share investment portfolio as well as adding attractive new growth capital investments 
to the B share portfolio from the strong pipeline of opportunities presented to them. We therefore look forward 
to the continued development of the B share portfolio in due course. 

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

John Hustler 
Chairman 
22 February 2021 

13 

 
 
 
 
 
 
 
 
 
 
 
Investment Manager’s Report  

We are pleased to set out in this section further details in relation to the development of both the B and Ordinary 
share pools and their respective investee companies during 2020.  

The B Share Pool 

Fundraising  
Our second B share offer was concluded in July 2020, bringing total funds raised to £7.2 million and our fund-
raising efforts have since continued under our third B share Offer that was launched in October 2020, with £1.5 
million being raised under this third Offer as at 31 December 2020. We were encouraged by the funds raised 
in the two months immediately following launch and remain focused on increasing the size of the B share pool, 
which will in turn allow us to increase the number and diversity of new investments that we make.  

Performance and Dividends 
Despite the unprecedented economic climate and general turmoil of financial markets occasioned by the C-19 
pandemic, we are pleased with the development of the B share portfolio, with six additional investments being 
made in the year. We are also pleased to report an increase in the NAV Total Return per B share, from 96.1p 
at 31 December 2019 to 97.8p as at 31 December 2020.  

This increase in NAV Total Return per B share was the result of a slight reduction in the B share NAV as at 31 
December 2020 (which fell to 91.8p per B share (2019: 93.1p)) which was more than explained by the payment 
of two B share dividends totalling 3.0p during the year.  

These two B share dividends paid during the year were in line with the Company’s ambition to continue to pay 
dividends on the B shares and it should be noted that the Company has sufficient distributable reserves to 
enable the continued declaration of B share dividends over the medium term subject to Board approval, the B 
share pool investment pipeline and liquidity levels.  

AIM Quoted Investments 
With the AIM market demonstrating a heightened level of volatility during the year as a result of the impact of 
C-19,  we  took  the  opportunity  to  realise  just  over  half  of  the  B  share  pool’s  shareholding  in  OptiBiotix  plc 
(“OptiBiotix”) (an investment made during the year), selling 400,000 shares and realising a gain of £92k on the 
disposal (1.6x cash return in just 2 months following the original investment). We also sold our full holding in 
Genedrive (another investment made in the year) which is the B share pool’s first full exit and generated a 
profit of £136k versus original cost (2.1x cash return).  

We were also encouraged that the during the year we saw an increase in the bid price of the two largest B 
share pool AIM quoted investments: the SkinBio share price increased to 22.0p as at 31 December 2020 (a 
57% increase from 14p as at 31 December 2019) and the OptiBiotix share price increased to 57.0p as at 31 
December 2020 (a 42.5% increase from the cost price of 40p per share).  

Co-investing With Seneca EIS Funds  
More generally we continue to develop Seneca’s position in the market as an active growth capital investor 
and as at 31 December 2020, we have raised and deployed c.£100 million of EIS and VCT investment funds 
into over 50 SME companies, through over 100 funding rounds, since we undertook our first EIS investment in 
2012. This includes £8.7 million raised to date by the B share pool.  

14 

 
 
 
 
 
 
 
 
 
 
 
 
The ten investments in the B share portfolio had a value of £3,982k as at 31 December 2020 and are co-
investments with EIS funds also managed by Seneca. We believe that the opportunity for the Company’s B 
share pool to co-invest with EIS funds that are also managed by Seneca provides the B share pool with a 
number of advantages including being able to participate in a higher number of investments, of a larger scale, 
into more established businesses than would be possible for the B share pool on a standalone basis.  

Further, as a result of our position in the UK market as an active growth capital investor we maintain a strong 
pipeline  of  investment  opportunities,  particularly  in  the  North  of  England,  with  a  focus  on  well  managed 
businesses with strong leadership teams that can demonstrate established and proven concepts in addition to 
growth  potential.  We  aim  to  invest  in  both  unquoted  and  AIM  quoted  companies  and  are  pleased  to  have 
completed three additional AIM quoted investments in the year.  

Investee Company Updates 
We are very happy with the development of the B share investment portfolio. As noted above, we are delighted 
to have been able to include some AIM quoted investments in these early investments and are also very happy 
that  by  31  December  2020  we  had  already  been  able  to  exit  some  of  these  at  a  profit  so  early  in  the 
development  of  those  businesses  (1  full  exit  and  2  partial  exits).  These  early  profits  have  supported  the 
performance of the B share pool NAV at the same time as we continue to develop the unquoted company 
investment portfolio.  

We are excited about the potential that lies with the B share investment portfolio and have included updates in 
relation to all of the B share pool investee companies later in this Investment Manager’s Report but wanted to 
highlight  in  particular  the  progress  being  made  by  B  share  pool  investee  companies  SilkFred  Limited 
(“SilkFred”) and SkinBio below and also comment on the reduction in fair value introduced against the carrying 
value of Qudini. 

SilkFred 
SilkFred is an online marketplace which specialises in independent ladies’ fashion brands. The B share pool 
invested £500k in SilkFred in December 2018 and the business made strong progress throughout the first year 
of our investment building a strong reputation and brand in the “event driven” fashion space.  

As you would expect however, this left the business exposed to the impact of the C-19 pandemic in 2020 which 
brought about a fall in sales levels as a result of the reduction in the number of celebrations and events which 
previously drove the company’s growth.  

Notwithstanding this, SilkFred’s recovery from the UK’s first lockdown was swift and Gross Marketplace Value 
(total sales value sold through the SilkFred platform) during the summer months of 2020 actually exceeded 
that of 2019. The business traded well for the rest of the year, remaining profitable throughout, buoyed by the 
loyalty shown by the customer base. The management team continue to view their market position positively 
and are looking to the future with confidence, particularly in anticipation of the return of their core markets as 
the UK emerges from lockdown. We too, are excited about SilkFred’s future.    

SkinBio 
SkinBio is an AIM quoted life science company focused on skin health and the B share pool invested £750k in 
February 2019 at 16p per share. The business made excellent progress during 2020 including raising c£4.45m 
of funds from new and existing investors, successfully accelerating the project timeline for its food supplement 
programme and gaining commercial interest for its MediBiotix™ and CleanBiotix™ programmes. The SkinBio 
share price closed on 31 December 2020 at 22p per share. 

Having initially invested in SkinBio in February 2019, we sold 175,000 shares in early June 2019 at a profit of 
c1.5x original cost reducing the remaining holding to 4,502,107 shares. We did not sell any shares in 2020; 

15 

 
      
 
 
 
 
 
 
 
however following the 31 December 2020 year end, the positive progress being made by SkinBio translated 
into further increases in the share price and we are pleased to report that we have taken the opportunity to 
take some profit from this investment. We sold 1,750,000 shares in January 2021 (37% of the B share pool’s 
original holding of 4,677,107 shares) reducing the remaining holding to 2,752,107 shares. These were sold at 
a net average price of 35.5p per share providing a return in the region of 2.2x on original cost.  

The business is well funded, is targeting a valuable market with unmet cosmetic and clinical needs and we 
remain confident of SkinBio’s long-term prospects of success.  

Qudini 
Qudini  is  a  UK  based  market  leading  provider  of  queue  management  software  for  enterprise  brands.  It 
generates the vast majority of its revenue from bricks and mortar retailers. Given the level of uncertainty caused 
in this core market by C-19, we took the prudent decision to reduce the carrying value of the B share pool’s 
investment in Qudini by 40% as at 30 June 2020. Whilst there has been some improvement in the trading 
performance of Qudini in H2 2020, some uncertainty remains over the future of its core bricks and mortar retail 
market. Therefore, we have maintained the 40% reduction in fair value and this investment was held at 60% 
of cost as at 31 December 2020. 

Investments made after the Year End and outlook 
Following the year end we also completed an additional unquoted company investment into Solascure Ltd 
(“Solascure”) for £500k. Solascure is an early stage wound care specialist which was originally spun out of 
(and continues to work alongside) world leading German biotech company BRAIN engaged in the development 
of a new-to-market wound care product. Solascure is also backed by strategic investor Eva Pharma and the 
business will commence their first clinical trial in 2021. Solascure’s Aurase product is a gel-based product that 
efficiently and gently cleans wounds, making the healing process much more straightforward.  

We look forward to continuing to increase the funds raised for the B share pool under the current Offer and 
with several new investment opportunities in the later stages of due diligence, we expect to add to the portfolio 
of B share investee companies in the coming months. 

16 

 
 
 
 
 
 
Investment Portfolio – B shares 

Unquoted Investments 

Fabacus Holdings Limited 

Silkfred Limited 

Old St Labs Limited  

Ten80 Ltd 

Qudini Limited 

Bright Network Ltd 

ADC Biotechnology Ltd 

Equity  
held  
% 

Investment at 
cost £'000 

Unrealised 
profit/(loss) 
£'000 

Carrying  
value at  
31 December 
2020  
£'000 

Movement  
in the year to  
31 December 
2020 
 £'000 

2.0 

<1.0 

3.8 

7.5 

2.4 

1.7 

<1.0 

500 

500  

500  

400 

500 

234 

150 

63 

- 

- 

- 

(200) 

- 

- 

563 

500 

500 

400 

300 

234 

150 

- 

- 

-                          

- 

(200) 

- 

- 

Total unquoted investments 

2,784 

(137) 

2,647 

(200) 

Quoted Investments 

SkinBioTherapeutics Plc 

OptiBiotix plc 

Abingdon Health plc 

Total quoted investments 

Total investments 

Shares held 

4,502,107 

350,000 

156,250 

Investment at 
cost £'000 

Unrealised 
profit/(loss) 
£'000 

Carrying  
value at  
31 December 
2020 £'000 

Movement 
 in the year to  
31 December 
2020  
£'000 

720 

140 

150 

1,010 

3,794 

270 

60 

(5) 

325 

188 

990 

200 

145 

1,335 

3,982 

360 

60 

(5) 

415 

215 

Exits for the period 

Investment Date 

No. of 
Shares sold 

Investment at 
cost £'000 

Sale 
Proceeds 
£’000 

Realised 
profit/(loss) 

£'000  Exit Multiple 

OptiBiotix Health Plc* 

April 2020 

400,000 

Genedrive Plc 

May 2020 

157,437 

Total 

*Partial exit 

160 

126 

286 

252 

262 

514 

92 

136 

228 

1.6 

2.1 

1.8 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B Share Pool – Investment Portfolio – Top Six Unquoted Investments by value as at 31 December 2020 

1.  Fabacus Holdings Limited 

Initial investment date: 

February 2019 

Cost: 

Valuation: 

Equity held: 

£500,000 

£563,000 

2.0% 

Last statutory accounts: 

31 August 2019 

Turnover: 

Loss before tax: 

Net assets: 

Not disclosed 

Not disclosed 

£7.6 million 

Valuation method: 

Price of last fundraise  

Fabacus is an independent software company that 
has 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  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. 

Progress made by the company in 2020 includes: 

• 

Continuing to make excellent progress with a number of customers, most 
notably through its promising relationship with Amazon.  

•  Onboarding fee-paying licensees to their market leading data platform and 
starting  to  generate  revenue  from  their  relationship  with  IMG  (#1  global 
licensing agency). 

• 

• 

Successfully raising c.£1m to fund the working capital requirements of the 
company and to onboard the growing customer pipeline. 

Collaborating  with  Amazon  to  provide  a  version  of  the  company’s 
technology  which  has  the  ability  to  identify  and  remove  any  counterfeit 
products  from  online  marketplaces.  In  turn  this  has  driven  a  significant 
increase  in  interest  in  and  demand  for  Fabacus’  platform  and  ancillary 
services  which  has  translated  into  increased  commercial  activity  and 
revenue in recent months. 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.  SilkFred Limited 

Initial investment date: 

December 2018 

Cost: 

Valuation: 

Equity held: 

£500,000 

£500,000 

<1% 

Last statutory accounts: 

31 December 2019 

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.  

Turnover: 

Loss before tax: 

Net assets: 

Valuation method:  

£20 million 

£3.1 million 

£4.4 million 

Cost and price of recent 
investment (reviewed for 
any fair value 
adjustment)  

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 seeking innovative methods to enhance the customer experience. 

Progress made by the company in 2020 includes: 

• 

• 

• 

Bouncing back extremely well from the impact of the first C-19 lockdown 
which  saw  the  company’s  primary  market  of  event  driven  fashion  being 
adversely  impacted  by  the  C-19  pandemic.  Product  mix  has  changed 
dramatically in the short term, meaning SilkFred is well positioned for future 
growth with a more diverse customer base and impacted less by seasonal 
trends.  

Continued expansion of SilkFred’s international presence. It is clear that the 
international potential of the brand is a key driver of value in the business 
and it is therefore encouraging to see international sales growing by more 
than 60% in 2020. 

Despite the C-19 impact being felt to some extent throughout 2020, SilkFred 
saw continued growth in its portfolio of brands, increasing to more than 900 
and once again selling over 1m units for the year. The company also saw 
continued improvement in its key performance metrics with average order 
value,  orders  to  repeat  customers  and  return  on  marketing  spend  all 
increasing during the year. 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.  Old St Labs Limited 

Initial investment date: 

March 2019 

Cost: 

Valuation: 

Equity held: 

£500,000 

£500,000 

3.8% 

Last statutory accounts: 

31 March 2020 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

Not disclosed 

Not disclosed 

£260,000 

Cost and price of recent 
investment (reviewed for 
any fair value 
adjustment) 

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. 

Progress made by the company in 2020 includes: 

• 

• 

• 

• 

Engaging with global leaders across a wide range of sectors with keeping 
annual recurring revenue consistent at just over £1m. In what was initially a 
slow period for the business with large corporate customers slowing down 
decision making and pausing project spend upon the onset of C-19, Old St 
Labs  have  worked  closely  with  existing  customers  and  have  returned  to 
growth  in  the  second  half  of  the  year  with  multiple  impressive  customer 
wins. 

Continuing to expand the Vizibl platform and enhancing its capabilities and 
usability. In the current year, in response to the global pandemic, the team 
have  pushed  more  of  a  sustainability  angle  into  the  platform,  adding 
features and enhancements to assist both new and existing customers with 
ensuring that their projects and organisations remain resilient. 

Building on an already impressive customer base by onboarding Unilever 
and  Sanofi.  Not  only  do  these  types  of  customers  improve  the  financial 
profile of  the business, but they  also further  validate  the  proposition and 
serve to demonstrate the viability of the Vizibl platform across a wider range 
of sectors. 

Securing a £2.5m funding from the UK Government-backed Future Fund, 
providing sufficient headroom to progress through to profitability. 

20 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4.  Ten80 Group Limited 

Initial investment date: 

March 2020 

Cost: 

Valuation: 

Equity held: 

£400,000 

£400,000 

7.5% 

Last statutory accounts: 

31 December 2019 

Based in Hammersmith, Ten80 Group Limited (“Ten80”) 
was established in early 2019. The company is a SAP 
focussed  on-demand  outcome-based  delivery  solution. 
SAP is  best  known  for  producing  enterprise  resource 
planning software which allows organisations to manage 
business operations across procurement, manufacturing, service, sales, finance, and 
HR. 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

Not disclosed 

Not disclosed 

£30,000 

At cost (reviewed for any 
fair value adjustment) 

Ten80’s aim is to connect every SAP customer with every SAP consultant globally, 
delivering outcome-based projects rather than time-driven costs through the contractor 
or freelancer marketplace. 

The SAP global consultancy market is estimated to be worth in excess of £300bn. 

Progress since our investment:  

• 

• 

• 

Securing  its  first  paying  customers,  providing  further  validation  that  the 
proposition is of value to large corporations with significant IT project spend. 
Whilst  the  global  pandemic  has  slowed  down  large  enterprise  decision 
making,  it  has  also  fast-tracked  the  shift  to  remote  working  and  flexible 
resource, something which plays into the hands of the Ten80 proposition. 

Successfully adding the required skills to the team scaling it from 5 people 
at the time of investment to 19 at present. This has added valuable resource 
across  the  business,  with  key  focus  on  the  development  team,  sales 
personnel and customer success roles. 

Further, in January 2021 the business secured a £1m funding round under 
the  UK  Government-backed  Future  Fund.  This  will  in  turn  provide  the 
business  with  additional  cash  headroom  as  they  focus  on  converting  an 
exciting customer pipeline and expanding the customer base, as well as 
ramping up usage of the Ten80 platform within existing customers. 

21 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5.  Qudini Limited 

Initial investment date: 

April 2019 

Cost: 

Valuation: 

Equity held: 

£500,000 

£300,000 

2.4% 

Last statutory accounts: 

31 December 2019 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

Not disclosed 

Not disclosed 

£3.1 million 

At cost, less a 40% 
reduction in fair value to 
reflect potential impact 
of C-19 on the 
company’s core UK 
markets 

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

experience  SaaS 

customer 

solutions 

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.  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.  

2020 update:  

•  Given that the company's main source of income is through the provision of 
queuing technology for bricks and mortar retailers, the effect of C-19 during 
the first UK lockdown was expected to be significant. As such, the company 
took the opportunity to restructure its cost base and reduce FTE’s by c.50% 
to 19 and put a stop to any unnecessary spend in order to preserve cash. 
Consequently, we applied a 40%  reduction in  fair value (in  March 2020) 
against  the  carrying  value  of  the  B  share  pool’s  investment  in  Qudini  to 
reflect this uncertainty and have maintained this at 31 December 2020. 

• 

Although a level of uncertainty remains given the company’s retail market 
exposure,  the  outlook  has  improved  somewhat  given  the  increasing 
demand for queuing/customer management technologies as retailers look 
to re-open and trade safely.  

•  Whilst the environment for new business during the first lockdown had not 
been ideal, Qudini now has a short window of opportunity to continue to 
gain market share in H1 2021.  

• 

The  demand  noted  above  has  driven  an  increase  in  Annual  Recurring 
Revenue  (“ARR”)  as  at  December  2020  to  c.£2.5m  (December  2019: 
£1.8m); however,  it  will be a key focus of the management team over the 
next 12 months to upsell Qudini’s other services in order to help retain the 
company’s new customers post-covid and transition those new customers 
on to longer term contracts. 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.  Bright Network (UK) Limited 

Initial investment date: 

March 2020 

Cost: 

Valuation: 

Equity held: 

£234,000 

£234,000 

1.7% 

Last statutory accounts: 

31 March 2020 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

Not disclosed 

Not disclosed 

£4.9 million 

At cost (reviewed for any 
fair value adjustment) 

Bright  Network  (UK)  Limited  (“Bright”)  is  a  Human 
Resources  technology  platform  designed  to  enable 
leading employers to reach, identify and recruit high 
quality  graduates  and  young  professionals.  At  the 
time of our investment, the platform supported a network of over 255,000 high calibre 
candidates  and  has  300+  leading  employers  within  its  customer  base,  including 
multiple high-quality blue-chip clients. These employers utilise Bright’s services to fill 
annual  intern  and  graduate  recruitment  scheme  places,  as  well  as  any  bespoke 
recruitment requirements. 

Data analytics and machine learning is utilised to support and continuously improve 
identification of the best-suited talent to each employer. Bright provides a free service 
to  undergraduates,  personalising  careers  advice  and  job  matches  to  support  their 
career journey. The database is therefore a growing data-rich asset, processing 30 
million pieces of data on a new generation of young professionals. 

