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FY2023 Annual Report · STMicroelectronics
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ANNUAL REPORT AND ACCOUNTS 2023 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Page 

Contents 

02 
04 
11 
17 
19 
20 
20 
21 
28 
29 
30 
31 
32 
33 
34 

Chairman’s Statement 
Chief Executive Officer’s Review  
Corporate Governance Report 
Directors’ Report 
Board of Directors 
Statement of Director’s Responsibilities 
Directors’ Remuneration Report 
Independent Auditor’s Report 
Consolidated Statement of Comprehensive Income 
Consolidated Statement of Financial Position 
Company Statement of Financial Position 
Statement of Consolidated Cash Flow 
Statement of Consolidated Changes in Equity 
Statement of Company Changes in Equity 
Notes to the Financial Statements 

1 

 
 
 
 
 
 
 
 
 
 
CHAIRMAN’S STATEMENT 

I am pleased to present to you the STM Group PLC (“STM”) results for the year ended 31st December 2023 - the first 
full year that the newly constituted Board has been in situ.  

Given the embedded value within the Group’s businesses and the backdrop of predictable recurring revenue and 
ongoing profitability, my role as Chair and that of my fellow directors has been to set a strategic course which would 
deliver enhanced shareholder value. This could come about by the introduction of new products and the achievement 
of greater efficiencies or by the orderly break-up or sale of the Group.  

As  announced  in  January  2023,  the  Board  commissioned  an  independent  strategic  review  from  a  third-party 
consultancy company to assess the Group’s operating businesses, identify those with the most potential for future 
profitability  and  recommend  alternative  strategies  for  those  and  the  remaining  businesses  within  the  Group.  The 
results of the review were presented to the Board in March 2023 and concluded that the success of the Group would 
ultimately  be  dependent  on  its  technology  capabilities.  The  review  did  highlight  that  the  anticipated  externally 
realisable value of the various businesses within the Group was significantly more that the market capitalisation of 
the Group at the time. As a result of the strategic review, the Board initiated a technology review as the final input 
required for the Board to determine the strategy going forward.  

However, as well documented in the various market announcements from July 2023 onwards, the Group received 
an initial approach and expression of interest in the Group, which culminated in the announcement of an offer for the 
whole  of  the  issued  and  to  be  issued  share  capital  of  the  Company,  issued  in  accordance  with  Rule  2.7  of  the 
Takeover Code, on 10th October 2023. The offer was to be effected via a Scheme of Arrangement, and the Scheme 
document was issued to shareholders on 9th November 2023. 

Full details of the offer are set out in the CEO’s Review within the Annual Report, but in summary the offeror, Jambo 
SRC Limited (“Jambo’) would acquire the whole STM Group, with the exception of the two SIPP businesses which 
would  exit  by  way  of  a  management  buyout  to  be  completed  immediately  prior  to  the  overall  transaction.  The 
acquisition, once completed, will deliver an up-front 60 pence per share in cash to STM shareholders, with up to a 
further 7 pence per share in deferred contingent consideration  at the one-year anniversary, dependant on certain 
criteria.  

The  Scheme  was  approved  by  99.99%  of  all  independent  Scheme  Shares  voted  and  by  89.5%  of  independent 
Scheme  Shareholders  who  voted  at  an  EGM  held  on  6th  December  2023.  The  transaction  remains  subject  to 
regulatory approval of the proposed change in control of the Group by the Gibraltar and Malta regulators. 

Given the anticipated acquisition by Jambo, and the fact that any dividend declared would be deducted from the final 
consideration under the terms of the Scheme, the Board has taken the decision not to declare a final dividend for 
2023 (2022: 0.60 pence). 

Turning to the performance of the business, I am pleased to confirm that the reported 2023 revenue and underlying 
profit before tax were in line with management’s expectations, although reported profitability was significantly reduced 
as a result of expensing £1.2 million of non-recurring professional advisory costs relating to the potential acquisition 
by Jambo. 

The Group’s recurring revenue continues to provide a predictable base for the Group’s ongoing profitability, and this 
has been bolstered by the additional revenue generated from the new interest sharing policy that was implemented 
for the UK SIPP businesses in July 2023. Similar policies are in the process of being rolled out for the other areas of 
the business.  

I noted in my previous Chairman’s statement that STM was at a cross-roads in its evolution, and that certain parts of 
the business would be difficult to grow or to achieve a full valuation. In this regard, I am delighted to confirm that, on 
14th June 2024, the Group announced it had signed a commercial agreement with Smart Pension Limited (“Smart”), 
and related agreements under which, subject to trustee approval, the members in the Group’s Options master trust 
will transfer to Smart’s master trust. This is likely to generate a consideration of £4.7m payable over the next couple 
of years. In addition, the Group has also signed an introducers agreement with Smart, which will allow for the Group 
to receive introductory fees for new business introduced by STM to Smart.  

2 

 
 
 
Importantly,  the  agreement  allows  STM  to  exit  the  UK  workplace  pension  market,  which  is  becoming  more 
competitive  and  starting  to  be  dominated  by  the  larger  players.  The  transaction  was  undertaken  with  Jambo’s 
consent. 

Finally, my thanks go to all of my STM colleagues for their hard work and commitment during the course of 2023 and 
into 2024. 

I  would  like  to  extend  my  particular  thanks  to  Therese  Neish,  who  left  the  Group  on  31st  May  2024,  for  her 
considerable contribution and dedication to the Group over many years. 

I look forward to updating the market in due course in relation to the change of control approvals from the Malta and 
Gibraltar regulators which, once received, will allow the acquisition by Jambo to conclude and the initial consideration 
of 60 pence per ordinary share to be paid to shareholders. 

Nigel Birrell 
Chairman 
26th June 2024 

3 

 
 
 
 
 
 
CHIEF EXECUTIVE OFFICER’S REVIEW 

Introduction 

The 2023 financial year has been dominated by strategic projects, with the focus in the second half of the year being 
on the initial approach and expression of interest by Jambo SRC Limited (‘Jambo”) in June 2023, which culminated 
in an offer by Jambo for the whole of the issued and to be issued share capital of the Company on 10th  October 
2023, subject to regulatory approval of the change of control in Gibraltar and Malta. The offer was also conditional 
on the UK SIPP businesses completing a management buy-out immediately prior to the Court approval of the Scheme 
of Arrangement (the “Scheme”) by which the acquisition was to be effected, subject to change of control approval in 
the UK.  

The Scheme was approved in an EGM on 6th December 2023 with 99.9% of Scheme shares voting to accept the 
Scheme offer. As at the date of these financial statements, the FCA in the UK has approved the prospective change 
of control of the companies subject to the management buyout, but the approval processes in Gibraltar and Malta 
have yet to be concluded. 

2023  commenced  with  the  appointment  of  third-party  consultants  to  undertake  a  strategic  review  of  the  Group’s 
operation, the results of which were reported to the Board in late March 2023. Further details of the results of the 
review and the impact of the approach and subsequent offer by Jambo on the Board’s conclusions and further actions 
are set out in the Chairman’s Statement. 

Notwithstanding the significant distractions arising from the approach by Jambo, the Group has continued to trade in 
line with management expectations. 

The  continuing  high  percentage  of  annual  recurring  revenue  for  2023,  amounting  to  81%  of  total  revenues, 
underpinned  the  day-to-day  performance  of  the  various  trading  divisions,  and  for  the  latter  part  of  2023  this  was 
supplemented by the new interest sharing policy implemented in the UK SIPP businesses.  

The integration of the Mercer SIPP and SSAS portfolios acquired in September 2022 was successfully completed 
during the course of 2023, and the books of business acquired performed in line with expectations. 

New  business  volumes  remained  generally  disappointing  across  the  Group,  but  this  needs  to  be  viewed  in 
conjunction  with  the  fact  that  certain  areas  of  the  business  would  only  see  better  volumes  upon  an  improved 
technology-based service  offering, and that potential  strategic developments of the Group’s technology  platforms 
have been paused pending the outcome of the Jambo transaction. All strategic projects remain on hold whilst the 
Group awaits the change of control regulatory approvals previously referred to,  

Finance review  

Financial performance in the year 

The principal key performance indicators used by the Board to assess the financial performance of the Group are as 
per Table 1 below.  

The Group reports both basic and adjusted financial key performance indicators in Table 1 and 2 below, as the impact 
of non-recurring movements does not allow for a clear understanding of operating performance without highlighting 
key non-recurring elements. 

The Group reported revenues of £28.1 million for 2023 (2022: £24.1 million). The 17% uplift in revenues over 2022 
is largely attributable to a full year’s revenue contribution from the 2022 acquisition of the SIPP and SSAS books 
from Mercer, which contributed £2.3 million in additional revenues, and the additional £3.2 million interest income 
earned as a result of the new SIPP interest sharing policy. This offset the shortfalls in new business revenues across 
the Group. 

Profit before other items on both a reported and adjusted basis for 2023, was £3.2 million and £5.8 million respectively 
(£3.3 million and £4.7 million respectively), and the latter represented a healthy uplift compared to 2022.  

4 

 
 
 
The uplift in adjusted profit before other items over 2022 was principally due to the impact of the client interest sharing 
policy incepted in the SIPP businesses in July 2023 which flowed through to the bottom line.  

On a like-for-like basis, adjusted profit before tax was similar to the previous year, with 2023 showing £3.1 million 
(2022 £2.8 million), although on a statutory basis the pre-tax result for 2023 was significantly lower at £0.4 million 
(2022 £1.6 million). This reduction was primarily driven by the one-off, non-recurring professional advisory and legal 
fees of £1.2 million incurred in relation to the proposed acquisition of the Company by Jambo. 

In addition, as set out below in Table 2, there were a number of non-recurring income and expense items that are 
added back to the reported measure for Profit Before Tax so as to give a better picture of the operating performance 
of the business. For 2023, this included £0.6 million (2022: £Nil) of deferred consideration and old debtors previously 
recognised  in  the  sale  of  the  Company  Management  and  Trustee  Services  businesses  in  2021,  £0.2  million  of 
deferred  consideration  previously  recognised  on  the  Berkeley  Burke  and  Mercer  acquisitions  in  2020  and  2022 
respectively that were ultimately not deemed to be recoverable (2022: £Nil), £0.5 million (2022: £0.5 million) of one-
off costs in relation to management restructuring and legal costs and £0.1 million (2022: £Nil) advisory fees paid for 
the independent strategic review undertaken in the first part of the year. 

5 

 
 
 
 
Table 1 

KPI 

Revenue 
(£’000s) 

Recurring 
revenue 
(£’000s) 

Definition 

Income derived from the 
provision of services. 

Revenue  derived  from  annual 
management  charges  and/or 
contractual 
fee 
agreements. 

fixed 

2023 
(reported) 
28,078 

2022 
(reported) 
24,094 

2023 
(adjusted) 
28,078 

2022 
(adjusted) 
24,599 

22,686 

22,219 

22,686 

22,219 

Interest income 
(£’000s) 

Interest  earned 
the 
Group’s  and  customer  cash 
balances 

from 

3,740 

531 

3,740 

531 

Profit before 
other items 
(£’000s) 

Profit before 
taxation 
(£’000s) 

Profit after 
taxation 
(£’000s) 

Earnings per 
share (pence) 

Profit margin 
before other 
items (%)  

less  administrative 
Revenue 
expenses 
i.e.  profit  before 
finance income and costs, gain 
on  disposal  of  subsidiary 
bargain purchase gain, goodwill 
impairment and gain on the call 
options and before taxation. 

Revenue 
expenses and other items  

less  administrative 

less  administrative 
Revenue 
expenses  and  other 
items 
less/add taxation charge/credit 

Profit  after  taxation  attributable 
to shareholder of the Company 
divided  by  weighted  average 
number  of  ordinary  shares 
outstanding  
Profit before other items 
divided by revenue. 

3,200 

3,321 

5,824 

4,686 

442 

1,578 

3,066 

2,778 

417 

854 

3,041 

2,054 

0.70 

1.42 

5.12 

3.44 

11% 

14% 

21% 

19% 

Adjusted measures are net of non-recurring costs and other exceptional items that do not form part of the normal 
course of business. 

6 

 
 
 
 
 
 
Table 2 

Revenue 

Profit before 
  other items 

Profit before tax 

2023 

2022 

2023 

2022 

2023 

2022 

£'000s 

£'000s 

£'000s 

£'000s 

£'000s 

£'000s 

Reported measure 

28,078 

24,094 

3,200 

3,321 

442 

1,578 

Add: adjustment due to revenue 
recognition  policy  change  on 
acquisition 

Add:  integration  and  acquisition 
cost 

Add: Project Atlantic professional 
costs 

Less: bargain purchase gain on 
acquisition and gain on call 
options 

Less: loss on disposal of 
companies and trust 
management 

Less: movement in deferred 
consideration related to prior 
year acquisitions 

Add: costs of strategic review 

Add: other non-recurring costs 

– 

– 

– 

– 

– 

– 

– 

Adjusted measure 

28,078 

24,599 

Tax Charge and Earnings per Share 

505 

– 

– 

– 

505 

390 

– 

– 

1,202 

– 

1,202 

– 

– 

– 

– 

– 

– 

761 

135 

– 

– 

– 

– 

– 

– 

– 

761 

135 

526 

5,824 

470 

526 

4,686 

3,066 

470 

2,778 

505 

390 

– 

(327) 

162 

– 

– 

The tax charge for the year was £0.03 million (2022: £0.7 million). This was an effective tax rate of 6% (2022: 46%), 
which was lower than the rates noted in prior years due to the writeback of tax over provided for in prior years. In the 
year ended 31st December 2022, the Group’s effective tax rate was higher than the jurisdictional effective tax rate, 
as tax  losses brought forward or  incurred in that year in some jurisdictions could not be utilised by  the profitable 
subsidiaries in other jurisdictions and dividends remitted to the holding company by overseas jurisdictions were higher 
than in prior years, thus resulting in a higher overall tax charge. 

Earnings per share (“EPS”) for 2023 were 0.7 pence per ordinary share compared to 1.42 pence per ordinary share 
in 2022. The decrease was a direct result of the lower profit before tax as explained above. There were no dilutive 
factors in either 2023 or 2022. 

Cashflows and Balance Sheet 

Cash and cash equivalents amounted to £18.4 million as at 31st December 2023 (2022: £19.2 million), with net cash 
inflow from operating activities of £2.5 million for the year ended 31st December 2023 (2022: £5.3m).  

The bank loan from RBSI, drawn down in 2021 and 2022 to finance the acquisition of the SIPP and SSAS books 
from Mercer, remained in place as at 31st December 2023. As at the year end the outstanding balance on the facility 
was £4.8 million (2022: £5.4 million). 

Cash and cash equivalents, net of the above mentioned outstanding bank loan, as at 31st December 2023 amounted 
to £13.6 million (2022: £13.9 million). 

7 

 
  
  
 
 
 
 
As would be expected for a Group regulated in several jurisdictions, a significant proportion of the gross cash balance 
is required to underpin the regulatory capital and solvency requirements.  

The cash and cash equivalents required for solvency purposes varies as other, non-cash, assets can be used to 
support  the  regulatory  solvency  requirement.  The  total  regulatory  capital  requirement  across  the  Group  as  at 
31st December 2023 was £17.3 million (2022: £17.3 million).  

As further disclosed in the notes to the financial statements, the Carey (“Options”) v Adams case came to a conclusion 
in 2022 and was settled during the course of that year. During the course of 2023 it was therefore possible to quantify 
the likely exposure to similar cases with the same profile. In a similar manner, but in an unrelated case, Options was 
unsuccessful in the Judicial review hearing of a previously determined case by the Financial Ombudsman Scheme.  

As a result, this case has been settled by the professional indemnity insurers, and cases with similar characteristics 
have now been provided for as at 31st December 2023. Whilst a provision has been established for the estimated 
likely amounts payable in relation to such claims, the Group has recognised an asset equal to an equivalent recovery 
of  such  exposure  from  the  Group’s  professional  indemnity  insurers,  such  that  the  net  assets  indicated  in  the 
consolidated statement of financial position are not affected. Further details in relation to the provisions held are set 
out in note 28 to the financial statements. 