In March 2020, the VCT invested £234,000, as part of a larger £3.5m fundraise to allow 
the company to increase the size of its digital and talent solutions’ sales and marketing 
resources,  together  with  improvements  to  the  technical  platform  to  drive  additional 
service revenues. 

Progress since our investment:  

• 

• 

• 

• 

Limiting the potential impact of C-19 by cutting its cost base and through 
the launch of online internships which were extremely well received over 
the summer. This has resulted in an increase in registered users to over 
350,000.  

Trading  ahead  of  expectations.  Due  to  the  pandemic  the  sales  season 
(which  typically  ends  at  the  end  of  August)  has  been  extended,  and  the 
company continues to be on track to surpass the £2.5M revenue target for 
the financial year ending 31 March 2021 (FY21). 

Delivering strong top line performance coupled with tight cost control has 
resulted  in  the  company  outperforming  FY21  planned  gross  profit  and 
EBITDA. 

Delivering an improved cash position which is £900k ahead of budget. This 
outperformance  alongside  business  agility  puts  the  company  in  a  strong 
position as the UK recovers from the C-19 pandemic. However, whilst more 
macro-economic  uncertainty  remains,  this  investment  will  continue  to  be 
held at cost. 

23 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B Share Pool - Investment Portfolio – AIM Quoted Investments as at 31 December 2020 

1.  SkinBioTherapeutics Plc 

Initial investment date: 

February 2019 

Cost (of the portion of 
the original investment 
still held as at 31 
December 2020): 
Valuation: 

Equity held: 

£720,000 

£990,000 

2.9% 

Last statutory accounts: 

30 June 2020 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

£nil 

£1.6 million 

£2.5 million 

Bid price of 22p per 
share 

SkinBioTherapeutics  is  a  life  science  company 
focused  on  skin  health.  The  company's  proprietary 
platform  technology,  SkinBiotixTM,  is  based  upon 
discoveries made by 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 SkinBiotixTM 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 SkinBiotixTM platform has beneficial attributes 
applicable to each of these areas.  

The aim of the company is to develop its SkinBiotixTM 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. 

Progress made by the company in 2020 includes:  

• 

• 

• 

• 

Announcing a 3 year agreement with Winclove to focus on the development 
of  a  blend  of  probiotic  bacteria  which  have  been  identified  as  having  a 
positive impact on the psoriasis disease pathway. Under the agreement, 
SkinBio  will  identify  the  specific  probiotic  strains  which  Winclove  will 
formulate  and  manufacture  into  a  consumable  product  to  be  branded 
AxisBiotix.  Later  in  the  year  the  company  announced  that  Winclove  had 
been able to successfully combine and formulate the blend as a probiotic 
food supplement, to be known as AxisBiotix Ps, several months ahead of 
schedule. A study is due to commence in February 2021. 

Announcing  in  July  2020  that  the  SkinBiotix  cosmetic  programme  had 
achieved a number of key scientific milestones with its partner Croda. Croda 
has successfully replicated the lysate manufacturing process and achieved 
the same performance from the SkinBiotixTM technology as established by 
the  company.  Croda  is  now  working  to  validate  scale  up  of  the 
manufacturing process at different volume levels. The project is progressing 
in line with the original plan and has not been adversely impacted by C-19. 

Continued progress with live opportunities across its MediBiotix, CleanBiotix 
and  PharmaBiotix  divisions,  including  the  development  of  eczema 
treatments as well as additional opportunities designed to reduce hospital 
acquired infections. 

Completion  of  a  £4.5m  funding  round  in  October  2020,  providing  the 
business with sufficient cash headroom to progress with its exciting pipeline 
of commercial opportunities, as well as continuing with the development of 
a number of early stage, pre-clinical opportunities. 

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.  OptiBiotix Health Plc 

Initial investment date: 

April 2020 

Cost (of the portion of 
the original investment 
still held as at 31 
December 2020): 
Valuation: 

Equity held: 

£140,000 

£200,000 

<1.0% 

Last statutory accounts: 

31 December 2019 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

£745,000 

£2.2  million 

£5.2 million 

Bid price of 57p per 
share 

OptiBiotix Health PLC is a Life Sciences business 
operating in one of the most progressive areas of 
research, 
developing 
biotechnological 
technologies 
human 
that  modulate 
microbiome  –  the  collective  genome  of  the 
microbes in the body. The business identifies and 
develops microbial strains, compounds and formulations for use in food ingredients, 
supplements and active compounds that can impact on human physiology, deriving 
potential health benefits. 

the 

With  an  established  pipeline  of  microbiome  modulators,  the  OptiBiotix  team  works 
today in the prevention and management of chronic lifestyle diseases including obesity, 
hypercholesterolemia and lipid profiles, and diabetes. 

To date, the company has signed in excess of 50 commercial deals globally to supply 
or licence its suite of products/supplements to manufacturers and retailers and has 
launched a number of its own brand products. The VCT invested £300,000 into a £1m 
fundraise in April 2020, with funds being used to launch its award-winning products 
across Asia and the US, through partners who have an international reputation and 
significant  retail  network,  as  well  as  further  expanding  the  portfolio  of  products. 
Between  investment  and  31  December  2020  53%  of  the  shares  originally  acquired 
have been realised at a 60% profit.  

Progress since our investment:  

• 

Announcing positive half year results for the 6 month period to 30 June 2020 
including: 

o  H1 revenue growth of £745k.  
o 
o 

a 5x increase in revenues from H1 2019.  
a 15.5% reduction in other administration costs.  
a 50% reduction in loss compared to the same period in the prior 
year. 

The company is now at a commercial turning point with the business model now proven 
through  growing  sales  from  proven  products,  established  partners  in  multiple 
international  territories,  and  reduced  administration  and  R&D  costs.  We  believe  the 
company is therefore well placed to attack the various attractive markets in which they 
are gaining traction. 

Optibiotix’s first generation products, SlimBiomeTM, and LPLDLTM, are now established 
scientifically, clinically, and commercially with products being sold in over 120 countries 
around the world and a growing brand presence. 

As sales and profitability in first generation products continues to improve, there is an 
expectation this should enhance the company’s reach into new application areas and 
territories, and commercialise next generation products – all of which have the ability 
to further enhance the scale and growth prospects of the company. 

25 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.  Abingdon Health plc 

Initial investment date: 

December 2020 

Cost: 

Valuation: 

Equity held: 

£150,000 

£145,000 

<1.0% 

Last statutory accounts: 

30 June 2019 

Turnover: 

Loss before tax: 

Net assets: 

Valuation method: 

£2.3 million 

£1.5  million 

£6.2 million 

Bid price of 93p per 
share 

Abingdon  Health 
is  a  specialist 
outsourced  Contract  Development 
and  Manufacturing  Organisation 
(CDMO)  providing  a  full  suite  of 
services to the lateral flow diagnostic market. It is the lead member of the UK’s Rapid 
Test  Consortium  (UK-RTC)  for  a  point-of-need  C-19  antibody  test  (AbC-19)  and  is 
investing in automated manufacturing to significantly increase capacity and attract new 
customers across a range of sectors. 

As  the  lead  member  of  UK-RTC,  the  company  co-ordinated  a  consortium  of  four 
companies (including former Ordinary share portfolio company Omega) and, in under 
four months, successfully developed and validated a rapid lateral flow test (“AbC-19”) 
for detecting SARS-CoV-2 IgG antibodies. The UK Government has ordered the first 
1m devices and provided funding for the components for a further 9m to be delivered 
in the coming months. There is a mechanism by which Abingdon Health can sell any 
excess supply externally and it has already had significant interest from a number of 
third  parties.  It  is  also  working  with  a  number  of  partners  on  rapid  antigen  tests, 
leveraging  its  key  lateral  flow  competencies  and  offering  broad  exposure  in  C-19 
diagnostics. The pandemic has driven a material step change in demand for lateral 
flow tests generally and has catalysed a number of other C-19 and non-C-19 contract 
development and manufacturing opportunities. 

Abingdon Health has established relationships with blue chip partners and a strong 
pipeline  of  potential  new  business,  including  a  number  of  signed  and  qualified 
opportunities.  It  also  has  an  innovative  and  proprietary  mHealth  solution,  AppDx,  a 
customisable smartphone reader that is capable of quantitative analysis of lateral flow 
tests and the transfer of real-time data.  

The investment was completed just before the end of the financial year, so there is no 
further progress to report from 2020. 

26 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B Share Pool – Investment Portfolio – Post-balance sheet Investments as at 22 February 2021 

1.  Solascure Ltd 

Initial investment date: 

January 2021 

Cost: 

Valuation: 

Equity held: 

£500,000 

£500,000 

2.8% 

Last statutory accounts: 

30 June 2019 

Turnover: 

Loss before tax: 

Net assets: 

Not disclosed 

Not disclosed 

£ 6.7 million 

Valuation method: 

At cost 

Solascure  is  an  early  stage  wound  care 
specialist, originally spun out of and working 
alongside  BRAIN  (world  leading  German 
biotech  company),  to  develop  a  new-to-
market  wound  care  product.  In  2019,  the 
company  deconsolidated  from  BRAIN  and 
brought in additional strategic investment from Eva Pharma (c.£2m) and is now set to 
commence clinical trials of its wound care product Aurase. Solscure’s Aurase is a gel-
based product that efficiently and gently cleans wounds, making the healing process 
much  more  straightforward.  Pre-clinical  work  has  been  extremely  positive  and  the 
clinical trial planning process is now well progressed.  

Chronic wounds are a growing global problem, and alternative methods of treatment 
for hard to heal wounds are extremely expensive, impractical and slow. Solascure’s 
proprietary technology utilises the key mechanism of maggot debridement without the 
cost  or  labour  input  of  live  maggots.  In  simple  terms,  it  uses  maggot  elements  to 
facilitate and promote the body’s own wound cleansing processes. Core benefits of the 
product  are  the  clear  practical  elements,  as  well  as  the  reduced  time  scale  to  full 
debridement without delaying wound healing.  

SolasCure  have  an  approved  protocol  for  a  clinical  study  in  order  to  reach  market 
authorisation, which is anticipated to commence in early 2021 (with phase 1 anticipated 
to conclude by the end of the year). Crucially, the product permits the use of the main 
maggot-derived wound debriding enzyme without the cost or labour input involved with 
the  use  of  live  maggots,  but  also  augments  and  synergises  the  body’s  own  wound 
cleansing  processes.  The  product  is  expected  to  demonstrate  3  key  benefits:  1) 
Specific swift destabilisation of fibrin debris; 2) No irritation or damage to healthy tissue; 
3) Reducing the time to full debridement without delaying wound healing.  

In January 2021, the VCT invested £500,000, alongside £733,000 of Seneca EIS funds 
as part of a £2.9m fundraise to allow the company to progress and complete the full 
trial (Phase 1 and 2) by the end of 2022.  

27 

 
 
 
 
 
 
 
 
 
 
 
  
 
 
The Ordinary Share Pool 

Shareholders  will  recall  that  whilst  Seneca  is  the  Company’s  Investment  Manager,  responsibility  for  the 
management of the Ordinary share pool investments continues to rest with those remaining members of the 
Board of Directors who were serving at the point of Seneca’s appointment on 23 August 2018, which now 
includes John Hustler and Richard Roth.  

AIM Quoted Investments 
The Ordinary share pool’s largest investment is AIM quoted Scancell and this represented 37% of the Ordinary 
share pool’s NAV as at 31 December 2019 when the Scancell share price was 7.0p. During the year, the 
Scancell share price almost doubled and ended the year at 13.5p. In view of this increasing share price, the 
Company took the opportunity to realise some profit and sold a small portion of our Scancell shares during the 
year (1,049,730 shares (8%) were sold from a holding at the start of the year of 13,049,730 shares) realising 
£127k and generating a profit versus original cost of £64k (a 2x return on the original investment) and a profit 
versus the 31 December 2019 carrying value of £54k. The Ordinary share pool’s remaining stake in Scancell 
of 12,000,000 shares increased by £780k during the year to stand at a value of £1,620k as at 31 December 
2020.  

The Ordinary share pool’s investment in AIM quoted Omega gained significant traction in the year following its 
involvement in a partnership to develop a C-19 antibody test. The share price rose substantially from its 31 
December 2019 price when it was 14p and this allowed the Company to sell the Ordinary share pool’s entire 
holding of 2,293,868 Omega shares in the year for a total of £987k. This generated a profit versus original cost 
of £659k (a 3x return on the original investment) and similarly a profit of £666k versus its 31 December 2019 
value.  

Unquoted Investments 
With regard to the Ordinary share pool’s unquoted investments, the carrying value of OR Productivity Limited 
(“ORP”) and Fuel 3D Technologies Limited (“Fuel 3D”) were both reduced as a result of fundraises by these 
companies in 2020. In the case of ORP, the dilutive impact of the funds raised are such that the Company  
reduced the carrying value to £nil for the Ordinary share pool’s investment in ORP as at 31 December 2020 
(31 December 2019 carrying value: £233k) and in the case of Fuel 3D the carrying value has been reduced to 
bring it in line with the price of their 2020 fundraise. Although the Ordinary share pool has maintained the value 
of Arecor Ltd at the price of the last fundraising in 2018, it continues to make excellent technical and commercial 
progress. 

Performance and Dividends 
As a result of the above AIM quoted investee company realisations, the Ordinary share pool was able to pay 
dividends totalling 13p per Ordinary share during the period. 

The Total Return in relation to the Ordinary shares is now 95.5p comprising cumulative distributions of 65.25p 
per Ordinary share and a residual NAV per Ordinary share of 30.2p as at 31 December 2020.  

As noted in the Chairman’s statement, the Company is focussed on realising assets in the Ordinary share pool 
at the appropriate time with the proceeds then being distributed to Ordinary shareholders as dividends – it is 
therefore noteworthy that in the 3 years to 31 December 2020 the Company has paid out dividends totalling 
41p per Ordinary share (equivalent to 64.3% of the NAV per Ordinary share of 63.8p as at 31 December 2017) 
and the Ordinary share pool also retains NAV per Ordinary share of 30.2p as at 31 December 2020.  

28 

 
 
 
 
 
 
 
 
 
 
Investment Portfolio – Ordinary shares 

Unquoted Investments 

Arecor Limited 

Fuel 3D Technologies Limited 

Insense Limited 

OR Productivity Limited 

Microarray Limited 

ImmunoBiology Limited 

Equity  
held  
% 

Investment 
at cost 
£'000 

Unrealised 
profit/(loss) 
£'000 

Carrying 
value at  
31 December 
2020  
£'000 

1.1 

<1.0 

4.6 

3.7 

3.0 

1.2 

142  

299  

509  

765  

132  

868  

63  

(104)  

(388) 

(765) 

(132) 

(868) 

205  

195  

121  

-  

-  

-  

Movement  
in the year to  
31 December 2020  
£'000 

                         - 

  (81)  

- 

(232) 

- 

- 

Total unquoted investments 

2,715 

(2,194) 

521  

(313) 

Quoted Investments 

Scancell plc 

Total quoted investments 

Total investments 

Shares held 

12,000,000 

Investment 
at cost 
£'000 

Unrealised 
profit/(loss) 
£'000 

Carrying 
value at  
31 December 
2020 £'000 

Movement 
 in the year to  
31 December 2020  
£'000 

726 

726  

894 

894 

          3,441 

(1,300) 

1,620 

1,620 

2,141 

780 

780 

467 

Exits for the period 

Investment Date 

No. of 
Shares sold 

Investment at 
cost £'000 

Sale 
Proceeds 
£’000 

Realised 
profit/(loss) 

£'000  Exit Multiple 

Scancell plc * 

December 2003 

1,049,730 

Omega Diagnostics plc 

August 2007 

2,293,868 

Exosect Limited ** 

January 2010 

8,575 

Total 

*Partial exit 
**Dissolved 24 January 2020 

63 

328 

270 

661 

127 

987 

- 

1,114 

64 

659 

(270) 

453 

2.0 

3.0 

- 

1.7 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ordinary Share Pool – Investment Portfolio – All Six Unquoted Investments by value as at 31 December 
2020 

1.  Arecor Limited 

Initial investment date: 

January 2008 

Cost: 

Valuation: 

Equity held: 

£142,000 

£205,000 

1.1% 

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.  

Last statutory accounts: 

31 December 2019 

Progress made by the company in 2020 includes: 

Turnover: 

£748,000 

Loss before tax: 

£2.7 million 

Net assets: 

£4.2 million 

Valuation method: 

Price of last fundraise 

• 

• 

• 

• 

• 

Announcing  in  March  2020  that  Arecor  had  extended  its  multi-product 
collaboration with a US-based clinical stage biotechnology company. 

Announcing in June 2020 positive results of their phase 1 trial on AT247.  

Expanding their partnership with Hikma announced 20 October 2020. 

Commencing in December 2020 dosing patients in the AT278 clinical study 
(ultra-concentrated insulin, first in man study) following a £1.9m fund raise: 
this is a very significant milestone as they continue to build momentum with 
their differentiated portfolio of superior products.  

Announcing in late December 2020 that Arecor’s partner, Inhibrx, exercised 
their option to license a novel formulation of the investigational clinical stage 
product, INH-101, developed by Arecor. This is the first license under a multi-
product  collaboration  with  Inhibrx  and  further  validates  the  value  of  the 
ArestatTM technology platform in developing superior versions of existing 
therapeutic products. 

30 

 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.  Fuel 3D Technologies Limited 

Initial investment date: 

March 2010 

Cost: 

Valuation: 

Equity held: 

£299,000 

£195,000 

< 1% 

Last statutory accounts: 

31 December 2019 

Turnover: 

£521,000 

Loss before tax: 

£4.3 million 

In 2014 Fuel 3D was formed to acquire the computer 
3D  imaging  IP  of  Seneca  Growth  Capital  Ordinary 
share 
initial 
investee  company,  Eykona.  The 
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 e.g. 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.  

Net assets: 

£5.4 million 

Progress made by the company in 2020 includes: 

Valuation method: 

Price of last fundraise 

• 

• 

• 

• 

The  development  of  BioVolume  in  conjunction  with  major  pharmaceutical 
companies  but  have  suffered  C-19  related  delays:  trials  with  three  of  the 
majors are only now coming to an end and the fourth commenced in January 
2021. The data to date looks promising and has recently enabled the signing 
of a contract to sell two units to a specialist research lab. 

The continued development of the technology for FitsYou applications (e.g. 
sleep apnoea masks and eyewear) has taken longer than expected, partly 
due to working at the edge of capability of partners’ platforms. The app that 
has  been  designed  for  the  world’s  largest  manufacturer  of  sleep  apnoea 
masks (to allow them to scan customers’ faces in order to assess best fit) 
has recently been completed and a three month pilot will start early in the 
New Year, hopefully resulting in a commercial licensing agreement later in 
2021. The same technology is also being used to develop tools targeted at 
the eyewear industry, developing apps to bring virtual try on and best fit to 
eyewear  retailers  and  brands.  Fuel  3d  is  exploring  the  launch  of  a  B2C 
marketplace  and  the  company  has  filed  a  patent  application  to  cover  the 
creation of a 3D model using depth data generated by mobile devices which 
it expects to form a fundamental part of its technology offering within FitsYou.   

The reduction in cash burn, which is now c.40% lower than this time last year 
and the raising of £3.8m (at a slightly reduced valuation) means that even in 
the  absence  of  revenues,  the  company  has  sufficient  runway  to  take  it 
through  to  the  end  of  2021,  although  it  may  seek  further  investment  to 
accelerate development and commercialisation of FitsYou.  