Within the consolidated statement of financial position, the Group recognised accrued income in the form of work 
performed for clients but not yet billed, as well as accrued interest income, of £3.1 million as at 31st December 2023 
(2022:  £0.9  million).  Additionally,  deferred  income  (included  within  current  liabilities  in  the  statement  of  financial 
position), relating to annual fees  invoiced  but not yet  earned,  amounted  to  £3.7  million (2022: £3.8  million). Both 
these figures give good visibility of cash collections and, in the case of deferred income, revenue still to be earned 
through the Income Statement in the coming months.   

Dividend  

The Board is not proposing a final dividend (2022: 0.60 pence per ordinary share), as, under the terms of the Scheme 
offer, any dividend declared would be deducted from the overall consideration payable by Jambo in respect of the 
potential  acquisition,  with  potential  adverse  tax  consequences  for  shareholders.  As  a  result,  the  total  proposed 
dividend for 2023 amounted to Nil pence per ordinary share (2022: 1.20 pence per ordinary share).  

Operational Performance 

Pensions  

The Group’s pension administration businesses continue to be the largest revenue generating stream, accounting 
for 84% of total Group revenues (2021: 77%), excluding interest earned on client interest sharing policy.  

Total revenue, excluding interest on client funds, across the Group’s pension businesses amounted to £20.4 million 
(2022: £18.5 million). The full year of the Mercer SIPP and SSAS acquisition during 2022 contributed £2.8 million of 
revenue in 2023 (2022: £0.5 million in 4 months).  

In addition to the above pension administration revenue, the Pensions division also benefited from the increase in 
market interest rates and the implementation of its interest sharing policy within the Group’s SIPP businesses, which 
was incepted in July 2023 to bring the Group’s policy in line with market norms. Across the whole of the pension 
division, interest income for 2023 amounted to £3.0 million (2022: £0.3 million). 68% of this amount (2022: 86%) was 
attributable to the SIPP businesses.   

The administration of the Group’s QROPS products continues to be the largest revenue generator within the pensions 
division, accounting for £9.0 million of revenue (2022: £9.4 million) and remains a robust and predictable revenue 
stream.  Since  the  UK  pension  legislation  changes  in  2017,  these  products  are  no  longer  a  growth  driver.  There 
remains  a  small  net  attrition  rate  on  the  QROPS  book  which  is  expected  to  continue  as  the  member  age  profile 
gradually  increases  and  members  look  to  take  advantage  of  flexi-access  benefits.  The  administration  of  such 
schemes is undertaken in Malta and Gibraltar. 

8 

 
 
 
The SIPP businesses, both Options Personal Pensions and London & Colonial Services Limited, contributed total 
pension administration revenues of £4.7 million in 2023 (2022: £4.1 million). As noted above, the increase is down 
to the full year benefit of the Mercer SIPP book of business acquired in September 2022. 

The Group’s Options Corporate pension auto-enrolment business generated revenue of £4.1 million in 2023 (2022: 
£3.4 million) and has performed as expected in a relatively mature marketplace.  

The  final  revenue  stream  of  the  pensions  divisions  comes  from  the  SSAS  and  EBC  third-party  administration 
businesses. These contributed revenues of £2.7 million in 2023 (2022: £1.6 million), with the uplift again being down 
to a full year contribution from the Mercer SSAS book acquired in September 2022. 

Life Assurance 

The  combined  revenues  of  the  two  life  assurances  businesses  in  Gibraltar  was  £4.0  million  in  2023  (2022:  £5.0 
million). Those businesses did not generate any new business revenues from the Group’s short term annuity product, 
which had contributed circa £0.8 million of revenue in 2022.  

The main products for the life companies remain the flexible annuity products for both private wealth and pension 
solutions. Whilst there has been a small increase in illustrations requested and provided during 2023, disappointingly 
we have not seen conversions increase, and the Group has struggled to broaden the range of IFAs that utilise the 
products.  

During the latter part of the year, the life companies revisited the pricing of the flexible annuity products and capped 
the establishment fee. Whilst this potentially reduces any upfront fees, it is anticipated that this will make the product 
more compelling and attractive to the larger potential policyholders.  

The Group retains its intention to broaden the range of products that will be available through the two life companies, 
and it is expected that over time this should  allow stronger organic growth. However, part of that strategy  will be 
reliant on the finalisation of the technology review instigated as part of the strategic review but subsequently deferred 
in the light of the proposed acquisition of the Company by Jambo which would determine what systems could and 
should be used as the main administration platform for the Group. 

Regulatory developments – Consumer Duty 

The Consumer Duty rules introduced by the Financial Conduct Authority in the UK came into effect on 31st July 
2023. 

These rules require regulated firms to act to deliver good outcomes for retail customers. 

These outcomes relate to: 

•  Products and services; 
•  Price and value; 
•  Consumer understanding; and 
•  Consumer support. 

The new rules require firms to consider the needs, characteristics and objectives of their customers – including 
those with characteristics of vulnerability – and how they behave, at every stage of the customer journey. As well 
as acting to deliver good customer outcomes, firms will need to understand and evidence whether those outcomes 
are being met.   

They apply to all UK retail customers, whether serviced by firms based in the UK or in other jurisdictions such as 
Gibraltar. 

The Group recognised the importance of the new rules and established a project group to identify the key factors to 
be considered in assessing the rules, develop new or amended rules and processes (including data gathering) to 
enable the Group to comply with its Consumer Duty obligations and to oversee such compliance. 

The 31st July 2023 deadline was met in all material aspects, with some minor additional processes and procedures 
being identified for future development. 

The process is ongoing and the Group continues to prioritise the delivery of good outcomes for its retail customers. 

9 

 
  
  
  
  
  
  
  
  
Outlook  

The future direction of the STM Group is currently awaiting the outcome of the applications by Jambo to the Gibraltar 
and Maltese regulatory authorities for change of control approvals pursuant to the proposed acquisition by Jambo of 
the whole of the issued share capital of the Company, and to sanction the completion of the transaction that was 
approved by 99.99 % of Scheme shares voted on 6th December 2023.  

In the meantime, other than the potential exit strategy of the Options master trust from the UK workplace pensions 
marketplace, which had been agreed by both the PLC Board and the potential acquirer as set out in the Scheme 
document, there is minimal ability to make strategic decisions on the business.  

On 14th June 2024, the Board announced that the Group had signed a commercial agreement with Smart Pension 
Limited in which, subject to approval by the trustees and regulator, members transferring from Options Master trust 
to Smart would result in Smart paying a consideration to the Group. It is anticipated that, over a two-year period, this 
consideration  is  likely  to  amount  to  circa  £4.7million.  In  addition,  the  Group  also  entered  into  an  introducers 
agreement with Smart at the same time, whereby any new members introduced to Smart by the Group’s existing or 
new intermediary contacts would lead to introductory commission income for the Group. The agreement is in place 
for a maximum period of three years, and management estimates that the quantum of such additional introductory 
commission could lie in the range of £1.0 million to £5.0 million over the three-year period. 

Notwithstanding  the above, the Group’s businesses continue to perform  in  line  with expectations, and  underlying 
performance for 2024 will continue to benefit from the interest sharing policies for the SIPP businesses that were 
implemented in the second half of 2023.  

Interest sharing policies for the other parts of the  Group have now been agreed, and these are in the process of 
being rolled out. It is anticipated that this will provide additional contribution for 2024, although, given the ongoing 
uncertainty  around  market  interest  rates,  it  is  not  possible  to  forecast  any  incremental  contribution  over  market 
expectations with any material degree of accuracy 

Whilst the technology review referred to above remains on hold as a result of the offer by Jambo, that process will 
need to be recommenced once the potential acquisition has been approved by the regulators in Malta and Gibraltar.  

As noted in my 2022 report, the outcome of any technology reviews will no doubt determine the strategy that the Plc 
board will take going forward. The UK and expatriate pension space remains buoyant and exciting, with opportunities 
to differentiate the business from industry peers, but only if the technology can support a self-serve administration 
process.  