The  board  of  Fuel3D  is  also  considering  separating  each  business  into 
separate units as the BioVolume and FitsYou businesses are likely to appeal 
to different buyer audiences. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3. 

Insense Limited 

Initial investment date: 

July 2003 

Cost: 

Valuation: 

Equity held: 

£509,000 

£121,000 

4.6% 

Last statutory accounts:  31 December 2019 

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

It  has  since  had  two  successful  spinouts,  namely 
Arecor  (see  above)  and  Archimed,  from  which 
Microarray  (see  below)  was  also  spun-out.  Current 
Insense  development  activity  is  concentrated  on 
dermatology  products  for  both  professional  and 
consumer applications.  

Turnover: 

Not Disclosed 

Progress made by the company in 2020 includes:  

Loss before tax: 

Not Disclosed 

Net liabilities: 

£51,000 

Valuation method:  

Price of last fundraise 

• 

Completing testing of the UV lamp that will be used in a first-in-man trial and 
continuing preparations for further formulation and stability testing. C-19 has 
affected  progress in 2020, slowing the speed of product and service delivery 
from Chinese and UK-based partners. 

4.  OR Productivity Limited 

Initial investment date: 

March 2011 

Cost: 

Valuation: 

Equity held: 

£765,000 

£nil 

3.7% 

Last statutory accounts: 

31 March 2020 

Turnover: 

Not Disclosed  

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.  

intellectual  property 

Freehand  2010  owns 
to 
the 
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  company  sells  the 
system outright and provides consumables although, increasingly, 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. 

Loss before tax: 

Not Disclosed  

Progress made by the company in 2020  includes: 

Net liabilities: 

£4.6 million 

Valuation method:  

Carrying value reduced 
to £nil 

• 

• 

• 

• 

An  initial  fundraising  in  2020  which  raised  £750,000  following  which  a 
Crowdcube funding campaign was launched. To date the fundraising has 
achieved £1.225 million.  

Year  over  year  sales  being  up  in  spite  of  C-19  but  pressures  on  elective 
surgery have resulted in significant revenue shortfall to budget.  

Spanish distributor MBA continuing to lead the way and has ordered 3 new 
Panorama robots from the company. 

Announcing a new distribution partnership with Imperial Medical Solutions to 
support sales in India, Sri Lanka, Malaysia and the Caribbean.  

The current fundraising has been through the issue of A Ordinary shares which carry a 
one times repayment preference. In addition further A Ordinary shares with the same 
preference have been issued to redeem certain outstanding liabilities. At the present 
time the Board considers it unlikely that the Ordinary share pool investment in ORP can 
be valued in excess of the value of the A Ordinary shares issued. The Ordinary share 
pool does not hold any A Ordinary shares. 

32 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
5. 

ImmunoBiology Limited 

Initial investment date: 

November 2005 

Cost: 

Valuation: 

Equity held: 

 £868,000 

 £nil 

 1.2% 

Last statutory accounts: 

 31 May 2020 

Turnover: 

 £nil 

Loss before tax: 

 £594,000 

Net assets: 

 £262,000 

Valuation method:  

Carrying value reduced 
to £nil  

(“ImmBio”) 

illnesses  such  as  meningitis, 

ImmunoBiology 
is  a  biotechnology 
company  that  is  focused  on  developing  treatments 
for 
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 
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.  

the  normal 

response 

immune 

ImmBio - formally known as ImmunoBiology Ltd has licensed its pneumococcal vaccine 
to China National Biotech Group. It has completed certain parts of its technology transfer 
and is now seeking to start a phase 2 study of the same vaccine. Coronavirus has again 
highlighted the importance of vaccines to the world and in recent years pneumococcal 
disease has claimed a similar number of deaths as C-19 in 2020. An existing vaccine 
has reduced the death rate, but the existing vaccines only protect against fewer than 20 
of the 90 or so existing strains. As ImmBio’s ImmBioVax technology utilises heat shock 
proteins to activate T-cell responses, it is hoped that it can be used to create vaccines 
for a wide range of currently poorly served infectious diseases. 

ImmBio has a complex equity structure which has impacted the investment valuation. 
As  such,  the  Board  does  not  believe  that  the  Company’s  Ordinary  share  pool’s 
investment currently has any value.  

Progress made by the company in 2020 includes: 

• 

• 

• 

Continuing with the technology transfer to a subsidiary company of China 
National  Biotec  Group  to  co-develop  ImmBio’s  proprietary  PnuBioVax 
vaccine  against  pneumococcal  disease  and  launch  the  pneumococcal 
vaccine  in  the  Greater  China  area  upon  completion  of  successful  clinical 
studies but there is also a requirement to start a clinical trial outside China 
which needs funding. 

Improving  the  required  storage  conditions.  (hoping  to  achieve  refrigerator 
storage)  via  their    partnership  with  CPI  (an  independent  technology 
innovation centre) to produce a Pneumococcal vaccine which is heat stable, 
thus avoiding the need (and inherent expense) of the cold chain – ImmBio 
estimate there to be c.50 million patients annually who could benefit from 
such a vaccine. 

Commencing  discussion  with  a  number  of  strategic  partners  and  vaccine 
producers, some of whom have technology to use Immbio’s approach; there 
are regulatory challenges but C-19 may help in this scenario. It has certainly 
made  everyone  more  receptive  to  vaccines  and  with  different  mutations, 
universal vaccines become more popular. Existing C-19 vaccine suppliers 
are also keen to have a  second or third approach on their books especially 
which doesn’t need to keep up with changing strains; this may be beneficial 
to Immbio. 

Almost all staff are currently furloughed, whilst further funds can be obtained. 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.  Microarray Limited 

Initial investment date: 

January 2011 

Cost: 

Valuation: 

Equity held: 

£132,000 

£nil 

3.0% 

Last statutory accounts:  31 December 2019 

Turnover: 

Not Disclosed  

Loss before tax: 

Not Disclosed 

Net liabilities: 

£(4 million) 

Valuation method: 

Carrying value reduced 
to £nil 

Microarray  Ltd  is  a  UK-based  specialist  wound 
healing company. Founded in 2000, Microarray was 
de-merged from 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, 
sales;  electrochemistry  and 
marketing  and 
diagnostic  sensor 
technologies;  biochemistry, 
oxygen  and  iodine  chemistry;  enzymology,  immunology  and  inflammation.  Current 
research  and  development  activities  are  concentrated  on  innovative  wound  care 
diagnostics. 

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 2020 includes: 

• 

• 

Designing  and  gaining  the  necessary  approvals  for  our  next  clinical  trial 
looking at chronic wound state biomarkers. C-19 has affected the recruitment 
of patients for the trial, which is now hoped to start  in Q3/2021.  

In  parallel,  the  company  continues  to  use  machine-learning  methods  to 
analyse  the  clinical  data    collected  to  date,  and  is  investigating  the 
commercial potential of these non-biomarker assets. 

Previously product testing results have not provided the indicators that the company 
hoped for in terms of assessing whether a wound is infected or not. As a result of this 
adverse outcome in relation to an area of focus for the company, the carrying value of 
the investment of the Ordinary share portfolio’s investment in Microarray Limited has 
been reduced to £nil. Notwithstanding the above, the company is continuing to develop 
its wound diagnostic products as the progress in 2020 indicates. 

34 

 
 
 
 
 
 
 
 
Ordinary Share Pool – Investment Portfolio – AIM Quoted Investment as at 31 December 2020 

December 2003  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.  

£726,000 

1.  Scancell plc 

Initial investment 
date: 

Cost (of the portion 
of the original 
investment still 
held as at 31 
December 2020): 

Valuation: 

£1,620,000 

Equity held: 

1.5% 

Last statutory 
accounts: 

30 April 2019 

Turnover: 

£nil 

Loss before tax: 

£6.7 million 

Net assets: 

£9.3 million 

Valuation method:   Bid price of 

13.5p per share 

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. The AvidMab platform was established in 2018 which 
allows direct tumour killing.  

Scancell  continues  to  develop  its  multiple  technologies.  Progress  made  by  the  company  in  2020 
includes:  

• 

• 

• 

The company received FDA approval in February 2020 to initiate the US arm of the Phase 
2 SCIB1 clinical trial although C-19 has delayed patient recruitment. The Modi-1 Phase1/2 
trial is progressing for regulatory submission with a planned study start in the UK in the first 
half of 2021. GMP drug manufacture is advancing and formal regulatory-compliant toxicity 
studies are complete The new AvidiMab platform has also generated significant interest and 
further agreements have been signed with different partners to evaluate its potential, which 
if successful, could translate into important commercial deals. 

In April Scancell announced it had initiated a research project to use its clinical expertise in 
cancer to produce a simple, safe, cost effective and scalable vaccine which could induce a 
durable response against the virus that causes C-19. The project is funded by a £2 million 
Innovate  UK  grant  awarded  in  August  to  a  consortium  between  Scancell,  University  of 
Nottingham and Nottingham Trent University. Scancell has now selected their C-19 vaccine 
candidate, SN14, for further development and clinical trials. SN14 is a second generation 
vaccine which offers several potential advantages over currently approved and late-stage 
C-19 vaccines. In October, it entered into a collaboration with Cobra Biologics, part of the 
Cognate BioServices family, to conduct preliminary work leading to the manufacture of SN14 
with the goal of starting a Phase 1 COVIDITY clinical trial as soon as possible during 2021.  

During the year, the company completed two successful fund raises totalling £48 million 
(£46.1 million net proceeds) from the issue of shares and convertible loan notes (CLN): In 
August,  it  raised  £15  million  at  a  price  of  5.5p  per  share  (includes  a  residual  amount  of 
£1.75m held in CLN, and which included a significant new US institutional investor (Redmile 
Group LLC, “Redmile”). This funding will allow planned trials to continue while partnering 
discussions  are  pursued.  In  October,  a  further  £33m  was  raised  predominately  from 
Redmile: £15.1m in equity at 11p per share and £17.9m in CLN. Redmile now holds just 
under 30% of the equity and all of the CLN, and Vulpes Life Science Fund 14.5%. These 
additional funds will extend the utility of the company's ImmunoBodyTM, ModitopeTM, and 
AvidiMab™/tumour-associated  glycans  ("TaG")  antibody  products  and  platforms  and  to 
accelerate  and  broaden  its  development  pipeline  of  new  potential  novel  therapies  and 
increase the funding available for the company's C-19 vaccine. 

As a result of these developments, the Scancell share price has seen much volatility with prices ranging 
from 4p to 20p during the year. These valuations are based on a bid price of 13.5p per share and the 
bid price was 24.5p per share at 19 February 2021. 

Richard Manley  
Seneca Partners Limited  
22 February 2021 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2020 and the B shares from August 2018 to December 2020, 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.  

Ordinary Share Performance

)
p
(
n
r
u
t
e
R

 350.00
 300.00
 250.00
 200.00
 150.00
 100.00
 50.00
 -

Q 4 2001

Q 4 2002

Q 4 2003

Q 4 2004

Q 4 2005

Q 4 2006

Q 4 2007

Q 4 2008

Q 4 2009

Q 4 2010

Q 4 2011

Q 4 2012

Q 4 2013

Q 4 2014

Q 4 2015

Q 4 2016

Q 4 2017

Q 4 2018

Q 4 2019

Q 4 2020

Ordinary Share NAV Total Return*

Ordinary Share NAV Total Return Including Income Tax Reliefs**

FTSE All-Share Index Total Return***

* Includes Ordinary share dividends reinvested. Rebased to 100p at launch 
** Includes Ordinary share dividends reinvested and income tax relief on initial investment and Ordinary share reinvestments. Rebased to 100p at launch  
*** Rebased to 100p at launch 

B Share Performance

)
p
(
n
r
u
t
e
R

 140.00
 120.00
 100.00
 80.00
 60.00
 40.00
 20.00
 -

Q 3 2018

Q 4 2018

Q 1 2019

Q 2 2019

Q 3 2019

Q 4 2019

Q 1 2020

Q 2 2020

Q 3 2020

Q 4 2020

B Share NAV Total Return*

B Share NAV Total Return Including Income Tax Reliefs**

FTSE All-Share Index Total Return***

* Includes B share dividends reinvested. Rebased to 100p at launch 
** Includes B share dividends reinvested and income tax relief on initial investment and B share reinvestments. Rebased to 100p at launch  
*** Rebased to 100p at launch 

36 

 
 
 
 
 
 
 
 
 
 
 
 
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 - Return on ordinary activities as per Income Statement 

Net return attributable to Ordinary shareholders  
Net return attributable to B shareholders 
Total 

Key Performance Indicators (KPIs) 

Year ended 

Year ended 

31 December 2020 

31 December 2019 

£’000 
1,045 
252 
1,297 

£’000 
(547) 
(168) 
(715) 

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

KPI 

Objective 

Total Return (Net Asset Value plus 
cumulative  dividends  paid)  per 
share for both share classes 

To  provide  shareholders  with  an  attractive  income  and  capital  return  by 
investing its funds in a portfolio of both unquoted and AIM/AQSE quoted UK 
companies which meet the relevant criteria under the VCT rules. 

the 
total  expenses  of 
The 
Company  as  a  proportion  of 
shareholders’ funds 

To maintain efficient operation of the VCT whilst minimising running costs. 

The Total Return for the Ordinary shares and B shares is included in the Financial Summary on page 1 and 
the change in the Total Return is explained in the Chairman’s Statement on pages 8 to 9. The Total Return for 
each share class increased during the year with the B share Total Return increasing 1.8% to 97.8p and the 
Ordinary share Total Return increasing 15.5% to 95.5p.  

The increase in the Ordinary share Total Return is principally as a result of the increase in the share prices of 
the Ordinary share pool’s AIM quoted investee companies and the subsequent realisations of these AIM quoted 
investments during the year as detailed in the Investment Manager’s report on page 28.  

Whilst the NAV per Ordinary share decreased by 0.2p from 30.4p to 30.2p during the year, this was after the 
payment of dividends per Ordinary share totalling 13.0p. A better understating of the underlying performance 
of  the  Company’s  Ordinary  share  portfolio  during  the  year  is  therefore  provided  by  considering  the  NAV 
movement per Ordinary share during the year before dividends which shows an increase of 12.8p (a 42% 
increase compared to 31 December 2019).       

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The increase in the B share Total Return in 2020 amounted to 1.7p which was principally due to the increase 
in  the  share  prices  of  the  B  share  pool’s  AIM  quoted  investee  companies,  the  subsequent  full  and  partial 
realisations of these AIM quoted investments during the year, offset by the impact of the Company’s running 
costs on the B share pool and a reduction in the fair value of one of the B share pool’s seven unquoted company 
investments as a result of the impact of C-19. Whist the overall NAV dropped by 1.3p, this was more than 
explained by the dividends of 3.0p per B share, paid in the period. 

The Company has also invested £1.36 million into six new companies during the period in the B share pool 
and has also made four realisations as detailed in the Chairman’s Statement on pages 8 to 9 (as well as one 
further investment from the Ordinary share portfolio being dissolved, that had previously been fully provided 
for). The new investments made are in line with the Company’s expectations for deploying capital raised and 
indicative of the healthy pipeline of growth capital investment opportunities. The disposals are also in keeping 
with the Company’s strategy on realising investments at an appropriate time.  

We have also achieved dividend payments for both share classes.  

•  An interim capital dividend of 8 pence per Ordinary share for the year to 31 December 2020 was paid on 
23  August  2020.  A  further  interim  capital  dividend  of  5  pence  per  Ordinary  share  for  the  year  to  31 
December 2020 was paid on 30 October 2020.  

•  An interim dividend of 1.5 pence per B share for the year to 31 December 2020 was paid on 15 May 2020. 
A second interim dividend of 1.5 pence per B share for the year to 31 December 2020 was paid on 24 
December 2020. 

The  Company  was  able  to  maintain  efficient  operation  of  the  VCT  whilst  minimising  running  costs  as  a 
proportion  of  shareholder’s  funds.  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 
£86,000 in the year to 31 December 2020 (2019: a reduction of £75,000) to keep expenses in line with this 
cap.  

Viability Statement 

In accordance with provision 30 and 31  of The UK Corporate Governance Code 2018, 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.  

In addition to the above, the Company is also facing risks resulting from the impact of the C-19 pandemic. The 
Company’s Board and Investment Manager are focused on ensuring that investee companies are taking the 
required actions to minimise the potential impact that the C-19 pandemic could have on them. The Board and 
Seneca will continue to review risks posed by C-19 and keep those risks under regular review.  

The  Board  has  also  considered  the  Company’s  cash  flow  projections  and  found  these  to  be  realistic  and 
reasonable. The assets of the Company consist mainly of securities, four of which are AIM quoted, relatively 
liquid and readily accessible, as well as more than £5 million of cash as at 31 December 2020 (47% of net 

38 

 
 
 
 
 
 
 
 
 
 
 
assets).  Since  31  December  2020,  an  additional  unquoted  investment  has  been  made  of  £500k,  but  the 
Company  has  also  realised  a  further  £914k  from  these  AIM  quoted  investments,  further  strengthening  the 
Company’s liquidity. 

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 2023. 

Principal risks, risk management and regulatory environment  

The  Board  carries  out  a  regular  review  of  the  risk  environment  in  which  the  Company  operates,  including 
principal and emerging risks. 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 
Chapter  3  of  Part  6  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.  

Funds  raised  by  VCTs  are  first  included  in  the  investment  tests  from  the  start  of  the  accounting  period 
containing the third anniversary of the date on which the funds were raised. The value used in the qualifying 
tests is not necessarily the original investment cost due to the complex rules required by HMRC, therefore the 
allocation of Qualifying Investments as defined by the legislation can be different to the portfolio weighting as 
measured by market value relative to the net assets of the VCT. 

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

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

securities. 

•  The Company has not retained more than 15% of its income from shares and securities. 
•  At least 80% 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. By virtue of a disregard of disposal proceeds, of which there have been £1.1m 
of relevant share sales (exit proceeds that occurred in the prevailing 12-month period are deducted 
from the total investments balance), as at the end of December 2020 the percentage is 100% in respect 
of the 80% Qualifying Holdings test. Note, these exit proceeds are only deducted to the point that the 
test reaches 100% but without these the Company was still well above the 80% qualifying requirement. 
•  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). 

•  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. This was the first year of 
this new test, and as at 31 December 2020, 39% of funds raised in the year to 31 December 2019 had 
been invested in qualifying investments. 

39 

 
 
 
 
 
 
 
 
•  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. 

•  The  Company’s  ordinary  capital  has  throughout  the  period  been  listed  on  a  regulated  European 

market. 

•  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  and  the  Investment  Manager  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 policies, 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 50. 

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

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
Gender and Diversity 

The Board consists of four Directors comprising three Independent Directors, two of whom were appointed 
prior to the appointment of Seneca, with a further Independent Director appointed in December 2019. The 
fourth Director is the CEO of Seneca. The Board considers diversity when reviewing Board composition and 
has made a commitment to consider diversity when making future appointments. The Board will always appoint 
the best person for the job. It will not discriminate on the grounds of gender, race, ethnicity, religion, sexual 
orientation,  age  or  physical  ability.  However,  the  Board  fully  supports  the  aims  of  the  Hampton  Alexander 
Report and the renewed focus and emphasis on diversity in the AIC Code of Corporate Governance (the “2019 
AIC Code”) and in due course will strive to comply with these recommendations. 