I would like to take this opportunity to thank all my STM colleagues, and particularly Therese Neish, who returned as 
interim CFO on a fixed-term contract which was expected to see the conclusion of the acquisition, for their continued 
hard work and professionalism in carrying out their duties. 

The Board looks forward to updating you on the progress of the proposed acquisition of the Company by Jambo in 
due course. 

Alan Kentish 
Chief Executive Officer 
26th June 2024 

10 

 
  
 
 
 
CORPORATE GOVERNANCE REPORT 

The Board is responsible for establishing and monitoring the strategic direction and performance of the Group, within 
a framework of prudent controls.   

STM has formally adopted the Quoted Companies Alliance Corporate Governance Code (the “Code”) and remained 
compliant with the Code throughout 2023 except that the Company did not have a quorate Audit & Risk Committee 
from 1st May 2023, as there were only two non-executive directors from that date whereas the quorate number for 
that Committee is three. During the period from 1st May 2023 on, the work of the Group’s Audit & Risk Committee 
was overseen and, where appropriate, undertaken by the full Board of Directors. This report sets out below how the 
Directors have applied the principles, and the spirit, of the Code.    

STRATEGY  

STM’s overarching strategy is to be the pensions and life assurance provider of choice in our chosen markets, being 
UK citizens who have or had a UK company pension scheme and have either moved overseas or remain in the UK.  
Through organic growth, product development and targeted acquisitions, the Group has continued to leverage our 
reputation for product innovation and service to build sustainable, recurring revenues within a framework of sound 
governance and risk management.  

The Group’s business model has been to:  

• 
• 

• 
• 
• 

• 

• 

• 

provide a range of innovative pension solutions to customers across our target markets.  
promote the Group’s Pensions Administration service and associated Life Assurance products to internationally 
mobile individuals with a focus on those that have previously worked in the UK.  
focus on high growth, well-regulated markets.   
operate the highest levels of service to both our customers and financial intermediaries in all jurisdictions.  
to embed a culture of customer service, compliance and sound internal controls to build a sustainable, ethical 
business.  
differentiate from UK competitors by being able to effectively operate within the more complex requirements of 
the UK expatriate market.  
differentiate 
product/jurisdictional offering.  
to identify and promote products, through the Group’s intermediary partners, to UK residents.  

levels,  and  a  more  comprehensive 

international  competitors 

through  service 

from 

During  the  first  half  of  2023  the  Board  recognised  that,  whist  it  has  a  wide  range  of  products  and  services,  it  is 
important to focus on the areas that have the potential to deliver step-change in profitability. As such it started the 
process of reviewing and challenging the strategy for the next three to five years by engaging with external advisors 
who carried out an independent review to identify areas to focus on. The Board assessed these recommendations 
and started the process of refining the strategy.  

The strategic review process required a review of the areas of the business that were not likely to materially grow in 
revenue  and  profitability  in  the  short  to  medium  term,  with  a  view  to  conducting  a  staged  realisation  programme 
where appropriate. As such the Board had already commenced the process of  examining options for the Options 
Workplace Pension Master Trust, the auto-enrolment vehicle which is administered by  the Group’s wholly owned 
subsidiary, Options Corporate Pensions UK Limited.  

The strategic review was put on hold during the summer following an approach by Jambo SRC Limited (“Jambo”) to 
acquire  the  entire  issued  and  to  be  issued  ordinary  share  capital  of  STM.  On  10th  October  2023,  the  boards  of 
directors of both STM and Jambo announced that they had agreed the terms and conditions of a recommended cash 
acquisition  by Jambo of STM (the "Acquisition"). It is intended that the Acquisition will be effected by means of a 
scheme of arrangement under Part X of the Isle of Man Companies Act 2006 (the "Scheme").   

The Board recognised that, whilst there were significant growth and value realisation opportunities for the Group in 
the  short  to  medium  term,  there  were  also  uncertainties  and  risks  which  may  impact  the  Group’s  ability  to  both 
optimise growth as a standalone quoted entity, and to execute a realisation strategy of certain parts of the business. 
The Board further acknowledged that there were additional commercial benefits which could be obtained as part of 
a  larger  group  with  a  clear  vision  to  deliver  a  complete  solution  to  pension  savers  and  members.  As  such  it 
recommended the acquisition to STM’s shareholders.  

Further details of the strategic review and the proposed Acquisition of STM by Jambo are set out in the Chairman’s 
Statement and the CEO’s Review within the Annual Report. 

11 

 
  
  
  
  
  
  
  
 
 
 
 
 
RISK MANAGEMENT  

The  Board  is  ultimately  responsible  for  the  Group’s  risk  management  framework.  Setting  strategy  includes 
determining the extent of exposure to the identified risks that the Group is able to bear and willing to take.  

The  Group  operates  a  formal  risk  management  framework  which  has  been  embedded  across  the  Group  and  is 
overseen and monitored by the Board. In addition, the Board has adopted a formal risk appetite statement against 
which our strategy, business model and capital projects are tested and assessed.   

The  risk  management  function  oversees  the  risk  management  framework  day  to  day  and  is  responsible  for  the 
implementation of risk management policies and processes throughout the Group. The compliance function in each 
jurisdiction provides assurance to the Group Audit & Risk Committee on regulatory and reputational risk through the 
completion of an annual compliance monitoring plan.   

The Audit and Risk Committee generally meets not less than four times a year and reports to the Board on risk across 
the Group. As noted above, in the particular circumstances of the proposed acquisition of the Group by Jambo SRC, 
risk matters have been considered by the full Board during 2023. 

Further  assurance  that  risk  management  processes  are  embedded  and  operating  effectively  is  achieved  via  the 
internal audit function, which is itself supported by specialist co-sourced audit consultants and overseen by the Audit 
and Risk Committee.  

The  Board has carried  out an  assessment  of the  principal risks facing the Group and have concluded  that these 
remain materially as applied in prior years, namely: 

Area  

Description of risk  

Examples  of  mitigating  activities  and 
factors  

Change 
year  

from  prior 

Distribution 
and market 
demographics  

Our markets are serviced by a 
limited number of 
intermediaries and product 
providers thus creating a 
competitive environment.   

Reputational 
risk  

A circumstance could arise 
which would adversely impact 
on the Group’s reputation, 
including adverse publicity 
from the activities of 
legislators, pressure groups 
and the media.  

•  Appointment of Group Business 

No change  

Development Director in March 2023 and 
further expansion of this team in Q4 of 
2023. 

•  Strong focus on intermediary liaison and 

customer experience  
Innovative product development  
Loyal intermediary base  

• 
• 
•  Board review of regulatory and business 

changes  

•  High level of compliance in product and 

service delivery  

•  Putting the customer at the heart of 

decision-making processes  
•  Retained financial PR and media 

relations consultancy to provide ongoing 
support and media contact.  

No change  

12 

 
 
 
  
  
  
 
 
 
  
  
 
 
Area  

Description of risk  

Examples  of  mitigating  activities  and 
factors  

Change 
year  

from  prior 

Regulatory 
Risk  

Loss arising from regulatory 
changes in the markets within 
which the Group operates or 
breach of existing laws and 
regulation.   

Key personnel   The Group could be adversely 
affected if there was a loss of 
key personnel or an inability to 
recruit individual with the 
appropriate skills set.  

Geopolitical 
risks  

Non-
performing 
investments  

The Group could be adversely 
affected by changes in existing 
legislation, fiscal policy or 
political factors.  

The Group recognises that the 
UK SIPP industry is becoming 
more litigious over non-
performing assets and that 
STM also has an exposure to 
QROPS’ non-performing 
assets. The Group could 
therefore be adversely affected 
by this. The market for 
professional indemnity 
insurance continues to 
contract. 

No change but 
regulatory environment 
in the UK continues to 
tighten with increased 
scrutiny from the 
Financial Services 
Ombudsman and the 
Financial Conduct 
Authority (“FCA”) 
(including the 
Consumer Duty 
obligations introduced 
by the FCA becoming 
effective from 31st July 
2023 – see further 
comments in CEO’s 
Review) 

No change – the Board 
recognises that whilst 
there is currently no 
CFO in place there are 
measures in place to 
ensure the finance 
function remains 
effective with 
appropriate oversight at 
Board level. 
No material change.   

No material changes in 
quantum of non-
performing assets. 
Legal and regulatory 
environment continues 
to tighten.   

•  Subsidiary Boards with experience in 

regulated businesses  

•  Dedicated Compliance function, 
supported by specialist external 
consultants in the UK and Gibraltar 

•  Completion of an annual compliance 

monitoring plan  

•  Risk Management monitors legislative 
changes and supports jurisdictional 
compliance functions as required  

•  Expert third-party legal and / or 

compliance advice is sought where 
necessary  

•  All companies comply with the respective 

jurisdiction’s solvency capital 
requirements  

•  Action plan developed and implemented 

to enable the Group to fulfil its 
obligations under the Consumer Duty 
rules introduced by the Financial 
Conduct Authority in the UK, which 
became effective from 31st July 2023 

• 

The Group offers competitive 
remuneration packages   

•  Succession planning  
• 

The Group provides appropriate training 
for staff and management  
The Group promotes a favourable work 
environment to retain and attract staff  

• 

• 

The Group is diversified in both its 
product range and the jurisdictions from 
which it administers them   

•  No material exposure to sanctioned 

• 

markets or individuals  
The Group does not provide financial or 
investment advice to its customers   

•  Adherence to regulatory requirements 

and appropriate due diligence 
procedures expected of a trustee for 
onboarding intermediaries and 
customers.  

•  Professional indemnity insurance in 

place.  

13 

 
  
  
  
  
 
 
Area  

Description of risk  

Examples  of  mitigating  activities  and 
factors  

Change 
year  

from  prior 

Technology 
disruption  

The Group could suffer 
operational disruption in the 
event of technology disruption 
such as a cyber-attack or 
hardware failure.  

Climate risk  

Climate risk is the risk of 
adverse impacts on the 
Group’s business caused by 
climate change  

•  Significant and ongoing investment in IT 

systems 

•  Cyber Essentials accreditation  
•  Migration of key business applications 
into the Cloud as well as flexible 
provisioning allowing STM to scale 
up/down when needed  

•  Ongoing management of deployment 

and maintenance of Microsoft 
applications to enable the Group to 
continue to function effectively 
notwithstanding local or wider disruption. 
•  Periodic testing to identify vulnerabilities 

and deliver improvements  

•  Detailed disaster recovery and business 

• 

continuity plans in place.  
Increased awareness of climate related 
risks, policies, business impact and 
disclosure requirements.  

Cyber threat has 
intensified. Steps taken 
to mitigate risk, 
particularly around 
remote working 
practices.  

No material change.  

Financial risks   The Group has exposure to 
the following financial risks:  

These risks are addressed within Note 25 of 
the financial statements   

No material change.  

Liquidity risk  

•  Credit risk  
• 
•  Market risk  
• 
•  Currency risk  

Interest rate risk   

LEADERSHIP  

The Board is responsible to shareholders for the proper management and governance of the Group. It is responsible 
for  strategic  planning,  business  acquisitions  and  disposals,  risk  management,  authorisation  of  major  capital 
expenditure  and  material  contractual  arrangements,  setting  policies  for  the  conduct  of  business  and  approval  of 
budgets and financial statements.   

The Chairman is responsible for over-seeing the development and implementation of the Company’s strategy, its 
governance framework and Board effectiveness. The Chief Executive is responsible for delivery of the strategy and 
the  day-to-day  management  of  the  Group  by  the  senior  executive  team.  The  Board  is  committed  to  continually 
developing the corporate governance and management structures of the Group to ensure they adapt to the changing 
needs of the business. The non-executive directors are considered by the Board to be independent of management 
and free from any relationship which might materially interfere with the exercise of independent judgment.   

The non-executive directors provide independent oversight and challenge to the Board and bring experience at a 
senior  level  of  business  operations  and  strategy.  During  the  year  the  Company  Secretary  was  responsible  for 
ensuring that Board procedures were observed and the Company’s obligations as an AIM listed entity on the London 
Stock Exchange were met.  Whilst the Board acknowledges that the Company Secretary left the business on 31 st 
December 2023, it remains confident that there are measures and resources in place to ensure that the obligations 
of the Company continue to be met. 

The profiles of the individual board members can be viewed on page 20.  

The Board comprises an appropriate balance of industry, finance and public market skills and experience, as well as 
an  appropriate  balance  of  personal  qualities  and  capabilities  to  successfully  oversee  and  challenge  the  Group’s 
strategy. The Group fully supports and funds any training, formal or otherwise, that is required by any individual Board 
member so as to ensure that their knowledge and experience remains relevant and effective.   

14 

 
  
  
  
  
  
  
  
 
 
BOARD EFFECTIVENESS   

An internal review of Board effectiveness, led by the then Chairman, was carried out in February 2021 by means of 
a  questionnaire  and  one-to-one  sessions.  The  findings  were  considered  and  implemented.  Given  the  number  of 
Board changes in 2022 and 2023, as well as the pending acquisition, no review exercise was undertaken during the 
year or to date.  

CULTURE  

The Board promotes a culture that is based on sound ethical values, standards and behaviours. This culture is visible 
in  the  Board’s  actions  and  decisions,  as  well  as  those  of  the  executives  and  senior  management  team.  These 
corporate values guide the objectives and strategy of the business and form the backbone of our Code of Conduct 
policy. Our long-term growth expectations are underpinned by the principles within this Code of Conduct.   

The Group promotes a ‘customer first’ ethos which is at the heart of decision-making processes, aligned to a positive 
and proactive relationship with our stakeholders.  

This  culture  has  been  communicated  to  all  employees  and  is  reinforced  by  the  training  program  which  all  staff 
participate in. This starts with the Code of Conduct forming part of any new member of staff’s induction program, and 
the application of the Code of Conduct is considered as part of all STM employees’ annual appraisal process.  

GOVERNANCE  

During the year the Board comprised two executive and, since the resignation of Graham Kettleborough as a non-
executive  director  in  April  2023,  two  independent  non-executive  directors  (including  the  Chairman).  The  Board 
acknowledges that there is now no Chief Financial Officer in place since Therese Neish stepped down on 31st May 
2024. However, it remains confident that it has the resources in place to ensure the business and the finance function 
continue being run effectively during the current period until the acquisition completes. 

The independence of directors is assessed periodically as part of the Board evaluation process. All non-executive 
directors have been appointed from outside the Group and are considered independent as defined by the Code.   

The Board meets bi-monthly throughout the year, or more frequently if appropriate. To enable the Board to discharge 
its duties, all directors receive appropriate and timely information. Briefing papers are  distributed to all directors in 
advance of the Board meetings. There is a formal agenda followed at all Board meetings which ensures discussions 
and decisions to be made on all strategic, financial and operational matters affecting the business.  

The Board has established an Audit & Risk Committee and a Remuneration Committee, both with formally delegated 
duties and responsibilities. The Directors do not consider that, given the size of the Board, it is necessary at this 
stage to have a Nomination Committee. Succession planning is carried out by the Board. In the absence of a fully 
quorate Audit & Risk Committee, the full Board continues to  meet and discharge its duties on such  matters. The 
Remuneration Committee comprises both the non-executive directors, with Nigel Birrell acting as Chairman.   

The Board had commenced recruitment processes for an additional independent Non-Executive Director and a 
new Chief Finance Officer during the first half of 2023, following Graham Kettleborough’s notification of his intention 
to resign as a director on 28th April 2023 and Therese Neish’s confirmation that she would not seek to extend her 
then fixed term contract beyond 2nd October 2023 (subsequently extended to 31st May 2024). 

The processes were suspended following the approach and subsequent offer by Jambo. Should the proposed 
acquisition by Jambo not take place, the Board would recommence the recruitment processes in order to recruit a 
new Chief Finance Officer and an additional independent Non-Executive Director as soon as possible. Once 
completed, the Audit & Risk and Remuneration Committee would again become quorate. 