41 

 
 
 
 
 
 
 
 
Details of Directors 

John Hustler (Non-Executive Chairman)  
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 been a Director of the Company since inception and has extensive historic knowledge of the Ordinary 
share pool investments and the recent development of the Company’s B share pool. His knowledge remains 
highly relevant to the ongoing success of the Company.  

John has a beneficial interest in Scancell.  

Richard Roth (Non-Executive Director and Chairman of the Audit Committee) 
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.  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 been a VCT investor for 20 years 
and  this,  combined  with  his  multiple  VCT  directorships,  provides  the  Company  with  valuable  and  detailed 
knowledge regarding the successful ongoing operation of a VCT. 

Richard has a beneficial interest in Scancell, and Fuel3D. 

Richard Manley (Non-Executive Director) 
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 2020. 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. As CEO of the Investment Manager, Richard is well placed to 
provide the Company with timely and accurate updates in relation to the development of the B share portfolio, 
ongoing fundraise progress, upcoming investments and the continuing administration of the Company. 

Alex Clarkson (Non-Executive Director) 
Alex  is  a  Managing  Director  of  Bamburgh  Capital.  He  qualified  as  a  chartered  accountant  with 
PricewaterhouseCoopers in 1998, joined Brewin Dolphin Securities in 2000 before becoming co-founder of 
Zeus Capital in 2003. Alex then went on to co-found Bamburgh Capital in 2011, executing a large number of 
transactions acting on both the “buy” and “sell” side and raising funding. During this time, Alex was co-founder 
of Compass BioScience Group Limited and Collbio, two acquisitive companies, and became interim CFO of 
Collbio which undertook an IPO on the London Stock Market within an 18-month period, changing its name to 
Collagen Solutions. Given Alex’s experience of public markets and growth capital investing, his expertise and 
knowledge are highly relevant to the ongoing success of the Company. 

Alex has a beneficial interest in Scancell.  

42 

 
 
 
 
 
 
 
 
 
Directors’ Report 

The Directors present their Report and the audited Financial Statements for the year ended 31 December 
2020. 

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

Review of Business Activities 

The  Directors  are  required  by  section  417  of  the  Companies  Act  2006  to  include  a  Business  Review  to 
shareholders. This is set out on page 36 and forms part of the Strategic Report. The purpose of the Business 
Review is to inform members of the Company and help them assess how the Directors have performed their 
duty  under  section  172  of  the  Companies  Act  2006  (duty  to  promote  the  success  of  the  Company).  The 
Company’s section 172 Statement on page 6, the Chairman's Statement on page 8 to 13, and the Investment 
Manager’s Report on pages 14 to 35 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 are shown in 
the table below: 

John Hustler  
Alex Clarkson 
Richard Manley 
Richard Roth  

31 December 2020 
Number of Shares 
190,000 
- 
- 
209,612 

31 December 2019 
Number of Shares 
190,000 
- 
- 
209,612 

All of the Directors’ shares were held beneficially. There have been no changes in the Directors’ Ordinary share 
interests between 31 December 2020 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  
Alex Clarkson 
Richard Manley 
Richard Roth  

31 December 2020 
Number of Shares 
- 
- 
62,071 
15,000 

31 December 2019 
Number of Shares 
- 
- 
51,010 
15,000 

All of the Directors’ B shares were held beneficially. There have been no changes in the Directors’ B share 
interests between 31 December 2020 and the date of this report. 

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Directors’ and Officers’ Liability Insurance 

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

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 

Seneca as the Company’s Investment Manager is 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 current Board of Directors who served immediately prior to 23 August 2018, 
namely John Hustler and Richard Roth. 

The strategies and policies which govern the Investment Manager have been set by the Board in accordance 
with section 172 of the Companies Act 2006. 

Corporate Governance Statement 

The  Board  has  considered  the  principles  and  recommendations  of  the  2019  AIC  Code.  The  Company’s 
Corporate Governance policy is set out on pages 50 to 54.  

The 2019 AIC Code is available on the AIC website (www.theaic.co.uk). It includes an explanation of how the 
2019 AIC Code adapts the Principles and Provisions set out in the UK Corporate Governance Code (the “UK 
Code”) to make them relevant for investment companies.  

The Company has complied with the recommendations of the 2019 AIC Code and the relevant provisions of 
the UK Corporate Governance Code, except as set out below: 

•  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.  

•  New Directors do not receive a formal induction on joining the Board, though they do receive one 

tailored to them on an individual basis.  

•  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.  

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

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
run by the Board and managed by the Investment Manager. 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.  

Directors 

Biographical details of the Directors are shown on page 42.  

In  accordance  with  the  Articles  of  Association  and  good  governance,  all  four  Directors  will  retire  and  offer 
themselves for re-election at the forthcoming AGM.  

The Board is satisfied that, following individual performance appraisals, the Directors 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.  Further  details  regarding  the  Company’s  succession  planning  are  set  out  in  the 
Corporate Governance policy on pages 51 to 52. 

The  Board  did  not  identify  any  conflicts  of  interest  between  the  Chairman’s  interest  and  those  of  the 
shareholders, especially with regard to the relationship between the Chairman and the Investment Manager.  

No concerns about the operation of the Board or the Company were raised by any Director during the period 
and had any been raised they would be mentioned in the minutes or in writing to the Chairman to be circulated 
to the Board in accordance with Provision 5.2 of the 2019 AIC Code. 

The Board is cognisant of shareholders’ preference for Directors not to sit on the boards of too many listed 
companies  (“over-boarding”).  The  Board  is  satisfied  that  all  Directors  have  the  time  to  focus  on  the 
requirements of the Company. 

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 (“IFRS”). The Company does not anticipate that it will voluntarily adopt IFRS. The Company has 
adopted  Financial  Reporting  Standard  102  –  The  Financial  Reporting  Standard  Applicable  in  the  United 
Kingdom and the Republic of Ireland. 

Environmental, Social and Governance (“ESG”) Practices 

The Board recognises the requirement under section 414c of the Companies Act 2006 to detail information 
about environmental matters (including the impact of the Company’s business on the environment), employee 
and human rights, social and community issues, including information about any policies it has in relation to 
these matters and effectiveness of these policies.  

Given the size and nature of the Company’s activities and the fact that it has no employees and only four non-
executive Directors, the Board considers there is limited scope to develop and implement environmental, social 
and  community  policies,  but  recognises  the  importance  of  including  consideration  for  such  matters  in 
investment decisions. The Board has taken into account the requirement of section 172(1) of the Companies 
Act  2006  and  the  importance  of  ESG  matters  when  making  decisions  which  could  impact  shareholders, 
stakeholders and the wider community. The Company’s Section 172(1) statement has been provided in the 
Strategic Report on page 6, where the Directors consider the information to be of strategic importance to the 
Company. 

45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  Company  seeks  to  ensure  that  its  business  is  conducted  in  a  manner  that  is  responsible  to  the 
environment. The management and administration of the Company is undertaken by the Investment Manager 
who recognises the importance of its environmental responsibilities, monitors its impact on the environment 
and  implements  policies  to  reduce  any  negative  environmental  impact  and  which  promote  environmental 
sustainability.  

The  Investment  Manager  recognises  that  managing  investments  on  behalf  of  clients  involves  taking  into 
account a wide set of responsibilities in addition to seeking to maximise financial returns for investors. Industry 
practice in this area has been evolving rapidly and the Company seeks to be an active participant by working 
to define and strengthen its principles accordingly. This involves both integrating ESG considerations into the 
Investment Manager’s investment decision-making process as a matter of course, and also signing up to major 
external bodies who are leading influencers in the formation of industry best practice. The following is an outline 
of the kinds of ESG considerations that the Investment Manager is taking into account as part of its investment 
process.  

Environmental  
Seneca, as part of its commercial due diligence practices and ongoing monitoring, examines potential issues 
which could arise from supply chains, climate change and environmental policy compliance. The Investment 
Manager looks for management teams who are aware of the issues and are proactive in responding to them.  

Social 
Seneca seeks to avoid unequivocal social negatives, such as profiting from forced labour within its investment 
portfolio  and  to  support  positive  impacts  which  will  more  likely  find  support  from  customers  and  see  rising 
demand. Seneca does not tolerate modern slavery or human trafficking within its business operations and 
takes  a  risk-based  approach  in  respect  of  our  portfolio  companies.  Seneca  actively  engages  with  portfolio 
companies  and  their  boards  to  discuss  material  risks,  ranging  from  business  and  operational  risks  to 
environmental and social risks.  

Governance  
Seneca  examines  and,  where  appropriate,  engages  with  companies  on  board  membership,  remuneration, 
conflicts of interest such as related party transactions, and business leadership and culture. In addition, the 
Company, as a matter of course, exercises its voting rights when possible.  

Greenhouse  Gas  (“GHG”)  Emissions  and  Streamlined  Energy  &  Carbon 
Reporting (“SECR”) 

Under  the  Companies  Act  2006  (Strategic  Report  and  Directors’  Report)  Regulations  2013  (‘the  2013 
Regulations’) and the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon 
Report) Regulations 2018, quoted companies of any size are required under Part 15 of the Companies Act 
2006 to disclose information relating to their energy use and GHG emissions.  

All of the Company’s activities are outsourced to third parties. The Company therefore has no greenhouse gas 
emissions to report from its operations, nor does it have direct responsibility for any other emissions producing 
sources under the Companies Act 2006 (Strategic Report and Directors’ Reports) Regulations 2013 and the 
Companies  (Directors’  Report)  and  Limited  Liability  Partnerships  (Energy  and  Carbon  Report)  Regulations 
2018. For the same reasons as set out above, the Company considers itself to be a low energy user under the 
SECR regulations and therefore is not required to disclose energy and carbon information. A low energy user is 
defined as an organisation that uses 40 MWh or less during the reporting period.  

46 

 
 
 
 
 
 
 
 
 
 
 
Going Concern 

The Company’s business activities and the factors likely to affect its future performance and financial position 
are set out in the Chairman’s Statement and Investment Manager’s Report on pages 8 to 13 and pages 14 to 
35. Further details on the management of the principal risks are set out on pages 39 to 40 and financial risks 
may be found in note 16 to the Financial Statements. 

The  Board  receives  regular  reports  from  Seneca  who  acts  as  both  the  Investment  Manager  and  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. 

The  assets  of  the  Company  consist  mainly  of  securities,  four  of  which  are  AIM  quoted,  relatively  liquid 
and readily accessible, as well as more than £5 million of cash as at 31 December 2020 (47% of net assets). 
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. 

The Company is also facing risks resulting from the impact of the C-19 pandemic. The Company’s Board and 
Investment  Manager  are  focused  on  ensuring  that  investee  companies  are  taking  the  required  actions  to 
minimise the potential impact that the C-19 pandemic could have on them. The Board and Seneca will continue 
to review risks posed by C-19 and keep those risks under regular review but do not consider the pandemic to 
have any impact on the Company’s own ability to continue as a going concern.  

Share Capital  

As disclosed on page 99 the Board has authority to make market purchases of the Company’s own B shares. 
No shares were purchased by the Company during the year (2019: nil). 

At the last AGM held on 28 April 2020, the Board received authority to allot up to 35,000,000 B shares in 
connection with any offer(s) for subscription (and any subsequent top up offer of B shares) and up to 405,800 
Ordinary shares (for any miscellaneous offers of such shares), which represented approximately 479% of the 
Company’s issued B share capital and approximately 5% of its issued Ordinary share capital as at 28 April 
2020.  

During the year, the Company did not issue any Ordinary shares (2019: nil). During the year, the Company 
issued 2,701,500 B shares raising £2.4 million before expenses (2019: 2,325,078 shares and £2.3 million) No 
further shares have been issued between 31 December 2020 and the date of this report.  

The Company’s issued Ordinary share capital as at 31 December 2020 was 8,115,376 Ordinary shares of 1p 
each (31 December 2019: 8,115,376 Ordinary shares of 1p each) and 9,062,948 B shares of 1p each (31 
December 2019: 6,361,448 B shares of 1p each).  

The total number of shares in issue for both the Ordinary shares and B shares of 1p each as at 31 December 
2020 and 19 February 2021 was 17,178,324 (31 December 2019: 14,476,824) with each share having one 
vote. 

In accordance with Schedule 7 of the Large and Medium Size Companies and Groups (Accounts and Reports) 
Regulations 2008, as amended, the Directors disclose the following information: 

47 

 
 
 
 
 
 
 
 
 
 
•  The Company’s capital structure and voting rights are summarised above, and there are no restrictions 
on  voting  rights  nor  any  agreement  between  holders  of  securities  that  result  in  restrictions  on  the 
transfer of securities or on voting rights; 

•  There exist no securities carrying special rights with regard to the control of the Company; 
•  The  rules  concerning  the  appointment  and  replacement  of  directors,  amendment  of  the  Articles  of 
Association and powers to issue or buy back of the Company’s shares are contained in the Articles of 
Association of the Company and the Companies Act 2006; 
•  The Company does not have an employee share scheme; 
•  There are no agreements to which the Company is party that may affect its control following a takeover 

bid; and 

•  There are no agreements between the Company and its Directors providing for compensation for loss 
of office that may occur following a takeover bid or for any other reason, apart from their normal notice 
period and any fees potentially due under the performance fee arrangements set out on page 58 and 
note 6. 

Substantial Shareholdings 

At 31 December 2020 and at the date of this report, there was one holding of 3% and over of the Company’s 
ordinary share capital. This holding related to Share Nominees Ltd and amounted to 3.34%. 

Annual General Meeting 

The Notice convening the 2021 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: 

Resolutions  3  to  6  will  seek  the  re-election  of  the  existing  four  members  of  the  Board  as  non-executive 
Directors of the Company. 

Resolution 7 will seek the re-appointment of UHY Hacker Young LLP as Independent Auditor to the Company.  

Resolution 8 will seek authorisation to determine the auditor’s remuneration. 

Resolution 9 will authorise the Directors to allot further B shares and Ordinary shares. This will enable the 
Directors until the next AGM to allot up to 35,000,000 B shares in connection with any offer(s) for subscription 
(and any subsequent top up offer of B shares) and up to 405,800 Ordinary shares (for any miscellaneous offers 
of such shares), representing approximately 386% of the Company’s issued B share capital and approximately 
5% of its issued Ordinary share capital as at 19 February 2021.  

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 share capital of the Company from time to time. The price paid must not be less than 
1p per B share, nor more than 5% above the average middle market price of a B share for the preceding five 
business days. Any B shares bought back under this authority may be cancelled by the Board.  

Resolution 11 will, under sections 570 of the Act, disapply pre-emption rights in respect of any allotment of 
the B shares and/or Ordinary shares authorised under Resolution 9.  

Resolution 12 will adopt amended Articles of Association which are substantially in the same form as the 
Company’s current Articles of Association save that:  

48 

 
 
 
 
 
 
 
 
 
 
 
 
(i) 

(ii) 

(iii) 

existing Clause 146 regarding Unclaimed Dividends has been deleted and replaced with a 
new  Clause  146  which  provides  the  authorisation  for  all  dividends,  interest  or  other  sum 
payable  and  unclaimed  for  12  months  after  having  become  payable  to  be  invested  or 
otherwise made use of by the Board for the benefit of the Company until claimed and the 
Company shall not be constituted a trustee in respect thereof. All dividends unclaimed for a 
period of six years after having been declared or become due for payment shall (if the Board 
so resolves) be forfeited and shall cease to remain owing by the Company; and 

existing Clauses 53 to 56 (including the insertion of new Clauses 55A and 56A) have been 
amended to include the ability for the Company to hold partially virtual general meetings. 

Existing  Clause  102  will  be  amended  to  authorise  an  increase  in  the  total  remuneration 
payable  to  the  Directors  to  £100,000  to  allow  for  the  appointment  of  a  new  non-executive 
Director. 

The Directors intend to use the authorities in Resolutions 9 and 11 for the purposes of the current Offer and a 
further  offer  for  subscription  of  B  shares.  The  Directors  have  no  current  intention  to  utilise  the  authority  in 
relation to the Ordinary shares. 

Copies of the Articles of Association of the Company (including a mark-up of the new articles of association 
proposed to be adopted pursuant to resolution 12) 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. However, given that shareholders will be unable to attend 
the  AGM  this  year,  the  Articles  of  Association  will  also  be  available  on  the  Company’s  website  at 
https://senecavct.co.uk/reports-documents/.  

Recommendation 

The Board believes that the passing of the resolutions above are in the best interests of the Company and its 
shareholders as a whole and unanimously recommends that you vote in favour of these resolutions as the 
Directors intend to do in respect of their beneficial shareholdings. 

By Order of the Board 

Craig Hunter 
Company Secretary 
22 February 2021 

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate Governance  

The Board has considered the principles and recommendations of the 2019 AIC Code.  

The 2019 AIC Code addresses the Principles and Provisions set out in the UK Code, as well as setting out 
additional Provisions on issues that are of specific relevance to Seneca Growth Capital. 

The Board considers that reporting against the Principles and Provisions of the 2019 AIC Code, which has 
been endorsed by the Financial Reporting Council (and associated disclosure requirements under paragraph 
9.8.6 of the Listing Rules) provides more relevant information to shareholders. 

The Company is committed to maintaining high standards in corporate governance and has complied with the 
Principles and Provisions of the 2019 AIC Code, except as set out below. The Company strongly believes that 
achieving  its  corporate  governance  objectives  contributes  to  the  long-term  sustainable  success  of  the 
Company.  

The 2019 AIC Code is available on the AIC website (www.theaic.co.uk). It includes an explanation of how the 
2019  AIC  Code  adapts  the  Principles  and  Provisions  set  out  in  the  UK  Code  to  make  them  relevant  for 
investment companies.  

Board of Directors 

The Company has a Board of four non-executive Directors, details of each can be found on page 42. 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 3. 

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; 
the consideration and review of the Company’s compliance with HMRC conditions for maintenance of 
approved VCT status as advised by Philip Hare & Associates LLP; 

●  consideration of corporate strategy; 
●  approval of the appropriate dividend to be paid to shareholders; 
● 

the appointment, evaluation, removal and remuneration of the Investment Manager, who also acts as 
the Administration Manager; 
the performance of the Company, including monitoring 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 in accordance with 
the Board’s duty to promote the success of the Company.  

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. 

50 

 
 
 
 
 
 
 
 
 
 
 
 
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.  

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

John Hustler 
Alex Clarkson 
Richard Manley 
Richard Roth  

Board meetings attended 
(9 held in year) 
9 
9 
9 
9 

Audit Committee meetings attended 
(2 held in year) 
2 
2 
2 
2 

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

Independence of Directors 

The Board regularly reviews the independence of its members and is satisfied that the Company’s Directors 
are independent in character and judgment and that there are no relationships or circumstances which could 
affect their objectivity (with the exception of Richard Manley who is the CEO of the Investment Manager).  

The 2019 AIC Code recommends that where a Director has served for more than nine years, the Board should 
state its reasons for believing that the individual remains independent. The Board is of the view that a term of 
service in excess of nine years is not in itself prejudicial to a Director’s ability to carry out his or her duties 
effectively and from an independent perspective; the nature of the Company’s business is such that individual 
Directors’ experience and continuity of Board membership can significantly enhance the effectiveness of the 
Board as a whole. However, the Board has applied the provision that all Directors are to seek annual re-election 
and has determined a policy of tenure for the Chairman and believe that both are essential in balancing the 
business of the Company whilst providing opportunity for regular refreshment and increasing the diversity of 
the Board.  