AUDIT & RISK COMMITTEE  

The Audit & Risk Committee reviews the integrity of the financial statements of the Group, announcements relating 
to  financial  performance,  accounting  policies,  the  application  of  critical  accounting  judgments  and  practices,  the 
operation of internal controls and the effectiveness of the financial reporting policies and systems. It is responsible 
each year for satisfying itself on the independence and objectivity of external auditor, agreeing the audit plan and the 
level of audit fee.  The Audit & Risk Committee ordinarily meets at least four times a year and at such other times as 
the Chairman of the Committee sees fit. The Chairman of the Committee is appointed by the Board.  

During 2023, the Audit & Risk Committee met on two occasions, with ongoing risk monitoring being undertaken in 
conjunction with the full Board as noted above.  

15 

 
  
  
  
  
  
  
  
 
  
  
  
 
 
  
  
The  Committee  and  the  Board  continued  to  monitor  the  Group’s  risk  appetite  and  risk  framework,  its  policies, 
methodologies, systems, processes and procedures, through a three-lines of defence model. The first line being the 
business systems and controls in place to prevent and detect errors, the second provided by compliance monitoring 
and the third by  internal audit review. The Group’s risk and compliance capabilities continue to evolve,  providing 
local-level management and Group level oversight. 

The Audit & Risk Committee has primary responsibility for the Group’s Risk Appetite Statement which sets out the 
Group’s  attitude  to  risk  and  the  limits  of  acceptable  risk  taking.  The  Committee  has  established  the  high-level 
qualitative Risk Appetite Statement for the Group and requires the Subsidiaries to link their own Risk Appetite to the 
Group. The subsidiaries are required to identify and manage Key Risk Indicators. The statement is subject to annual 
review by the Audit & Risk Committee and the Group Board. The Committee makes recommendations to the Board 
in respect of any risks faced by the Group outside of its declared risk appetite.  

As noted above, as the Audit & Risk Committee has not been quorate since 30th April 2023, the Board acknowledged 
the position and has overseen and, where appropriate, discharged these responsibilities on behalf of the Committee. 

The  Audit & Risk Committee  is responsible for the  Risk Framework with all risks identified being recorded in the 
Corporate Risk Register and reviewed by the Committee on a biannual basis.  

REMUNERATION COMMITTEE  

The duties of the Committee are to:  

• 

• 

• 
• 
• 

determine and agree with the Board the policy for the remuneration of the Chairman, Executive Directors and 
other members of the Group Executive team.  
determine  individual  remuneration  packages  including  bonuses,  incentive  payments,  share  options  and  any 
other benefits.  
determine the contractual terms on termination and individual termination payment.  
be informed of and advise on changes in benefit structures in the Group; and  
agree the policy for approving expense claims of the Chief Executive and the Chairman of the Board.  

The Committee ordinarily meets at least twice in each year and at such other times as the Chairman of the Committee 
sees fit. The Chairman of the Committee is appointed by the Board.   

The Committee met twice in 2023. Key areas of focus included the extension of the CFO’s fixed term contract and 
the retention arrangements for the proposed acquisition of the Company. 

Directors’ attendance at scheduled meetings of the Board and its Committees that they were eligible to attend during 
2023 is shown below: 

Nigel Birrell 

Alan Kentish   
Therese Neish 
Peter Smith[1] 
Graham Kettleborough [2] 

Board  

Audit & Risk   

Remuneration   

14/14 

14/14 
13/14 
13/13 
5/5 

2/2 

- 
- 
2/2 
2/2 

2/2 

- 
- 
2/2 
2/2 

[1] Peter Smith was appointed on 26th January 2023 
[2] Graham Kettleborough resigned with effect from 30th April 2023 

Peter Smith 
Non-Executive Director 
26th June 2024 

16 

 
   
 
  
  
  
  
 
  
  
 
 
  
  
 
 
 
 
 
DIRECTORS’ REPORT  

The Directors of STM Group PLC present their Annual Report together with the financial statements of the Group 
and the Company and the independent auditors’ report for the year ended 31st December 2023. These will be laid 
before the shareholders at the Annual General Meeting, details of which will be sent to shareholders in due course.  

Principal activities and business review  
The principal activity of the Group during the year was the provision of UK and international retirement solutions and 
life  assurance  products.  A  review  of  the  business  performance  during  the  year  ended  31st  December  2023  is 
contained in the CEO’s Review within the Annual Report. 

Result and dividends  
The retained profit for the financial year of £417,000 (2022: £854,000) has been transferred to reserves.   

The final dividend for the year ended 31st December 2022 of 0.60 pence per ordinary share (£356,000 in aggregate) 
was paid during the year. No interim dividend was declared or paid in respect of the year ended 31st December 2023 
(2022: 0.60 pence per ordinary share) and the Directors do not recommend any dividend for the year (2022: 0.60 
pence per ordinary share). This is consistent with the terms of the offer, via a Scheme of Arrangement, by Jambo 
SRC Limited for the whole of the issued and to be issued share capital of the Company announced on 10th October 
2023 and approved by the Company’s shareholders on 6th December 2023. 

Going Concern  
The Directors have prepared the financial statements on a going concern basis, as in their opinion the Group is able 
to meet its obligations as they fall due for a period of at least 12 months from the date of this report. In considering 
this requirement, the Directors have considered the three-year business plan, three-year budgets and rolling cashflow 
forecasts for the forthcoming 18-month period and the level of professional indemnity insurance held by the Group 
and the indemnity related to the UK SIPP claims. These show that the Group should continue to be cash generative, 
and have sufficient resources to meet its business objectives, both in the short-term and in relation to its strategic 
priorities.   

Having due regard to these matters, the Directors have a reasonable expectation that the Group and Company have 
adequate resources to continue in operational existence for at least 12 months from the date on which the financial 
statements were approved and signed. As such, the Board continues to adopt the going concern basis in preparing 
the financial statements.  

The  ongoing  Russian  invasion  of  Ukraine  has  led  to  the  imposition  of  economic  and  other  sanctions  against  the 
Russian state, businesses, and certain personnel. But for the impact on monetary policy, most notably interest rates, 
we  do  not  expect  this  to  have  a  significant  impact  on  the  Group’s  operations  in  the  foreseeable  future,  but 
management continues to monitor the situation.  

Directors   
Details of the Directors of the Company who served during the year and to date are:  

Alan Kentish 
Nigel Birrell 
Therese Neish (resigned 31 May 2024) 
Peter Smith (appointed 19 January 2023) 
Graham Kettleborough (resigned 28 April 2023) 

Alan Kentish has an interest in 6,418,817 ordinary shares in the Company (10.8% of the issued share capital). These 
shares are held in the name of Clifton Participations Inc and form part of the assets of the Perros Trust of which Alan 
Kentish is a potential beneficiary. Therese Neish has an interest in 492,756 ordinary shares of the Company (0.8% 
of the issued share capital).  

None of the other Directors had any interest in the issued share capital of the Company, either at the year-end or as 
at the date of this Report. 

International Financial Reporting Standards (“IFRS”)  
These financial statements were prepared under IFRS, and interpretations adopted by the International Accounting 
Standards Board (“IASB”).  

17 

 
 
  
  
  
  
  
   
  
  
  
 
 
  
 
  
 
Substantial interests  
Save as disclosed in the table below, the Directors are not aware of any person who directly or indirectly is interested 
in 3% or more of the issued ordinary share capital of the Company as at 25th June 2024 or any persons who, directly 
or indirectly, jointly or separately, exercise or could exercise control over the Company.  

Premier Miton Group  
Septer Limited  
Clifton Participations Inc and A R Kentish  
Peter Gyllenhammar AG  
Eastmount Capital Partners LLP  
Aeternitas Imperium Privatstiftung  

At 25th June 2024  
%  

16.14  
10.85  
10.80  
9.93  
4.70  
3.59  

Independent auditor  
Grant Thornton, being eligible, have expressed their willingness to continue in office as auditor. A resolution to re-
appoint Grant Thornton will be proposed at the Annual General Meeting.   

Annual General Meeting  
The date of the Annual General Meeting  for 2024 has yet to be determined, pending the  outcome of the offer by 
Jambo SRC Limited to acquire the whole of the issued and to be issued share capital of the Company, and will be 
communicated to shareholders in due course.  