Directors are appointed with the expectation that they will serve for a period of at least three years and all 
Directors will retire at the first general meeting after election and will be subject to annual re-election thereafter 
in  line  with  practices  recommended  in  the  2019  AIC  Code.  It  is  the  Company’s  policy  of  tenure  to  review 
individual appointments every year, with increased scrutiny after nine years of service to consider whether the 
Director is still independent and still fulfils the role. However, in accordance with the principles of the 2019 AIC 
Code,  we  do  not  consider  it  necessary  to  mandatorily  replace  a  Director,  including  the  Chairman,  after  a 
predetermined period of tenure. A more flexible approach to Chairman tenure will help the Company manage 
succession  planning  in  the  context  of  the  business  needs  of  the  Company,  whilst  at  the  same  time  still 
addressing the need for regular refreshment and diversity. The Company’s report on Gender and Diversity is 
on page 41.  

Given that the Chairman has now served as a Director for nearly 20 years, the Board and Chairman have had 
a number of conversations  over the  last  12  months  with  regard to his ongoing tenure  and  the  process for 
identifying  his  potential  successor.  Whilst  the  Board  has  determined  that  John  Hustler,  74,  is  capable  of 
carrying  out  his  duties  effectively,  given  the  policies  outlined  above,  plans  are  now  being  made  for 
his succession. 

51 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Remuneration  in  addition  to  the  Directors’  fees  is  potentially  payable  to  those  Directors  serving  prior  to  23 
August 2018 subject to certain conditions as set out in the Directors’ Remuneration Report and Policy on pages 
58 to 59. Having regard for the historic nature and circumstances under which the performance incentive fees 
were agreed, the Board does not believe that the performance incentive fees in any way impact or hinder the 
Directors’  independence  or  present  a  conflict  of  interest  which  could  compromise  or  override  independent 
judgment of the Directors.  

Performance Evaluation  

In accordance with the 2019 AIC Code, 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 or telephone calls between 
the Chairman and each Director. The Directors were made aware of the annual performance evaluation on 
their appointment. The Board considers the size of the Company, the number of independent non-executive 
Directors  on  the  Board  and  the  robustness  of  the  reviews  to  be  such  that  an  external  Board  evaluation  is 
unnecessary. Annual evaluations of the Board consider its composition, diversity, succession planning and 
how effectively members work together to achieve objectives as well as individual contributions. 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 is evaluated by the other Directors. The Board has not appointed a 
Senior Independent Director, as it does not believe that such an appointment is necessary when the Board is 
comprised solely of non-executive Directors. As suggested in the 2019 AIC Code, this role can be, and in this 
instance is, fulfilled by the Chairman of the Audit Committee, Richard Roth. 

The Board sets out the assessment of its members and explains why its members are and continue to be of 
importance to the long-term sustainable success of the business on page 45.  

The Board reviews the performance of the Investment Manager on an ongoing basis, both formally and outside 
of Board meetings with regard to its appointment, evaluation, removal and remuneration, in both contexts of 
its role as Investment Manager and Administration Manager. The Board considers the Company’s size to be 
such that it would be unnecessarily burdensome to establish a separate management engagement committee 
to perform this role.  

Board Committees 

The Board does not have a separate remuneration committee, as the Company has no employees or executive 
directors. Detailed information relating to the remuneration of Directors is given in the Directors’ Remuneration 
Report and Policy on pages 58 to 59.  

The  Board  as  a  whole  considers  the  selection  and  appointment  of  Directors  and  reviews  Directors’ 
remuneration on an annual basis. The Board considers the Company’s size to be such that it is unnecessary 
to form a separate committee for the purposes of nomination. When making an appointment, the Board draws 
on its members’ extensive business experience and range of contacts to identify suitable candidates. To date 
the use of formal advertisements and external search consultants have not been used. However, the Board 
would consider their use as and when appropriate. The Board speaks regularly about Board composition and 
succession planning in order to identify and address any issues that may arise.  

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 Richard Roth possesses appropriate and relevant financial experience as per the requirements of the 
2019  AIC  Code.  The  Board  considers  that  the  members  of  the  Committee  have  collectively  the  skills  and 
experience required to discharge their duties effectively. 

52 

 
 
 
 
 
 
 
 
 
The Audit Committee’s terms of reference, and how it discharges its duties are listed on pages 55 to 57. 

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. The Board also monitors and evaluates external service providers and maintains 
regular  discussions  with  the  Investment  Manager  about  the  services  provided.  The  Investment  Manager 
reviews  the  service  contracts  on  an  annual  basis  and  discusses  any  recommendations  with  the  Board  as 
relevant.  

City Partnership are the custodian of the documents of title relating to the Company’s unquoted investments.  

Seneca are also the Administration Manager in addition to their role as the Investment Manager.  

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.  

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. 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,  shareholders  have  the 
opportunity  to  engage  directly  with  the  Board  as  part  of  the  regular  shareholder  update  presentations  as 
detailed in the Strategic Report on page 6 and the Board is available to answer any questions a shareholder 
may have and is happy to respond to written queries made by shareholders during the course of the year. The 
Board can be contacted at the Company’s registered office:  9 The Parks, Haydock, WA12 0JQ. 

There was no resolution proposed at the last AGM which received 20% or more of votes cast against it for the 
purposes of disclosure under Provision 4 of the UK Code.  

53 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Compliance Statement 

As previously indicated, the Board considers that reporting against the principles and recommendations of the 
2019 AIC Code will provide better information to shareholders.  

The Company has complied with the recommendations of the 2019 AIC Code and the relevant provisions of 
the UK Corporate Governance Code, except as set out below: 

•  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.  

•  New Directors do not receive a formal induction on joining the Board, though they do receive one 

tailored to them on an individual basis.  

•  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.  

•  The Company does not have a Remuneration Committee as it does not have any executive directors. 
•  The Company does not have a Nomination Committee as these matters are dealt with by the Board. 

For the reasons set out in the 2019 AIC Code, 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 run by the Board and managed by the Investment Manager. 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 
22 February 2021 

54 

 
 
 
 
 
 
 
 
 
 
 
Audit Committee Report  

This report is submitted in accordance with the 2019 AIC Code in respect of the year ended 31 December 2020 
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 51.  

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. The Committee is happy to recommend UHY Hacker 
Young LLP for reappointment at the AGM in relation to the audit for the year ending 31 December 2021. UHY 
Hacker Young LLP do not provide any non-audit services and as such, the Committee does not believe there 
is any risk that any non-audit services can influence their independence or objectivity due to any associated 
fee. When considering whether to recommend the reappointment of the external auditor the Committee takes 
into account the quality of service, 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 resulting 
discussions on topics raised. The Committee also challenges the Auditor when present at a Committee meeting 
if appropriate.  

55 

 
 
 
 
 
 
 
 
 
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.  

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 resulting impact. 

During the year ended 31 December 2020, the Audit Committee discharged its responsibilities by: 

● 
● 

● 

● 
● 

● 
● 

reviewing and approving the external auditor’s terms of engagement and remuneration;  
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 Seneca’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 pages 47 and 82; and 
reviewing the external auditor’s Report to the Audit Committee on the annual Financial Statements. 

The Committee has considered the Report and Financial Statements for the year ended 31 December 2020 
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 Seneca and the Board 
of Seneca Growth Capital. The impact of this risk could be a large movement in the Company’s net 
asset  value.  Guidelines,  discussions,  reviewing  and  challenging  the  basis  and  reasonableness  of 
assumptions  made  in  conjunction  with  available  supporting  information  goes  into  the  valuation 
process. The valuations are supported by investee company Financial Statements and/or third-party 
evidence where possible. Otherwise, valuations are supported by the share price of the most recent 
fundraising and/or management information. 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 and the Investment Manager and the Board review the advice.  

●  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 2020, and Seneca has confirmed this to the Audit Committee.  

●  Performance Fees: The Auditors give special audit consideration to the performance fees as these are 
directly linked to the NAV which is dependent upon investment valuations. The Audit Committee gives 

56 

 
 
 
 
 
 
 
 
due consideration to the valuation methodology as referenced above and maintains controls around 
performance fees to mitigate any risks to the Company’s costs.  

These  issues  were  discussed  with  Seneca,  the  Board  of  Seneca  Growth  Capital  and  the  Auditors  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 2020. 

Richard Roth 
Audit Committee Chairman 
22 February 2021 

57 

 
 
 
 
 
 
 
 
 
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 2020. A resolution to approve the Directors’ Remuneration Report will 
be proposed at the Annual General Meeting on 29 March 2021. The statement of Directors’ Remuneration 
Policy was last approved by shareholders at the Annual General Meeting on 10 June 2019. The Directors’ 
Remuneration Report was last approved at the Annual General Meeting on 28 April 2020. 

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 61 to 69. 

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 is the Company’s Investment Manager 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 remaining members of the Board of the Company serving immediately prior to the 
appointment of Seneca (the Commercial Advisory Committee or “CAC”), which now consists of John Hustler 
and Richard Roth. 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 will be subject to re-election 
on an annual basis in line with practices recommended in the 2019 AIC 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. Members of the CAC are entitled to a pro rata proportion of any performance fees payable to the 
CAC accruing at the date of resignation up to five years from the date of resignation.  

Each Director’s annual fee is currently £15,000 per annum inclusive of all expenses, with the exception of 
Richard  Roth  whose  fee  was  increased  from  £15,000  per  annum  to  £20,000  per  annum  inclusive  of  all 
expenses with effect  from 1  October 2020.  As  part  of  the  Board’s  regular  review  of  Directors’  fees,  it was 
determined that Richard Roth’s Director’s fee would increase to reflect the work performed by him in respect 
of his role as Chairman of the Audit Committee. It was also decided that Richard Roth would receive a one-off 
payment of £2,500 in respect of the work he performed as part of this role for the period prior to 1 October 
2020.  

The performance incentive fees relevant to those Directors serving up to 7 October 2015 were revised under 
an agreement dated 7 October 2015 (the “Accrued Performance Incentive Fee”). 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  14.75p  of 
dividends have been paid in respect of each Ordinary share (such that original subscribing shareholders will 

58 

 
 
 
 
 
 
 
 
 
 
have received 80p per share in dividends). As no liability is payable to any relevant Director more than five 
years after his resignation from the Company, James Otter is no longer entitled to any such fee: as explained 
in Note 6, his potential share of any liability has been extinguished and the remaining total potential liability 
under the Accrued Performance Incentive Fee has been reduced to £468,000. This liability will then be paid at 
the rate of 16.67% of subsequent dividends until a liability of £468,000 has been discharged; this is in keeping 
with the original approved arrangement. 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  members  of  the  CAC  based  on  a  formula  driven  by  relative  length  of  service  starting  from  7 
October 2015 (“Further Performance Incentive Fee”). Further details of the revised arrangements are set out 
in note 6 to the Financial Statements. 

The Company entered into an agreement with Charles Breese following his resignation on 10 June 2019 that 
he will be entitled to a pro rata proportion of performance fees as set out in note 6 to the Financial Statements.  

Company Performance  

The Board is responsible for the Company’s investment strategy and performance. The performance table on 
page 36 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 
Alex Clarkson 
Richard Manley 
Total  

Year ended 
31 December 2020 
£ 
15,000 
- 
18,750 
15,000 
- 
48,750 

Year ended 
31 December 2019 
£ 
12,897 
6,375 
12,897 
981 
- 
33,150 

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 
apart from the additional fees paid to Richard Roth as detailed above in respect to his role as Chairman of the 
Audit Committee. John Hustler 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;  however,  no  Directors 
currently perform such a role in relation to the Ordinary share pool and any fee that could be payable in relation 
to the B share pool would be payable to Seneca and would be disclosed in note 19. The Board would ensure 
that any such fee would not present a conflict of interest which could impact its independent judgment. 

By order of the Board 
Craig Hunter 
Company Secretary 
22 February 2021 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
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 
22 February 2021 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
2020, which comprise the Income Statement, the Statement of Changes in Equity, the Balance Sheet, the 
Statement of Cash Flows and the related notes to the Financial Statements, including  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”  (United  Kingdom  Generally  Accepted  Accounting 
Practice). 

In our opinion the Financial Statements: 

•  give a true and fair view of the state of the Company’s affairs as at 31 December 2020 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 going concern 
In auditing the Financial Statements, we have concluded that the Directors’ use of the going concern basis of 
accounting  in  the  preparation  of  the  financial  statement  is  appropriate.  Our  evaluation  of  the  Directors’ 
assessment of the entity’s ability to continue to adopt the going concern basis of accounting included: 

Evaluation of management assessment 

Key observations 

We evaluated the Directors’ going concern assessment 
and performed the following procedures: 

At 31 December 2020, the Company held cash of 
£5,056,000 at bank. 

•  We assessed the appropriateness of the cash 
flow forecasts in the context of the Company’s 
2020 financial performance and evaluated the 
Directors’  sensitivities  performed  against  this 
forecast. 

•  We  evaluated  the  key  assumptions  in  the 
forecast,  which  were  consistent  with  our 
knowledge  of  the  business  and  considered 

The  Company’s  cash  flow  forecasts  to  1  March 
2022  (‘the  going  concern  period’)  have  been 
approved  by  the  Board.  These  are  prepared 
based on certain key assumptions, against which 
plausible sensitivities have been applied. These 
included  considering  further  investments  being 
made,  no  further  shares  to  be  issued  and  no 
further  investments  to  be  realised  over  the 
forecast period. 

61 

 
 
 
 
 
 
 
 
 
 
 
 
The forecast shows that the Company has at all 
times available cash and liquidity to meets its 
liabilities as they fall due. 

Based  on  the  audit  procedures  performed  we 
concluded  that  the  Company  has  appropriately 
adopted the going concern basis of preparation. 
Further,  we  did  not 
identify  any  material 
disclosures that should be included regarding any 
material  uncertainty  in  respect  of  the  going 
concern basis of preparation.    

whether these were supported by the evidence 
we obtained. 

•  We  compared  the  prior  year  forecast  against 
current  year  actual  performance  to  assess 
management’s  ability  to  forecast  accurately. 
We factored in to our assessment the previous 
expectation  of 
raise 
expectations  in  light  of  C-19  and  accordingly 
the investments made in 2020. 

the  B  share 

fund 

•  We  examined  and  confirmed  the  Directors’ 
assessment  of  the  liquidity  of  the  AIM  listed 
shares. 

•  We  also  reviewed  the  disclosures  relating  to 
going concern basis of preparation and found 
that  these  provided  an  explanation  of  the 
Directors’ assessment that was consistent with 
the evidence we obtained. 

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

In relation to the Company reporting on how they have applied the AIC Code of Corporate Governance (the 
“2019 AIC Code”), we have nothing material to add or draw attention to in relation to the Directors’ statement 
in the Financial Statements about whether the Directors considered it appropriate to adopt the going concern 
basis of accounting. 

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

Our approach to the 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 enough work to be able to give an opinion on 
the Financial Statements as a whole, taking into account an understanding of the structure of the Company, 
their 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. 

The  audit  team  met  and  communicated  regularly  throughout  the  audit  with  the  Audit  Committee  and  the 
Investment Manager in order to ensure we had a good knowledge of the business of the Company. During the 
audit, we reassessed and re-evaluated audit risks and tailored our approach accordingly. 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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. This is not a complete 
list of all risks identified during our audit. Going concern is a significant key audit matter and is described above. 
In arriving at our audit opinion above, the other key audit matters were as follows: 

Key risks 
Valuation  of  Investments  and  recognition  of 
realised 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.  Due 
to the nature of the Company’s business, there is 
an  inherent  risk  that  if  incorrectly  valued  this  will 
have  the  greatest  impact  on  both  the  Income 
Statement and Balance Sheet. 

The  investment  portfolio  at  the  year-end  had  a 
carrying value of £6,123,584. 

Approach taken for the assessed risks 
Our audit work included, but was not restricted to: 

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

•  The  unquoted 

investment  valuations 
include  significant  assumptions  and 
judgement  by  management  and  there  is 
inherent estimation uncertainty. 

We obtained an understanding of how the 
valuations  were  performed  considered 
in 
whether 
accordance  with  published  guidance  and 
reviewed and challenged the assumptions 
applied to the valuation inputs.  

the  method  chosen  was 

We  verified  and  benchmarked  key  inputs 
and estimates to independent information 
from our own research and against metrics 
from the investments. 

Where  appropriate,  we  have  performed 
the  valuation 
sensitivity  analysis  on 
calculations.  

Alternative  valuations  methods  were 
with 
considered 

discussed 

and 

63 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
management  to  provide  alternative  views 
on the value of the investments.  

Further, we also considered the economic 
environment  in  which  the  investments 
operate  in  to  identify  factors  that  could 
impact the investment valuation.  

•  We  agreed  the  purchase  and  sale  of 
investments to supporting evidence of the 
transaction  and  cash  movements  on  a 
sample basis and recalculated the realised 
the  sale  of 
losses  on 
gains  and 
investments 
individual 
the 
for  both 
transactions on a sample basis and for the 
total portfolio.  

•  Checking  the  movement  in  unrealised 
gains and losses for arithmetical accuracy 
and  validated  by  reviewing  the  opening 
costs to prior year balances on a sample 
basis. 

The  Company's  accounting  policy  on  fixed  asset 
investments held at fair value through profit or loss 
is shown on page 83 to the Financial Statements 
and related disclosures are included in note 10.  

testing  did  not 

Key observations 
Our 
identify  any  material 
misstatements  in  the  valuation  of  the  Company’s 
investment portfolio as at the year end. 

Compliance with the VCT rules 

Our audit work included, but was not restricted to:  

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

We 

obtained 

•  Review of the design and implementation 
of  controls  around  the  ongoing  internal 
assessment  and  monitoring  of  VCT 
compliance. 
an 
understanding  of  the  processes  adopted 
and evidenced the  work completed by the 
Investment  Manager  on  documenting  
compliance  with  the  key  VCT  rules  and 
management’s review of this on a regular 
basis. Further, an external VCT Adviser is 
to  complete  a  six  monthly 
employed 
assessment of the Company’s compliance 
with  the  VCT  Rules  that  is  reviewed  by 
management,  copies  of  which  we 
reviewed.  

64 

 
 
 
 
 
 
 
 
  
 
 
•  Testing 

conditions 

the  eleven 

for 
maintaining approval as a VCT as set out 
by  HMRC.  Each  of  the  conditions  was 
reviewed in turn in order to assess whether 
it had been met as at the year-end. 

Key observations 
We  reviewed  the  documentation  maintained,  that 
confirmed the Company was in compliance with the 
VCT rules during the period and at the year end. 
Further  our  own  testing  of  compliance  with  the 
individual VCT rules did not identify any breaches. 

Our application of materiality 
The scope and focus of our audit was influenced by our assessment and application of materiality. We apply 
the  concept  of  materiality  both  in  planning  and  performing  our  audit,  and  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 omissions, could 
reasonably be expected to influence the economic decisions taken on the basis of the Financial Statements 
by reasonable users.  

In order to reduce to an appropriately low level the probability that any misstatements exceed materiality, we 
use a lower materiality level, performance materiality, to determine the extent of testing needed. Importantly, 
misstatements below these levels will not necessarily be evaluated as immaterial as we also take account of 
the nature of identified misstatements, and the particular circumstances of their occurrence, when evaluating 
their effect on the Financial Statements as a whole. 

Materiality Measure 

Company 

Overall materiality 

We determined materiality for the Financial Statements 
as a whole to be £223,000. 

How we determine it 

Based on a benchmark of 2% of gross assets. 

Rationale for benchmarks applied 

Performance materiality 

We  believe  2%  of  gross  assets  to  be  the  most 
appropriate  benchmark,  as  it  primarily  comprises  the 
Company’s investment portfolio, which is considered to 
be  the  key  driver  of  the  Company’s  total  return 
performance  and  forms  part  of  the  net  asset  value 
calculation  being  the  performance  measure  investors 
use to assess the Company’s performance.   

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, and 
was set at £167,250. 

65 

 
 
 
 
 
 
 
 
 
 
 
 
Specific materiality   

Reporting threshold 

We also determine a lower level of specific materiality 
for certain areas such as Director’s remuneration. Area 
materiality  for  the  disclosure  of  the  cash  element  of 
Director’s  remuneration  has  been  set  at  £2,000  and 
performance materiality of £1,000.  

We  agreed  with  the  Audit  Committee  that  we  would 
report to them all misstatements over £11,150 (5% of 
overall materiality) identified during the audit, as well as 
differences  below  that  threshold  that,  in  our  view, 
warrant  reporting  on  qualitative  grounds.    We  also 
report  to  the  Audit  Committee  on  disclosure  matters 
the  overall 
identified  when  assessing 
that  we 
presentation of the Financial Statements. 

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

Our responsibility is to read the other information and, in doing so, consider whether the other information is 
materially inconsistent with the Financial Statements or our knowledge obtained in the course of 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 this gives rise to a material misstatement in the Financial 
Statements themselves.   

If, based on the  work we have  performed,  we  conclude  that  there  is  a  material  misstatement of this  other 
information; we are required to report that fact.  

We have nothing to report in this regard. 

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

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

• 

• 

the information given in the Strategic Report and the Directors’ Report for the financial year for which 
the Company’s 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. 

66 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

• 

received 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. 

Corporate Governance Statement 
The Listing Rules require us to review the Directors’ statement in relation to going concern, longer-term viability 
and that part of the Corporate Governance Statement relating to the Company’s compliance with the provisions 
of the UK Corporate Governance Statement specified for our review.   

Based on the work undertaken as part of our audit, we have concluded that each of the following elements of 
the Corporate Governance Statement is materially consistent with the Financial Statements or our knowledge 
obtained during the audit: 

•  Directors’  statement  with  regards  the  appropriateness  of  adopting  the  going  concern  basis  of 

accounting and any material uncertainties identified set out on page 47; 

•  Directors’  explanation  as  to  their  assessment  of  the  Company’s  prospects,  the  period  this 

assessment covers and why the period is appropriate set out on page 38;  
•  Directors’ statement on fair, balanced and understandable set out on page 43; 
•  Board’s confirmation that it has carried out a robust assessment of the emerging and principal risks 

set out on page 39;  

•  The section of the Annual Report that describes the review of effectiveness of risk management and 

internal control systems set out on page 53; and  

•  The section describing the work of the Audit Committee set out on page 55 to 57.   

Responsibilities of Directors 
As  explained  more  fully  in  the  Directors’  Responsibilities  Statement  set  out  on  page  60,  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 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. 

67 

 
 
 
 
 
 
 
 
 
Irregularities,  including  fraud,  are  instances  of  non-compliance  with  laws  and  regulations.    We  design 
procedures  in  line  with  our  responsibilities,  outlined  above,  to  detect  material  misstatements  in  respect  of 
irregularities,  including  fraud.    The  extent  to  which  our  procedures  are  capable  of  detecting  irregularities, 
including fraud is detailed below: 

Based  on  our  understanding  of  the  Company  and  the  industry  in  which  it  operates,  we  identified  that  the 
principal risks of non-compliance with laws and regulations related to the acts by the Company which were 
contrary  to  applicable  laws  and  regulations  including  fraud  and  we  considered  the  extent  to  which  non-
compliance might have a material effect on the Financial Statements. We also considered those laws and 
regulations that have a direct impact on the preparation of the Financial Statements such as the Companies 
Act  2006.  We  evaluated  management’s  incentives  and  opportunities  for  fraudulent  manipulation  of  the 
Financial Statements (including the risk of override of controls), and determined that the principal risks were 
related to inflated investment valuations and profit. 

Audit procedures performed included: review of the Financial Statement disclosures to underlying supporting 
documentation, review of correspondence with legal advisors, and enquiries of management in so far as they 
related to the Financial Statements, and testing of journals and evaluating whether there was evidence of bias 
by the Directors that represented a risk of material misstatement due to fraud.  

There  are  inherent  limitations  in  the  audit  procedures  described  above  and  the  further  removed  non-
compliance with laws and regulations is from the events and transactions reflected in the Financial Statements, 
the less likely we would become aware of it. Also, the risk of not detecting a material misstatement due to fraud 
is higher than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment 
by, for example, forgery or intentional misrepresentations, or through collusion. 

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/auditorsresponsibilities.  This  description  forms  part  of  our 
auditor’s report. 

Other matters which we are required to address 
Following the recommendation of the Audit Committee, we were appointed by Seneca Growth Capital VCT Plc 
to audit the Financial Statements for the year ending 31 December 2018 and subsequent financial periods.  
Our ongoing appointment is confirmed by shareholders annually. The period of total uninterrupted engagement 
is 3 years, covering the years ending 31 December 2018 to 31 December 2020. 

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.   

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 auditor’s report and for no other purpose. To 
the  fullest  extent  permitted  by  law,  we  do  not  accept  or  assume  responsibility  to  anyone  other  than  the 
Company and the Company’s members as a body, for our audit work, for this report, or for the opinions we 
have formed. 

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 

22 February 2021 

69 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Combined Income Statement 

Note 

2 

6 

3 

4 

7 

Gain on disposal of fixed asset investments  

Gain/(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 

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

Combined 
Year to 31 December 2020 
Capital 
£’000 

Revenue 
£’000 

Total 
£’000 

Combined 
Year to 31 December 2019 
Capital 
£’000 

Revenue 
£’000 

Total 
£’000 

- 

- 

- 

- 

(10) 

(150) 
(160) 

- 

948 

682 

- 

948 

682 

- 

(140) 

(140) 

(31) 

(41) 

(2) 
1,457 

(152) 
1,297 

- 

- 

- 

- 

(7) 

(123) 
(130) 

52 

52 

(752) 

(752) 

- 

136 

(21) 

- 
(585) 

- 

136 

(28) 

(123) 
(715) 

- 

- 

- 

- 

- 

(160) 

1,457 

1,297 

(130) 

(585) 

(715) 

(160) 

1,457 

1,297 

(130) 

(585) 

(715) 

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 two share classes, the Ordinary share and B share class. 

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. 

70 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ordinary Share Income Statement 
(non-statutory analysis) 

Note 

Gain on disposal of fixed asset investments  

Gain/(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 

Return on ordinary activities after tax 
Return on ordinary activities after tax attributable 
to: 
Ordinary shareholders  
Earnings per share – basic and diluted 

2 

6 

3 

4 

7 

8 

Ordinary shares 
Year to 31 December 2020 
Capital 
£’000 

Revenue 
£’000 

Total 
£’000 

Ordinary shares 
Year to 31 December 2019 
Capital 
£’000 

Revenue 
£’000 

Total 
£’000 

- 

- 

- 

- 

- 

- 
- 

- 

- 

720 

467 

- 

720 

467 

- 

(140) 

(140) 

- 

- 

(2) 
1,045 

(2) 
1,045 

- 

- 

1,045 

1,045 

- 

- 

- 

- 

- 

4 
4 

- 

4 

38 

38 

(725) 

(725) 

- 

136 

- 

- 
(551) 

- 

- 

136 

- 

4 
(547) 

- 

(551) 

(547) 

- 
0.0p 

1,045 
12.8p 

1,045 
12.8p 

4 
0.0p 

(551) 
(6.7)p 

(547) 
(6.7)p 

71 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B Share Income Statement (non-statutory analysis) 

Note 

Gain on disposal of fixed asset investments  

Gain/(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 

Return  on ordinary activities after tax 
Return on ordinary activities after tax attributable 
to: 
B shareholders  
Earnings per share – basic and diluted 

2 

6 

3 

4 

7 

8 

B shares 
Year to 31 December 2020 
Capital 
£’000 

Revenue 
£’000 

Total 
£’000 

B shares 
Year to 31 December 2019 

Revenue 
£’000 

Capital 
£’000 

Total 
£’000 

- 

- 

- 

- 

14 

14 

(27) 

(27) 

- 

- 

- 

- 

(7) 

(21) 

(28) 

(127) 
(134) 

- 
(34) 

(127) 
(168) 

- 

- 

- 

228 

215 

- 

- 

(41) 

(150) 
252 

- 

252 

(134) 

(34) 

(168) 

- 

- 

- 

- 

(10) 

(150) 
(160) 

- 

(160) 

228 

215 

- 

- 

(31) 

- 
412 

- 

412 

(160) 
(2.2)p 

412 
5.7p 

252 
3.5p 

(134) 
(2.5)p 

(34) 
(0.7)p 

(168) 
(3.2)p 

72 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Combined Statement of Changes in Equity 

Capital 
reserve 
realised 
gains/ 
(losses) 
£’000 
1,029 
- 

Capital 
reserve 
holding 
gains/ 
(losses) 
£’000 
(1,309) 
- 

Special 
distributable 
reserve 
£’000 
10,839 
- 

- 

- 

- 

(2,444) 
- 

- 

8,395 
- 

- 

- 

- 

(1,301) 
- 

- 

- 
7,094 

- 

(21) 

136 

- 
52 

- 

1,196 
- 

- 

(33) 

(140) 

- 
948 

- 

(267) 
1,704 

- 

- 

- 

- 
- 

(752) 

(2,061) 
- 

- 

- 

- 

- 
- 

682 

267 
(1,112) 

Revenue 
reserve 
£’000 
(1,967) 
- 

(130) 

- 

- 

- 
- 

- 

(2,097) 
- 

(160) 

- 

- 

- 
- 

- 

- 
(2,257) 

Total 
£’000 
9,281 
2,262 

(130) 

(21) 

136 

(2,444) 
52 

(752) 

8,384 
2,390 

(160) 

(33) 

(140) 

(1,301) 
948 

682 

- 
10,770 

Share 
capital 
£’000 
121 
24 

Share 
premium 
£’000 
568 
2,238 

- 

- 

- 

- 
- 

- 

- 

- 

- 

- 
- 

- 

145 
27 

2,806 
2,363 

- 

- 

- 

- 
- 

- 

- 

- 

- 

- 
- 

- 

- 
172 

- 
5,169 

Balance as at 1 January 2019 
B share issue 
Revenue return on ordinary activities after 
tax 
Expenses charged to capital 
Performance fee allocated as capital 
expenditure 
Dividends paid 
Current period gains on disposal 
Current period losses on fair value of 
investments 
Balance as at 31 December 2019 
B share issue 
Revenue return on ordinary activities after 
tax 
Expenses charged to capital 
Performance fee allocated as capital 
expenditure 
Dividends paid 
Current period gains on disposal 
Current period gains on fair value of 
investments 
Prior years' unrealised losses now realised 
Balance as at 31 December 2020 

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

73 

 
 
 
 
 
 
 
 
 
Ordinary Shares - Statement of Changes in Equity 

Balance as at 1 January 2019 
Revenue return on ordinary activities after 
tax 
Performance fee allocated as capital 
expenditure 
Dividends paid 
Current period gains on disposal 
Current period losses on fair value of 
investments 
Balance as at 31 December 2019 
Revenue return on ordinary activities after 
tax 
Expenses charged to capital  
Performance fee allocated as capital 
expenditure 
Dividends paid 
Current period gains on disposal 
Current period gains on fair value of 
investments 
Prior years' unrealised losses now realised 
Balance as at 31 December 2020 

Share 
capital  
£’000 
81 

Share 
premium   
£’000 
- 

Special 
distributable 
reserve 
£’000 
7,412 

Capital 
reserve 
realised  
gains/ 
(losses) 
£’000 
1,047 

Capital 
reserve 
holding 
gains/ 
(losses) 
£’000 
(1,309) 

- 

136 

- 
38 

- 

- 

- 

- 
- 

(725) 

Revenue 
reserve 
£’000 
(1,949) 

4 

- 

- 
- 

- 

- 

- 

(2,272) 
- 

- 

5,140 

1,221 

(2,034) 

(1,945) 

- 

- 

- 

(1,055) 
- 

- 

- 
4,085 

- 

(2) 

(140) 

- 
720 

- 

(267) 
1,532 

- 

- 

- 

- 
- 

467 

267 
(1,300) 

- 

- 

- 

- 
- 

- 

- 
(1,945) 

Total  
£’000 
5,282 

4 

136 

(2,272) 
38 

(725) 

2,463 

- 

(2) 

(140) 

(1,055) 
720 

467 

- 
2,453 

- 

- 

- 
- 

- 

81 

- 

- 

- 

- 
- 

- 

- 
81 

- 

- 

- 
- 

- 

- 

- 

- 

- 

- 
- 

- 

- 
- 

74 

 
 
 
 
 
 
 
 
 
 
 
 
B Shares - Statement of Changes in Equity 

Share 
capital  
£’000 
40 
24 
- 
- 
- 
- 

Share 
premium   
£’000 
568 
2,238 
- 
- 
- 
- 

Special 
distributable 
reserve 
£’000 
3,427 
- 
- 
- 
(172) 
- 

- 

64 
27 
- 
- 
- 
- 

- 

91 

- 

2,806 
2,363 
- 
- 
- 
- 

- 

5,169 

- 

3,255 
- 
- 
- 
(246) 
- 

- 

3,009 

Capital 
reserve 
realised  
gains/ 
(losses) 
£’000 
(18) 
- 
- 
(21) 
- 
14 

Capital 
reserve 
holding 
gains/ 
(losses) 
£’000 
- 
- 
- 
- 
- 
- 

- 

(25) 
- 
- 
(31) 
- 
228 

- 

172 

(27) 

(27) 
- 
- 
- 
- 
- 

215 

188 

Revenue 
reserve 
£’000 
(18) 
- 
(134) 
- 
- 
- 

- 

(152) 
- 
(160) 
- 
- 
- 

- 

Total  
£’000 
3,999 
2,262 
(134) 
(21) 
(172) 
14 

(27) 

5,921 
2,390 
(160) 
(31) 
(246) 
228 

215 

(312) 

8,317 

Balance as at 1 January 2019 
B share issue 
Revenue return on ordinary activities after tax 
Expenses charged to capital 
Dividends paid 
Current period gains on disposal 
Current period losses on fair value of 
investments 
Balance as at 31 December 2019 
B share issue 
Revenue return on ordinary activities after tax 
Expenses charged to capital 
Dividends paid 
Current period gains on disposal 
Current period gains on fair value of 
investments 
Balance as at 31 December 2020 

75 

 
 
 
 
 
 
 
 
 
 
Combined Balance Sheet 

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 reserve – realised gains and losses 
                         – holding gains and losses 
Revenue reserve 
Total equity shareholders' funds 

*At fair value through profit and loss 

Combined as at 
31 December 2020 

Combined as at 
31 December 2019 

Note 

£'000 

- 

7 
5,056 
(223) 

(193) 

10 

11 

12 

12 

13 
14 
14 
14 
14 
14 

£'000 

6,123 

- 

- 
4,840 

10,770 

172 
5,169 
7,094 
1,704 
(1,112) 
(2,257) 
10,770 

£'000 

3 
3,909 
(236) 

(53) 

£'000 

4,761 

3,676 

8,384 

145 
2,806 
8,395 
1,196 
(2,061) 
(2,097) 
8,384 

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

The statements were approved by the Directors and authorised for issue on 22 February 2021 and are 
signed on their behalf by: 

John Hustler 
Chairman 
Company No: 04221489 

76 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ordinary Share Balance Sheet 
(non-statutory analysis) 

Ordinary shares as at 
31 December 2020 

Ordinary shares as at 
31 December 2019 

£'000 

- 
527 
(22) 

(193) 

£'000 

- 
470 
(22) 

(53) 

£'000 

2,141 

505 

2,453 

81 
- 
4,085 
1,532 
(1,300) 
(1,945) 
2,453 
30.2p 

£'000 

2,068 

448 

2,463 

81 
- 
5,140 
1,221 
(2,034) 
(1,945) 
2,463 
30.4p 

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 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 

Note 

10 

12 

13 

9 

77 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B Share Balance Sheet (non-statutory analysis) 

B shares as at 
31 December 2020 

Note 

£'000 

7 
4,529 
(201) 

- 

10 

12 

13 

9 

£'000 

3,982 

4,335 

8,317 

91 
5,169 
3,009 
172 
188 
(312) 
8,317 
91.8p 

B shares as at 
31 December 2019 
£'000 

£'000 

3 
3,439 
(214) 

- 

2,693 

3,228 

5,921 

64 
2,806 
3,255 
(25) 
(27) 
(152) 
5,921 
93.1p 

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 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 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Combined Statement of Cash Flows 

Combined Year to 
31 December 2020 
£'000 

Combined Year to 
31 December 2019 
£'000 

Note 

Cash flows from operating activities 
Return on ordinary activities before tax 
Adjustments for: 
(Increase)/decrease in debtors 
Increase/(decrease) in creditors 
Gain on disposal of fixed asset investments 
(Gain)/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 inflow/(outflow) from investing activities 

Cash flows from financing activities 
Dividend paid 
Issue of B shares 
Awaiting B share issue 
Total cash inflow/(outflow) from financing activities 

Increase/(decrease) in cash and cash equivalents 

Opening cash and cash equivalents 

Closing cash and cash equivalents 

11 
12 

7 

10 
10 

12 

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

1,297 

(4) 
143 
(948) 
(682) 
(194) 
- 
(194) 

(1,360) 
1,628 
268 

(1,301) 
2,390 
(16) 
1,073 

1,147 

3,909 

5,056 

(715) 

20 
(143) 
(52) 
752 
(138) 
- 
(138) 

(2,248) 
80 
(2,168) 

(2,444) 
2,262 
(49) 
(231) 

(2,537) 

6,446 

3,909 

79 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ordinary Shares Statement of Cash Flows 
(non-statutory analysis) 

Cash flows from operating activities 
Return on ordinary activities before tax 
Adjustments for: 
(Increase)/decrease in debtors 
Increase/(decrease) in creditors 
Gain on disposal of fixed asset investments 
(Gain)/loss on valuation of fixed asset investments 
Cash from operations 
Income taxes paid 
Net cash used in operating activities 

Cash flows from investing activities 
Sale of fixed asset investments 
Total cash inflow from investing activities 

Cash flows from financing activities 
Dividend paid 
Total cash outflow from financing activities 

Increase/(decrease) in cash and cash equivalents 

Opening cash and cash equivalents 

Closing cash and cash equivalents 

Note 

10 

7 

10 

Ordinary shares 
Year to  
31 December 2020 
£'000 

Ordinary shares  
Year to  
31 December 2019 
£'000 

1,045 

- 
140 
(720) 
(467) 
(2) 
- 
(2) 

1,114 
1,114 

(1,055) 

(1,055) 

57 

470 

527 

(547) 

- 
(174) 
(38) 
725 
(34) 
- 
(34) 

38 
38 

(2,272) 

(2,272) 

(2,268) 

2,738 

470 

80 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B Shares Statement of Cash Flows 
(non-statutory analysis) 

Cash flows from operating activities 
Return on ordinary activities before tax 
Adjustments for: 
(Increase)/decrease in debtors 
Increase in creditors 
Gain on disposal of fixed asset investments 
(Gain)/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 outflow from investing activities 

Cash flows from financing activities 
Dividend paid 
Issue of B shares 
Awaiting B share issue 

Total cash inflow from financing activities 

Increase/(decrease) in cash and cash equivalents 

Opening cash and cash equivalents 

Closing cash and cash equivalents 

B shares 
Year to  
31 December 2020 
£'000 

B shares  
Year to  
31 December 2019 
£'000 

Note 

10 

7 

10 
10 

12 

252 

(4) 
3 
(228) 
(215) 
(192) 
- 
(192) 

(1,360) 
514 
(846) 

(246) 
2,390 
(16) 

2,128 

1,090 

3,439 

4,529 

(168) 

20 
31 
(14) 
27 
(104) 
- 
(104) 

(2,248) 
42 
(2,206) 

(172) 
2,262 
(49) 

2,041 

(269) 

3,708 

3,439 

81 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2019)’. 