By order of the Board  

Alan Kentish 
Director 
Viking House  
St Paul’s Square 
Isle of Man IM8 1GB  

26th June 2024 

18 

 
 
  
  
  
  
  
  
 
  
  
 
  
 
 
BOARD OF DIRECTORS 

NIGEL BIRRELL NON-EXECUTIVE CHAIRMAN (appointed September 2022) 

Nigel has served as the Chief Executive Officer of Lottoland Group since May 2014. Lottoland is an online gaming 
operator based in Gibraltar, which operates across multiple territories and has 17 million customers. Prior to this, 
Nigel was a group director on the executive board of bwin.party digital entertainment plc (now Entain plc), then the 
world’s leading on-line gaming business. Prior to bwin.party, Nigel was a main board director of the FTSE 250 
media group HIT Entertainment PLC (“HIT”). In his early career, Nigel worked as an investment banker with both  
Dresdner Kleinwort Benson and later Donaldson, Lufkin & Jenrette (subsequently, Credit Suisse). Nigel is the non-
executive Chairman of Duke Royalty Limited (AIM listed) and also holds a number of other private company non-
executive positions. He holds a Bachelor of Laws (LLB) from the University of London (Queen Mary College) and is 
a Solicitor of the Senior Courts of England and Wales. Nigel is Chair of the Remuneration Committee. 

ALAN KENTISH, ACA ACII AIRM CHIEF EXECUTIVE OFFICER (appointed CEO April 2016) 

Alan trained with a Big 4 accountancy firm in the UK and specialised in financial services audits, qualifying as a 
Chartered Accountant over 25 years ago. He moved to Gibraltar in 1993 and joined the BDO firm as the founder of 
their insurance management division. Alan was at the forefront of developing the hugely successful Gibraltar 
insurance sector and qualified as an Associate of the Chartered Insurance Institute as well as becoming a qualified 
Associate of the Institute of Risk Management along the way. The BDO member firm evolved into STM as part  
of the AIM listing in 2007, with Alan holding the office of Chief Financial Officer at that time, as well as navigating 
STM through the difficult financial crisis of 2008 and 2009. Alan became the director of business development in 
2012 as STM moved into its growth phase, particularly in relation to its pension product offering, and took  
over as CEO in April 2016 as part of continuing to build the infrastructure of the business. Alan has served on 
numerous company boards, both regulated and non-regulated, but primarily in the financial services and insurance 
sector, including a main subsidiary board of a FTSE 100 company 

PETER SMITH NON-EXECUTIVE DIRECTOR (appointed January 2023) 

Peter is a Fellow of the Institute of Chartered Accountants in England and Wales and has extensive experience in 
the financial services sector and in helping businesses to develop and implement their strategic goals. Peter was  
previously Chief Financial Officer of two AIM quoted financial advisory businesses between 2005 and 2019, 
including Lighthouse Group plc (“Lighthouse”) from 2008 until 2019 when that business was acquired by Quilter 
plc. Most recently, Peter has been a consultant to Quilter in respect of its integration of Lighthouse. Prior to this, 
Peter held a number of senior finance roles, including as a corporate finance partner at KPMG. Peter holds a BSc 
Econ (Hons) degree from Cardiff University and is Chair of the Audit & Risk Committee and a member of the 
Remuneration Committee. 

19 

 
 
 
 
 
 
 
 
  
Statement of Directors' Responsibilities in Respect of the Directors' Report and the Financial Statements   

The  Directors  are  responsible  for  preparing  the  Annual  Report  and  the  financial  statements  in  accordance  with 
applicable law and regulations.  

Isle of Man 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  International  Financial 
Reporting Standards (IFRSs and interpretations adopted by the International Accounting Standards Board (“IASB”). 
Under company law the Directors must not approve the financial statements unless they are satisfied that they give 
a true and fair view of the state of affairs of the Group and Parent Company and of the profit or loss of the Group for 
that period.   

In preparing these financial statements, the Directors are required to:   

•  properly select and apply accounting policies.  
•  present information, including accounting policies, in a manner that provides relevant, reliable, comparable 

and understandable information.   

•  provide additional disclosures when compliance with the specific requirements in IFRSs are insufficient to 

enable users to understand the impact of particular transactions, other events and conditions on the entity's 
financial position and financial performance; and  

•  make an assessment of the Company's ability to continue as a going concern.  

The Directors are responsible for keeping reliable accounting records that are sufficient to show and correctly 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 Isle of Man Companies Act 2006. They are 
also responsible for the system of internal control, 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 Isle of Man governing the preparation and dissemination of financial 
statements may differ from legislation in other jurisdictions.  

Directors’ Remuneration Report  

Executive Directors 
Alan Kentish 
Therese Neish 
Nicole Coll 
Sub-total 

Non-Executive Directors 
Nigel Birrell 
Duncan Crocker 
Robin Ellison 
Malcolm Berryman 
Graham Kettleborough 
Peter Smith 
Sub-total 
Total 

2023 

2022 

Notes 

 210,331  
 210,061  
          -    
 420,392  

 210,331  
   48,750  
 180,625  
 439,706  

   60,000  
          -    
          -    
          -    
   56,667  
   50,481  
 167,148  
 587,539  

   20,000  
   70,231  
     4,333  
   60,374  
   68,000  
          -    
 222,939  
 662,644  

a 
a,b 

c 
d 
e,i 
f,i 
g,i 
a,h 

a.  Therese Neish was appointed 
as a director on 14th October 
2022  and  resigned  on  31st 
May  2024.  She  received  a 
benefit of 5% of her salary by 
way of a pension contribution. 
Peter  Smith  (and  Nicole  Coll 
in  2022)  received  pension 
benefits  by  way  of  pension 
contributions in line with auto-
enrolment  requirements.  No 
other  directors  receive  any 
form  of 
in 
benefits 
pension 
or 
contributions 
share based incentives. 

the 

b.  Nicole Coll resigned as a director on 14th October 2022 
c.  Nigel Birrell was appointed as a director on 1st September 2022 
d.  Duncan Crocker resigned as a director on 31st August 2022 
e.  Robin Ellison resigned as a director on 31st January 2022  
f.  Malcolm Berryman resigned from the PLC Board on 4th August 2022 
g.  Graham Kettleborough resigned as a director on 28th April 2023 
h.  Peter Smith was appointed as a director on 19th January 2023 
i.  Robin Ellison and Malcolm Berryman (in 2022) and Graham Kettleborough (in 2022 and in 2023) received 
remuneration for their NED roles on the PLC Board as well as for their roles on various subsidiary boards.  

20 

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

Report on the audit of the financial statements 

Opinion 
We have audited the financial statements of STM Group Plc (“the Parent Company”) and its subsidiaries 
(the  “Group’’),  which  comprise  the  consolidated  statement of  comprehensive income,  the  consolidated 
statement of financial position, the company statement of financial position, the statement of consolidated 
cash flow, the statement of consolidated changes in equity, the statement of company changes in equity for 
the year ended 31 December 2023, and the related notes to the financial statements, including a summary 
of significant accounting policies.  

The financial reporting framework that has been applied in the preparation of the financial statements is 
applicable law and International Financial Reporting Standards (“IFRS”) as adopted by the International 
Accounting Standards Board (“IASB”). 

In our opinion,  

• 

• 

• 

the consolidated financial statements of the Group give a true and fair view in accordance with 
IFRS as adopted by the  IASB of the assets, liabilities and  financial position of  the Group at 31 
December 2023 and of the Group’s financial performance and cash flows for the year then ended; 
the Parent Company’s statement of financial position and statement of company changes in equity 
have been properly prepared in accordance with IFRSs as issued by the IASB and as applied in 
accordance with provisions of the Isle of Man Companies Act 2006; and 
the financial statements have been properly prepared in accordance with the requirements of the 
Isle of Man 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 ‘Responsibilities of 
the auditor for the audit of the financial statements’ section of our report. We are independent of the Group 
and  Parent  Company  in  accordance  with  the  ethical  requirements  that  are  relevant  to  our  audit  of  the 
financial  statements  in  the  United  Kingdom,  including  the  FRC’s  Ethical  Standard  and  the  ethical 
pronouncements established by Chartered Accountants Ireland, applied as determined to be appropriate in 
the circumstances for the entity. 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.  