The  principal  accounting  policies  have  remained  materially  unchanged  from  those  set  out  in  the 
Company’s  2019  Annual  Report  and  Financial  Statements.  A  summary  of  the  principal  accounting 
policies is set out below. 

The Company is a public company and is limited by shares. 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 
The  assets  of  the  Company  consist  mainly  of  securities,  four  of  which  are  AIM  quoted,  quite  liquid 
and readily accessible, as well as cash. As at 31 December 2020, 47% of net assets was cash. 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. 

In addition to the above, the Company is also facing risks resulting from the impact of the C-19 pandemic. 
The Company’s Board and Investment Manager are focused on ensuring that investee companies are 
taking the required actions to minimise the potential impact that the C-19 pandemic could have on them.  
The Board and Seneca will continue to review risks posed by C-19 and keep those risks under regular 
review.  

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 or revenue multiples, 

82 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
forecast results of investee companies, asset values of investee companies and liquidity or marketability 
of  the  investments  held.  The  material  factors  affecting  the  returns  and  net  assets  attributable  to 
shareholders of the different share classes are the valuations of the Ordinary and B share pools and 
ongoing general expenses.  

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 (£). 

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  or  revenue  multiples,  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: 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 held 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/revenue multiple, discounted cash flows and/or net assets) where 
it is available and rely as little as possible on entity specific estimates. 

There have been no transfers between these classifications in the year (2019: 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 2020 or 31 December 2019. 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. 

The Company has not generated any income in 2020 (2019: £nil).  

Expenses 
All expenses are accounted for on an accruals basis. Expenses are charged wholly to revenue with the 
exception of the performance and management fee. The performance fee is charged 100% to the capital 
reserve and 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 

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  applicable  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 
53  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. 

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 and may be used to cover dividend payments.  

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

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

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

85 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 shareholders. 

2.  Income Investment Management Investment Management 

Dividends received 
Loan note interest receivable 

Year to  
31 December 2020 
£’000 
- 
- 
- 

Year to  
31 December 2019 
£’000 
- 
- 
- 

Investment income includes interest earned on bank balances and dividends. 

The  Company  has  not  generated  any  income  in  the  period  and  as  such  we  have  not  included  any 
segmental reporting. In the event the Company had generated income, we would disclose information 
about the Company’s operating segments and the geographical areas in which they operate, which is 
currently in the United Kingdom.  

3.  Investment Management Fees for B shares 

Gross Investment management fee 
Cost cap refund from Seneca  
Investment management fee net of cost cap 

Year to  
31 December 2020 
£’000 
127 
(86) 
41 

Year to  
31 December 2019 
£’000 
103 
(75) 
28 

Seneca is entitled to an annual management fee of 2% of the weighted net asset value of the B share 
pool (2019: 2%) and, with effect from 1 August 2019, is also entitled to an annual fee of £9,000 (plus 
VAT, if applicable) in relation to management accounting services. These fees are payable quarterly in 
arrears. Seneca will also be entitled to certain monitoring fees from investee companies and the Board 
reviews the amounts (please see note 19). 

Seneca are also entitled to receive a performance related incentive fee (the “Performance Incentive Fee”) 
in relation to the B share pool of an amount equal to 20% of the shareholder proceeds arising, 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. 

Shareholder proceeds are all amounts paid by way of dividend or other distributions, share buy backs, 
proceeds on a sale or liquidation of the Company in relation to the B shares and calculated on a per share 
basis, 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  the  avoidance  of  doubt,  no  Performance  Incentive  Fee  will  be  payable  to  the  extent  that  the 
shareholder  proceeds  paid  by  the  Company  to  the  holders  of  the  B  shares  have  been  justified  by 

86 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reference  to  distributable  reserves  otherwise  attributable  to  the  Ordinary  share  pool  (as  permitted  in 
accordance with the Articles). 

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). Following this initial period, expenses are capped at 3% across both the Ordinary share 
pool and the B share pool pro-rata to their respective net asset values.  

The Investment Manager will indemnify the Company for any excess over the cost cap, with an amount 
equal to such excess either being paid by Seneca to the Company or refunded by way of a reduction to 
its fees. Accordingly, Seneca reduced its management fee by £86,000 in the year to 31 December 2020 
(2019: reduced by £75,000).  

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

4.  Other Expenses 

Directors’ remuneration  
Fees payable to the Company’s auditor for the audit of the Financial Statements 
Legal and professional expenses 
Accounting and administration services 
Other expenses (revenue)  
Other expenses (capital)  

Year to  
31 December 2020 
£'000 
50 
22 
59 
7 
12 
2 
152 

Year to  
31 December 2019 
£'000 
33 
15 
49 
12 
14 
- 
123 

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. It should be noted that the only items specifically relating to the Ordinary 
share pool relate to a £2k legal fee (2019: £4k credit of released accruals for advisory fees). 

5.  Directors’ Remuneration 

Directors’ emoluments: 
John Hustler (Chairman) 
Charles Breese 
Richard Roth 
Alex Clarkson 
Richard Manley 

Year to 
31 December 2020 
£ 

Year to  
31 December 2019 
£ 

15,339 
- 
19,608 
15,339 
- 
50,286 

12,897 
6,375 
12,897 
981 
- 
33,150 

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. 

87 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As part of the Board’s regular review of Directors’ fees, it was determined that Richard Roth’s Director’s 
fee would increase to £20,000 per annum inclusive of all expenses with effect from 1 October 2020 to 
reflect the work performed by him in respect of his role as Chairman of the Audit Committee. It was also 
decided that Richard Roth would receive a one-off payment of £2,500 in respect of the work he performed 
as part of this role for the period prior to 1 October 2020. Apart from this, none of the Directors received 
any other remuneration from the Company during the year. 

Directors’ emoluments include remuneration and employers’ National Insurance contributions.  

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 58 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 four (2019: four).  

6.  Performance Fees for Ordinary shares 

The  performance  incentive  fees  are  calculated  separately  on  the  Ordinary  shares  and  the  B  shares. 
Performance incentive fees in relation to the Ordinary shares are potentially payable to past and current 
members of the CAC. The current members of the CAC are John Hustler and Richard Roth.  

The CAC entered into an agreement to take over management of the Company’s investments on 30 July 
2007  (the  “2007  Agreement”),  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 (the “Accrued Performance Incentive Fee”). 

On 7 October 2015, the performance incentive fee structure was further amended as follows. In respect 
of the period to 31 December 2014, the Accrued Performance Incentive Fee on the Ordinary share class 
of up to £702,000 shall be payable to James Otter (a former director of the Company who was also a 
member of the CAC), Charles Breese (a former director of the Company who was also a member of the 
CAC) and John Hustler, in equal proportions (with the liability to pay a director his share of such fee being 
extinguished if the fee is due for payment five years after his ceasing to be a member of the CAC. Such 
extinguished fees are credited back to the Company). 

The  liability  to  pay  James  Otter  his  share  of  any  potential  Accrued  Performance  Incentive  Fee  was 
extinguished on 7 October 2020 - the fifth anniversary of his ceasing to be a member of the CAC. No 
payment  has,  or  will  be  paid,  to  James  Otter  under  these  schemes  as  the  required  shareholder 
distributions had not been made in time. The fee of £17,667 that had been accrued at 31 December 2019 
for his potential benefit has been credited back to the Company, with the total potential liability for the 
Company now reduced from £702,000 to £468,000.  

As a result of the reduction in the Accrued Performance Incentive Fee by one third, the amount of the 
Accrued Performance Incentive Fee shall be 16.67% of any dividends and capital distributions returned 
to shareholders, which in total exceed the sum of 80p per Ordinary share (the "Hurdle"). This includes 
dividends paid to date on the Ordinary shares, being 65.25p per share. As a result of this, for every £1 
potentially distributable in excess of the Hurdle, 80p shall be distributed to shareholders and 13.33p shall 
be  paid  as  the  Accrued  Performance  Incentive  Fee,  with  6.67p  (being  one  third  of  the  original  20p) 
retainable by the Company up until an amount of 114.65p per Ordinary share has been distributed to 
Ordinary shareholders, after which no further payment is payable in respect of the Accrued Performance 
Incentive  Fee  or  otherwise  under  the  terms  of  the  2007  Agreement  (as  amended).  The  Accrued 

88 

 
 
 
 
 
 
 
 
 
 
Performance  Incentive  Fee  shall  be  paid  at  the  same  time  as  payments  are  made  to  the  Ordinary 
shareholders. All distributions by way of dividends and capital distributions in relation to the Ordinary 
share class shall count towards the Accrued Performance Incentive Fee and where non-cash dividends 
are declared, the Company's auditors shall assess their value by reference to a distribution per share. 
Following payment in full of the Accrued Performance Incentive Fee, a further performance incentive fee 
may become payable to the CAC in relation to the period after 7 October 2015 (the, “Further Performance 
Incentive Fee”).  

Following  the  amendment  on  7  October  2015,  any  returns  above  the  31  December  2014  levels  are 
subject to a further hurdle (the “Further Hurdle”), and the Further Performance Incentive Fee reduces the 
share to the CAC to 10% of sums returned to Ordinary shareholders by way of dividends and capital 
distributions of whatever nature, which in total exceed the Further Hurdle (excluding any initial tax relief 
on the subscription for the Ordinary shares). The "Base Figure" for the Further Hurdle shall be 90.4p per 
Ordinary share and shall be increased by a sum equal to notional interest thereon, at the rate of 1.467% 
per quarter from 1 January 2015, compounded with quarterly rests. For the purposes of determining the 
increase in the Base Figure, the amount on which notional interest is to accrue in each quarter shall be 
reduced by the amount of all sums returned to Ordinary shareholders by way of dividends and capital 
distributions in the previous quarter. Shareholders will need to have received distributions of 114.65p per 
Ordinary share, together with the amount to take account of notional interest as calculated above, before 
any Further Performance Incentive Fee is payable.  

As at 31 December 2020, the Total Gross Return in respect of the Ordinary shares is 97.85p, and so 
3.57p per Ordinary share, totalling £290,000 would have accrued, though only two thirds of the Accrued 
Performance Incentive Fee, 2.38p per Ordinary share totalling £193,000, has been accrued as part of 
this liability as a result of James Otter’s liability being extinguished as detailed above, resulting in the 
remainder being retainable by the Company (31 December 2019: 83.25, 0.65p and £53,000).  

Assuming no dividends are paid on the Ordinary shares in 2021, the Total Gross Return would need to 
exceed 163.3p at 31 December 2021 before any Further Performance Incentive Fee could be due, and 
at that time, it would be 10% of any dividends or capital distributions made above this threshold. If the 
Further Performance Incentive Fee is not triggered (as it has not been in this financial year) the Further 
Hurdle, net of dividends paid, increments by a compound annual growth rate of 6%, applied quarterly as 
described above.  

If the CAC consider it necessary to engage external advisors in support of managing its portfolio, the 
costs of this will be borne by the Ordinary share pool. The Further Performance Incentive Fee shall be 
divided among such members of the CAC (past, present and future) who have been members of that 
committee since the 7 October 2015, on a pro rata basis, linked to the relative amount of time since the 
date of the 7 October 2015 agreement for which each individual has been a member of the CAC. An 
individual will not be entitled to payment of any of Further Performance Incentive Fee if he ceased to be 
a member of the CAC in certain conditions, or ceased to be a member of the CAC more than five years 
before the payment of any amount of Further Performance Incentive Fee becomes due and any such 
fees will be credited back to the Company. For the purposes of the Further Performance Incentive Fee, 
the  method  of  determining  distributions  will  follow  that  used  in  calculating  the  Accrued  Performance 
Incentive Fee. 

89 

 
 
 
 
 
 
 
 
 
7.  Tax on Ordinary Activities  

The corporation tax charge for the period was £nil (2019: £nil). 
The tax charge is calculated on return on ordinary activities before taxation at the applicable rate of 19.0% 
(2019: 19.0%) 

Current tax reconciliation: 
Return on Ordinary activities before tax 

Current tax at 19% (2019: 19%)   

Gains/losses not subject to tax 

Performance fee accrual not tax deductible  

Excess management expenses carried forward 

Total current tax charge and tax on results of ordinary activities 

Year to  
31 December 2020 
£’000 
1,297 

Year to  
31 December 2019 
£’000 
(715) 

246 

(310) 

37 

27 

- 

(136) 

133 

- 

3 

- 

The company has excess management expenses of £2,896,000 (2019: £2,755,000) 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 2019: 8,115,376) shares, being 
the  weighted  average  number  of  Ordinary  shares  in  issue  during  the  year,  and  a  return  for  the  year 
totalling £1,045,000 (31 December 2019: (£547,000)). 

The  earnings  per  B  share  is  based  on  7,248,338  (31  December  2019:  5,269,973)  shares,  being  the 
weighted average number of B shares in issue during the year, and a return for the year totalling £252,000 
(31 December 2019: (£168,000)). 

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 2020 is based on 8,115,376 Ordinary 
shares in issue at that date (31 December 2019: 8,115,376). 

The calculation of NAV per B share as at 31 December 2020 is based on 9,062,948 B shares in issue at 
that date (31 December 2019: 6,361,448). 

90 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10. 

Fixed Asset Investments  

Ordinary Shares 

Valuation and net book amount: 
Book cost as at 1 January 2020 
Cumulative revaluation 
Valuation at 1 January 2020 

Movement in the year: 
Purchases at cost 
Disposals – cost 
Disposals – revaluation 
Revaluation in year 
Valuation at 31 December 2020 

Book cost at 31 December 2020 
Revaluation to 31 December 2020 

Valuation at 31 December 2020 

B Shares 

Valuation and net book amount: 
Book cost as at 1 January 2020 
Cumulative revaluation 
Valuation at 1 January 2020 

Movement in the year: 
Purchases at cost 
Disposals – cost 
Disposals – revaluation 
Revaluation in year 
Valuation at 31 December 2020 

Book cost at 31 December 2020 
Revaluation to 31 December 2020  

Valuation at 31 December 2020 

Level 1: 
AIM-quoted investments 
£’000 

Level 3: 
Unquoted 
 investments 
£’000 

Total  
investments 
£’000 

1,117 
117 
1,234 

- 
(391) 
(3) 
780 
1,620 

726 
894 

1,620 

2,985 
(2,151) 
834 

- 
(270) 
270 
(313) 
521 

2,715 
  (2,194) 

521 

4,102 
(2,034) 
2,068 

- 
(661) 
267 
467 
2,141 

3,441 
(1,300) 

2,141 

Level 1: 
AIM-quoted 
investments 
£’000 

Level 3: 
Unquoted 
 investments 
£’000 

Total  
investments 
£’000 

720 
(90) 
630 

576 
(286) 
- 
415 
1,335 

1,010 
325 

1,335 

2,000 
63 
2,063 

784 
- 
- 
(200) 
2,647 

2,784 
(137) 

2,647 

2,720 
(27) 
2,693 

1,360 
(286) 
- 
215 
3,982 

3,794 
188 

3,982 

Further details of the fixed asset investments held by the Company are shown within the Investment 
Manager’s Report on pages 14 to 35. 

All investments are initially measured at their transaction price. Subsequently, at each reporting date, the 
investments are valued at fair value through profit or loss, and all capital gains or losses on investments 

91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
are so measured. Unquoted fixed asset investments are valued at fair value in accordance with the IPEV 
guidelines.           

The changes in fair value of such investments recognised in these Financial Statements are treated as 
unrealised holding gains or losses. 

The launch of the B Share pool took place relatively recently in August 2018, and all but one of the B 
Share unquoted investments have taken place in the two years ending 31 December 2020. As these 
companies are at an early stage of the investment cycle, it is the Board’s view that the most appropriate 
valuation methodology is to hold the B Share unquoted investments at cost or in line with the price of the 
most recent investment received by the investee company. This is consistent with the approach adopted 
for the valuation of the Ordinary share pool’s unquoted investments. 

When using this methodology however, a detailed assessment of the respective value of each portfolio 
company is also performed in order to gain the necessary comfort as to whether a fair value reduction or 
uplift is in fact required. This process involves a review of the progress made by each investee company, 
recent developments in the M&A market and comparisons to listed competitors across all relevant key 
performance indicators.  Further, all  of  these  are  considered  in  the  context  of  the  exit  equity  waterfall 
structure as detailed in each investee company’s articles of association. 

FRS 102 requires the Directors to consider the impact of changing one or more of the assumptions used 
as part of the valuation process to reasonable possible alternative assumptions. As noted above, whilst 
the methodologies adopted for the 31 December 2020 investee company valuations are not based on 
revenue or earnings multiples, the Board do consider revenue multiple based valuation methodologies in 
support of the valuations adopted where relevant.   

In view of the FRS 102 requirement, the Board have considered the impact that introducing reasonable 
alternative assumptions to this revenue multiple based valuation methodology could have on the value 
of the Company’s investment pool as at 31 December 2020.    

As  a  result  of  this  analysis  the  Board  have  concluded  that  such  reasonable  possible  alternative 
assumptions could result in an increase in the valuation of the B share pool unquoted investments by 
£81,000 or a decrease in the valuation of B share pool investments by £48,000. It was considered that 
only one B share portfolio company was relevant for this exercise due to its more mature trading profile.  
It  was  not  considered  that  any  of  the  Ordinary  share  pool  portfolio  companies  were  relevant  for  this 
exercise.  

Throughout  this  exercise,  and  in  determining  the  value  of  the  Company’s  equity  investments  where 
trading multiples are considered, multiples used are reviewed and compared to industry peers, based on 
size,  stage  of  development,  revenue  generation  and  growth  rate,  as  well  as  their  wider  strategy  and 
market position. These multiples are calculated in the traditional manner, by dividing the enterprise value 
of the comparable group by its revenue, EBITDA or earnings depending on what is the norm in a particular 
sector driven by how acquisitions in that sector are typically valued. The trading multiple is then adjusted 
for considerations such as illiquidity, marketability and other differences, advantages and disadvantages 
between the portfolio company and the comparable public companies based on company specific facts 
and circumstances. 

92 

 
 
 
 
 
 
                                                                                                                                                     
 
 
 
 
 
 
 
11.  Debtors 

Prepayments and accrued income 

12.  Creditors 

Amounts falling due within one year 
Trade creditors 
PAYE/NIC 
Awaiting B share allotment 
Other creditors 
Accruals 

Total amounts falling due within one year 

Amounts falling due after one year 
Accruals 

Total amounts falling due after one year 

31 December 2020 
£’000 
7 

31 December 2019 
£’000 
3 

31 December 2020 
£’000 

31 December 2019 
£’000 

1 
7 
154 
23 
37 

223 

193 

193 

8 
- 
170 
22 
36 

236 

53 

53 

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.  The  awaiting  B  share  issue  included  in  the 
combined and B share cash flow statements shows the movement in cash awaiting B share issue in the 
year since the prior year end.  

13.  Share Capital 

Allotted and fully paid up: 
8,115,376 Ordinary shares of 1p (2019: 8,115,376 shares of 1p) 
9,062,948 B shares of 1p (2019 : 6,361,448) 

31 December 2020 
£’000 

31 December 2019 
£’000 

81 
91 
172 

81 
64 
145 

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 4.  

During the year, the Company did not issue, nor buy back, any Ordinary shares.  

The Company issued a total of 2,701,500 B shares at prices between 79.5 to 94.7p per B share during 
the year. These were issued pursuant to the offer for subscription for B shares launched on 16 July 2019 
and a further offer for subscription for B shares launched on 13 October 2020 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 shares. 

The total proceeds received for the shares issued in the period was £2,390k (net of facilitated fees, gross 
of Seneca’s promoter fee) for the B share pool.  

93 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Share Rights 
As regards Income: shareholders shall be entitled to receive such dividends as the Directors resolve to 
pay out in accordance with the Articles. Under the Articles of the Company, all the assets of the Company 
and all the liabilities of the Company will be allocated either to the Ordinary share pool or the B share 
pool. The Ordinary shares will be entitled to the economic benefit of the assets allocated to the Ordinary 
share pool and the B shares will be entitled to the economic benefit of assets allocated to the B share 
pool.  Therefore,  although  the  rules  in  the  CA  2006  and  elsewhere  in  relation  to  the  payment  of 
distributions  will  be  applicable  to  the  Company  on  a  company-wide  basis,  the  income  arising  on  the 
portfolios will belong to one or the other of the share classes depending on which portfolio generated the 
income.  

As regards Capital: similarly, the capital assets of the Company will be allocated to either the Ordinary 
share pool or the B share pool. On a return of capital on a winding-up or on a return of capital (other than 
on a purchase by the Company of its shares) the surplus capital shall be divided amongst the holders of 
the relevant share class pro rata according to the number of shares of the relevant class held and the 
aggregate entitlements of that share class. The Ordinary shares will not be entitled to any capital assets 
held in the B share pool and the B shares will not be entitled to any capital assets held in the Ordinary 
share pool. In relation to the purchase by the Company of its shares, the purchase of Ordinary shares 
may only be financed by assets in the Ordinary share pool and the purchase of the B shares may only 
be financed by assets in the B share pool. 

As regards voting and general meetings: subject to disenfranchisement in the event of noncompliance 
with a statutory notice requiring disclosure as to beneficial ownership, each shareholder present in person 
or by proxy shall on a poll have one vote for each share of which he/she is the holder. The Ordinary 
shareholders may not be entitled to vote on certain matters which concern the B share class only and 
vice versa. 

As  regards  Redemption:  none  of  the  B  shares  or  the  Ordinary  shares  are  redeemable.  The  Articles 
provide that reserves (whether created upon the cancellation of the share premium account arising from 
the issue of Ordinary shares or B shares or otherwise) may also be used for the benefit of the other share 
class. While this will not transfer any net asset value between the different share classes, it will permit 
those reserves to be treated as distributable profits on a Company-wide basis such that on an accounting 
basis dividends and share buybacks in respect of both share classes may be facilitated by the availability 
of those reserves.  

14.  Movement in Shareholders’ Funds 

Shareholders’ funds at start of year 
Return on ordinary activities after tax 
Increase due to issue of B shares 
Dividend paid 

Shareholders’ funds at end of year 

Year ended  
31 December 2020 
£’000 
8,384 
1,297 
2,390 
(1,301) 

10,770 

Year ended  
31 December 2019 
£’000 
9,281 
(715) 
2,262 
(2,444) 

8,384 

The analysis of changes in equity by the various reserves are shown in the Statement of Changes in 
Equity on page 73.  

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 

94 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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 £5,429,000 as at 31 December 2020 (2019: £5,433,000). Although the distributable reserves total 
£5,429,000 as at 31 December 2020, only £2,002,000 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 8 pence per Ordinary share for the year to 31 December 2020 was paid on 
28  August  2020.  A  further  interim  capital  dividend  of  5  pence  per  Ordinary  share  for  the  year  to  31 
December 2020 was paid on 30 October 2020.  

An interim dividend of 1.5 pence per B share for the year to 31 December 2020 was paid on 15 May 
2020. A second interim dividend of 1.5 pence per B share for the year to 31 December 2020 was paid on 
24 December 2020. 

15. 

Financial Instruments  

The Company's financial instruments comprise equity investments, cash balances and liquid resources 
including 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 2020 and 31 December 2019:  

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 
Total 

Financial liabilities measured at amortised cost 
Creditors 
Accruals 
Performance fee 
Total 

31 December 2020 
£’000 

31 December 2019 
£’000 

6,123 
6,123 

5,056 
5,056 

31 
37 
193 
261 

4,761 
4,761 

3,909 
3,909 

30 
36 
53 
119 

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 the IPEV guidelines. The fair value of all other 

95 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 are initially recognised at fair value, which is usually the transaction price, and 
then thereafter at amortised cost.  

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 4. 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 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 pages 14 to 35. 

29.4%  (2019:  34.5%)  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 
2020 would have increased net assets and the total return for the year by £317,000 (2019: £290,000) 
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.  

27.4% (2019: 22.2%) 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 2020 would have increased net 
assets and the total return for the year by £296,000 (2019: £186,000) 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  2020  or  31 
December 2019.  

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.  

96 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

The share price of SkinBio rose substantially since the year end when it was 22p and this allowed the 
Company to sell a total of 1,750,000 SkinBio shares from the B share pool in January 2021 for a total of 
£621k and generating a profit versus original cost of £341k (a 2.2x return on the original investment).  

In  addition  the  Company  was  able  to  realise  nearly  50%  of  its  holdings  in  Abingdon  Health  Plc 
(“Abingdon”) for a small profit. The Company sold a total of 78,000 shares in Abingdon from the B share 
pool in January 2021 for a total of £76k at 98 pence per share. 

One additional unquoted investment was made in the B share pool in January 2021 into Solascure Ltd. 
for £500,000. 

Following recent press coverage, the share price of Scancell rose significantly from 13.5p at 31 December 
2020 and was 24.5p at 19 February 2021 and this allowed the Company to take the opportunity to sell 
1,000,000 Scancell shares from the Ordinary share pool in February 2021 at 21.7p per Scancell share.  

As a result of the above, the Company is pleased to announce an updated unaudited NAV of 99.4p per 
B share and 44.0p per Ordinary share at 19 February 2021.  

The Company also declared an interim B share dividend of 1.5p per B share on 18 February 2021 to be 
paid on 14 May 2021 to shareholders on the B share register on 30 April 2021, with an ex-dividend date 
of 29 April 2021. 

The Directors are not aware of any other post balance sheet events which need to be brought to the 
attention of shareholders.  

18.  Contingencies, Guarantees and Financial Commitments 

There were no contingencies, guarantees or financial commitments as at 31 December 2020 (2019: £nil). 

19.  Related Party Transactions 

The Board acted as the investment manager of the Company until Seneca was appointed on 23 August 
2018. Certain Directors are entitled to participate in a performance bonus as detailed in note 6. During 
the year, Seneca has earnt £127,000 in management fees (2% of the weighted average net assets of the 
B share portfolio) (2019: £103,000). However, only £41,000 is recoverable by Seneca as a result of the 
cost cap, as detailed in note 3 and this was paid to Seneca during the year (2019: £28,000). 

97 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Seneca as Investment Manager accrued £76,191 (2019: £138,132) transaction fees and directors’ fees 
from investee companies in relation to the arrangement and monitoring of investments. As a related party, 
we believe that this transaction is disclosable, and the Board ensures it is managed from a conflicts of 
interest point of view. 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 13 October 2020, Seneca (as promoters of the 
Offer) is entitled to charge the Company up to 5.5% of investors’ subscriptions. A total of £6,595 has 
been paid to Seneca, based on the allotments of £2,396,950 (net of facilitated fees, gross of the promoter 
fee) as at 31 December 2020 (2019: £20,294). 

98 

 
 
 
 
 
 
 
 
  
 
 
Shareholder Information and Contact Details 

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, whose details can be found on page 101. 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 (19 February 2021) 

Ordinary shares 
33.5p per share 

B shares 
84.0p 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 
Paul Nolan 

020 7886 2716               chris.lloyd@panmure.com 
020 7886 2717               paul.nolan@panmure.com 

Risk Warning - Financial Scams 

We have been made aware that a number of existing shareholders and those of other VCTs have been 
contacted in connection with fraudulent financial scams. In these instances, shareholders have received 
unsolicited  phone  calls  from  persons  claiming  to  work  for  a  corporate  finance  firm,  offering  to  buy 
shareholder’s VCT shares at an inflated price in connection with a possible take-over of the VCT and 
asking shareholders to sign a non-disclosure agreement. 

The claims made are false and are invariably an attempt to obtain confidential personal information from 
shareholders with a view to fraudulently extract money from them. 

Shareholders are warned to be very suspicious if they receive any similar type of communication and we 
would recommend that you do not respond with any personal information. 

99 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
If you are in any doubt, we recommend that you seek professional financial advice before taking any 
action.  You  can  also  call  Seneca  Partners  Limited  on  01942  295  981  if  you  wish  to  check  that  any 
correspondence or communication you receive from the Company is genuine. 

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 Registrars, 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 also be 
made  available  there.  The  Company  has  introduced  e-communication  for  its  shareholders,  and  we 
continue to encourage all of our investors to switch to receiving updates from the Company via e-mail 
and documents in soft copy. This enables you to receive documents more quickly and has the added 
benefits of being more environmentally friendly and reducing printing and postage costs. 

Should you wish to switch to e-mail communication and documents in the future by e-mail, please contact 
our Registrars, Neville Registrars Limited, Neville House, Steelpark Road, Halesowen, B62 8HD, e-mail 
info@nevilleregistrars.co.uk, or phone 0121 585 1131. Please also contact them for any other queries 
related to your shareholding in the Company. 

100 

 
 
 
 
 
 
 
 
 
 
 
 
 
Directors and Advisers 

Board of Directors 
John Hustler (Chairman) 
Alex Clarkson 
Richard Manley 
Richard Roth 

Company Number 
Registered in England & Wales 
No 04221489 

Secretary and Registered Office 
Craig Hunter 
9 The Parks 
Haydock 
WA12 0JQ 

Investment Manager and 
Administration Manager 
Seneca Partners Limited 
9 The Parks 
Haydock 
WA12 0JQ 
Tel: 01942 271746 

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

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

VCT Adviser 
Philip Hare & Associates LLP 
1 Temple Avenue 
Temple 
London  
EC4Y 0HA  

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 
Building 3 
566 Chiswick High Road 
London 
W4 5YA 

101 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notice of Annual General Meeting 

Notice is hereby given that the Annual General Meeting (“AGM”) of Seneca Growth Capital VCT Plc (“the Company”) will be 
held as a closed meeting at 14:00 on Monday, 29 March 2021 at the Company’s registered address 9 The Parks, Haydock, 
WA12  0JQ  in  accordance  with  the  provisions  of  the  Corporate  Insolvency  and  Governance  Act  2020.  In  light  of  the 
unprecedented restrictions on movement and gatherings due to the Covid-19 pandemic, the meeting will take place with either 
two Directors who hold shares in the Company or one Director and an investment manager from Seneca Partners Limited, 
who is also a shareholder, present only, to constitute the minimum quorum for the AGM to take place under the Company's 
Articles of Association and company law requirements. Shareholders should note that only the formal business set out in the 
notice of AGM will be considered at the AGM. 

Although shareholders will not be permitted to attend the AGM this year there will be a shareholder update presentation and 
a question and answer (“Q&A”) session at 10:00 on 8 March 2021, further details of which can be found on the Company’s 
website at https://senecavct.co.uk/march-2021-shareholder-presentation/.   

Shareholders  wishing  to  vote  on  any  of  the  matters  of  business  are  urged  to  do  so  through  completion  of  a  proxy  form 
appointing the chairman of the AGM, which can be submitted to the Company’s Registrar as detailed in the Notes. Proxy 
forms should be completed and returned in accordance with the instructions thereon and the latest time for the receipt of proxy 
forms is 14:00 on Saturday, 27 March 2021. Proxy votes can be also be submitted by CREST.   

All resolutions will be decided by a poll and therefore it is essential that shareholders wishing to vote submit their proxy forms 
by 14:00 on Saturday, 27 March 2021.  

Shareholders  will  have  the  opportunity  to  ask  questions  prior  to  submitting  their  proxy  votes  at  the  shareholder  update 
presentation on 8 March 2021 as detailed above.  

Resolutions 1 to 9 (inclusive) will be proposed as Ordinary Resolutions and resolutions 10 to 12 (inclusive) will be proposed 
as Special Resolutions. 

Ordinary Business 

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 2020 be received. 

2.  THAT the Directors’ Remuneration Report in respect of the year ended 31 December 2020 be approved. 

3.  THAT John Hustler be re-elected as a Director of the Company.  

4.  THAT Richard Manley be re-elected as a Director of the Company. 

5.  THAT Alex Clarkson be re-elected as a Director of the Company.  

6.  THAT Richard Roth be re-elected as a Director of the Company.  

Biographical  details  for  each  Director  and  their  individual  contributions  to  the  Company  towards  its  long-term  sustainable 
success can be found on page 42 of the Annual Report.  

7.  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. 

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

102 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Special Business 

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

9.  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 shares") up to an aggregate nominal amount 

of £350,000 in connection with offer(s) for subscription; 

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

amount of £80,000; 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 next Annual General Meeting 
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 a Special 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 shares provided that: 

a. 

b. 
c. 

the maximum number of B shares hereby authorised to be purchased is an amount equal to 14.99% of 
the issued B share capital of the Company from time to time; 
the minimum price which may be paid for a B share is 1 pence per share, the nominal amount thereof; 
the maximum price which may be paid for a B share is an amount equal to the higher of: 

i. 

ii. 

105% of the average of the middle market prices shown in the quotations for a B 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  
the amount stipulated by Article 5(6) of Market Abuse Regulation (596/2014/EU);  

d. 

e. 

the authority hereby conferred shall (unless previously renewed or revoked) expire on the earlier of the 
conclusion of the Company’s next Annual General Meeting 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 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 shares in pursuance of any such contract or contracts as if the 
authority conferred hereby had not expired. 

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

11.  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 9 as if section 561(1) of the 
Act did not apply to any such allotments and so that: 

a. 

b. 

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

103 

 
 
 
 
 
 
 
 
 
 
 
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. 

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

12.  ALTERATION TO THE ARTICLES OF ASSOCIATION 

THAT with effect from the conclusion of the meeting the draft articles of association produced to the meeting and, 
for the purposes of identification, initialled by the chairman be adopted as the Articles of Association of the Company 
in substitution for, and to the exclusion of, the Company's existing Articles of Association. 

By order of the Board 
Craig Hunter 
Company Secretary 
22 February 2021 

Notes: 

Registered Office: 
9 The Parks 
Haydock 
WA12 0JQ 

i. 

ii. 

iii. 

iv. 

v. 

vi. 

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. Please note that no shareholders or other persons 
(other than the minimum required to form a quorum as previously explained in this notice) will be permitted to physically attend the 
meeting or vote in person at the meeting due to the Covid-19 pandemic and, therefore, the Board strongly encourages members to appoint 
the chairman of the meeting as their proxy to exercise their right to vote at the meeting in accordance with their instructions.  

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.  

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.  

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. 

CREST members who wish to appoint a proxy or proxies by utilising the CREST electronic proxy appointment service may do so for the AGM and 
any  adjournment(s)  of  it  by  using  the  procedures  described  in  the  CREST  Manual  (available  from  https://www.euroclear.com/site/public/EUI). 
CREST Personal Members or other CREST sponsored members, and those CREST members who have appointed a voting service provider(s), 
should refer to their CREST sponsor or voting service provider(s), who will be able to take the appropriate action on their behalf. In order for a proxy 
appointment made by means of CREST to be valid, the appropriate CREST message (a CREST Proxy Instruction) must be properly authenticated 
in  accordance  with  Euroclear  UK  &  Ireland  Limited's  (EUI)  specifications  and  must  contain  the  information  required  for  such  instructions,  as 
described in the CREST Manual. The message must be transmitted so as to be received by the issuer's agent (CREST ID 7RA11) by 14:00 on 
Saturday, 27 March 2021. For this purpose, the time of receipt will be taken to be the time (as determined by the timestamp applied to the message 
by the CREST Applications Host) from which the issuer's agent is able to retrieve the message by enquiry to CREST in the manner prescribed by 
CREST. CREST members and, where applicable, their CREST sponsors or voting service providers should note that EUI does not make available 
special procedures in CREST for any particular messages. Normal system timings and limitations will therefore apply in relation to the input of 
CREST Proxy Instructions. It is the responsibility of the CREST member concerned to take (or, if the CREST member is a CREST personal member 
or sponsored member or has appointed a voting service provider(s), to procure that his CREST sponsor or voting service provider(s) take(s)) such 
action as shall be necessary to ensure that a message is transmitted by means of the CREST system by any particular time. In this connection, 
CREST members and, where applicable, their CREST sponsors or voting service providers are referred, in particular, to those sections of the 
CREST Manual concerning practical limitations of the CREST system and timings. The Company may treat as invalid a CREST Proxy Instruction 
in  the  circumstances  set  out  in  Regulation  35(5)(a)  of  the  Uncertificated  Securities  Regulations  2001.  Given  that  no  shareholders  or  other 
persons (other than the minimum required to form a quorum as previously explained in this notice) will be permitted to physically attend 
the meeting or vote in person at the meeting due to the Covid-19 pandemic, the Board strongly encourages members to appoint the 
chairman of the meeting, rather than any other person, as their proxy to exercise their right to vote at the meeting in accordance with 
their instructions. 

104 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
vii. 

viii. 

ix. 

x. 

xi. 

A reply-paid Form of Proxy or a reply-paid envelope is enclosed with this document if received by post. 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 or, 
due to the current restrictions as a result of Covid-19, may be emailed to info@nevilleregistrars.co.uk so as to be received not later than 14:00 on 
Saturday, 27 March 2021 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. 

A member can only appoint a proxy using the procedure set out in these notes and the notes to the Form of Proxy. 

As at 19 February 2021 (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 9,062,948 B shares, all of which carry one vote each. Therefore, the total voting rights in the Company as at 19 February 2021 
was 17,178,324. 

Copies of the directors’ letters of appointment, the Register of Directors’ Interests in shares of the Company and copies of the Articles of Association 
of the Company (including a mark-up of the new articles of association proposed to be adopted pursuant to resolution 12) 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. 

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. Given that no shareholders or 
other persons (other than the minimum required to form a quorum as previously explained in this notice) will be permitted to physically 
attend the meeting or vote in person at the meeting due to the Covid-19 pandemic, the Board strongly encourages members to appoint 
the chairman of the meeting, rather than any other person, as their proxy to exercise their right to vote at the meeting in accordance with 
their instructions and not to appoint a corporate representative.   

xii. 

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. 

105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Seneca Growth Capital VCT Plc
9 The Parks
Haydock
WA12 0JQ

www.senecavct.co.uk