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

Conclusions relating to going concern 
In auditing the financial statements, we have concluded that the directors’ use of going concern basis of 
accounting in the preparation of the financial statements is appropriate. Our evaluation of the directors’ 
assessment of the Group and Parent Company’s ability to continue to adopt the going concern  basis of 
accounting included: 

•  Evaluating management’s future cash flow forecasts, understanding the process by which they were 

prepared, and assessed the calculations are mathematically accurate. 

•  Challenging the underlying key assumptions such as expected cash inflow from technology and 

development sales and cash outflow from project costs and other operating expenses. 

•  Making inquiries on the status of the projects and understanding on how the Group and Parent 
Company’s  future  plans  for  each of  the  projects  will  be  funded and  assessing  whether  this  can 
support the future developments and cost projections. 

•  Making  inquiries  with  management  and  reviewing  the  board  minutes  and  available  written 
communication with commercial partners in order to understand the future plans and to identify 
potential contradictory information. 

•  Assessing the adequacy of the disclosures with respects to the going concern assertion. 

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

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

Key audit matters 
Key audit matters are those matters that, in our professional judgement, were of most significance in our 
audit of the financial statements of the current financial 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 the directing of 
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 therefore we do not provide a separate 
opinion on these matters. 

Overall audit strategy  
We designed our audit by determining materiality and assessing 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 also addressed the risk of management override of internal 
controls, including evaluating whether there was any evidence of potential bias that could result in a risk of 
material misstatement due to fraud. 

Based on the considerations set out below, our area of focus included impairment of goodwill relating to 
the cash generating units (CGUs).  

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

Key audit matters (cont’d) 
How we tailored the audit scope 
We tailored the scope of  our audit by obtaining an understanding of  the Group and the Parent Company 
and its environment, including assessing the risks of  material misstatements, to be able to give an opinion 
on  the  consolidated  and  company  financial  statements  as  a  whole,  taking  into  account  the  operational 
structure of  the Group and the Parent Company, the accounting processes and controls, the involvement 
of  third parties and the industry in which the Group and the Parent Company operates. Audit work on the 
Group and Parent Company was performed by the same audit team. 

We  have  also  identified  the  reporting  components  across  the  regulated  and  trading  entities  within  the 
jurisdictions in which the group operates. The regulated and trading entities in Gibraltar, Malta and the UK 
are considered of  individual financial significance to the reported results of  the Group. These components 
were  subjected  to  either  full  scope  audits  or  audits  of   specified  account  balances  for  group  reporting 
purposes. 

Materiality and audit approach 
We  apply  the  concept  of   materiality  in  planning  and  performing  the  audit,  in  evaluating  the  effect  of 
identified  misstatements  on  the  audit  and  in  forming  our  audit  opinion.  We  set  certain  quantitative 
thresholds for materiality. These, together with qualitative considerations, such as our understanding of  the 
entity and its environment and the complexity of  the Group and Parent Company and the reliability of  the 
control environment, helped us to determine the scope of  our audit and the nature, timing and extent of  
our audit procedures and to evaluate the effect of  misstatements, both individually and on  the financial 
statements as a whole. 

Materiality  is  defined  as  the  magnitude  of   an  omission  or  misstatement  that,  individually  or  in  the 
aggregate, could reasonably be expected to influence the economic decisions of  the users of  the financial 
statements. Materiality provides a basis for determining the nature and extent of  our audit procedures. 

Based on our professional judgement, we determined materiality for the Group to be £281,000, which is 
1% of the revenue and the Parent Company to be £211,000, which is 1% of the net assets. We believe that 
a percentage of revenue is the appropriate benchmark as it reflects the interests of the investors and stability 
of the benchmark in recent years for the Group and a percentage of net assets as the Parent Company has 
limited transactions as a holding company. 

Performance  materiality is  defined  as  the  application  of  materiality at  the individual account  or balance 
level.  It is set at an amount to reduce to an appropriately low level the probability that the aggregate of 
uncorrected and undetected misstatements exceeds materiality.  

On the basis of our risk assessments, together with our assessment of the Group and the Parent Company’s 
overall control environment, our judgement was that performance materiality was 75% of materiality. We 
have  set  performance  materiality  at  this  percentage  having  taken  account  of  there  being  minimal 
uncorrected misstatements in the prior year.  

Reporting threshold is defined as the amount below which identified misstatements are considered  to be 
clearly trivial. 

We agreed with the Board of Directors that we would report to them misstatements identified during our 
audit above 5% of materiality, as well as  misstatements below that amount that, in our view, warranted 
reporting on qualitative grounds.   

We evaluate any uncorrected misstatements against both the quantitative measures of materiality discussed 
above and in light of other relevant qualitative considerations in forming our opinion. 

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

Key audit matters (cont’d) 

Significant matters identified 
The risks of material misstatement that had the greatest effect on our audit, including the allocation of our 
resources and effort, are set out below as significant matters together with an explanation of how we tailored 
our audit to address these specific areas in order to provide an opinion on the financial statements as a 
whole. This is not a complete list of all risks identified by our audit. 

Description of significant matter 

Our audit response 

Impairment of goodwill relating to the cash 
generating units (CGUs) 
Management  are  required  by  IAS  36  – 
Impairment of Assets, to perform an annual 
impairment review of goodwill where there 
are indicators of impairment. 

We consider there to be a risk of material 
misstatement due to fraud or error in 
respect of the impairment of goodwill, 
specific to certain assumptions within the 
assessment, including the cash flows 
assumed within the discounted cash flow 
model and the assumptions applied to 
these, including growth rates and discount 
rates. 

As a result, a significant portion of the audit 
effort was directed towards the audit of the 
impairment assessment of goodwill. 

Refer  to  accounting  policy  in  Note  3  and 
disclosures  in  Note  15  of  the  financial 
statements. 

Our response to address these risks include: 

•  Obtained an understanding and evaluated the design 
and implementation of key controls relevant to the 
impairment  process  and  key  controls  over  the 
impairment review performed by management. 
•  Evaluated the cash flow forecast used in the model 
against the historical trading of the cash generating 
units  (CGUs)  and  challenged  the  assumptions 
underpinning 
the 
retrospective  review  of  the  estimates,  growth  rate 
and discount rate used. 

including 

forecast, 

the 

•  Assessed  factors  behind  the  growth  and  financial 

performance forecast for each CGU. 

•  Compared the forecast used in the impairment test 
in  the  going  concern 

to  the  forecasts  used 
assessment for consistency.  

•  Reviewed the disclosures in relation to goodwill in 
the financial statements  to ensure compliance with 
accounting standards. 

We  completed  our  planned  audit  procedures,  with  no 
exceptions noted. 

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

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

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

We have nothing to report in this regard. 

Responsibilities  of  management  and  those  charged  with  governance  for  the  financial 
statements  
As  explained more  fully in  the Directors'  responsibilities  statement,  management is  responsible  for  the 
preparation of the financial statements which give a true and fair view in accordance with IFRS as adopted 
by the IASB, and for such internal control as directors determine necessary to enable the preparation of 
financial statements are free from material misstatement, whether due to fraud or error. 
In  preparing  the  financial  statements,  management  is  responsible  for  assessing  the  Group  and  Parent 
Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern 
and using the going concern basis of accounting unless management either intends to liquidate the Group 
or Parent Company or to cease operations, or has no realistic alternative but to do so. 

Those charged with governance are responsible for overseeing the Group and Parent Company’s financial 
reporting process. 

Responsibilities of the auditor for the audit of the financial statements  
A further description of an auditor’s 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. 

Explanation as to what extent the audit was considered capable of detecting irregularities, including 
fraud 
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. Owing to the inherent limitations of an audit, there is an unavoidable risk 
that material misstatement in the financial statements may not be detected, even though the audit is properly 
planned and performed in accordance with the ISAs (UK). The extent to which our procedures are capable 
of detecting irregularities, including fraud is detailed below. 

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

Responsibilities of the auditor for the audit of the financial statements (cont’d)  
Explanation as to what extent the audit was considered capable of detecting irregularities, including 
fraud (continued) 
Based on our understanding of the Group and industry, 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 Isle of  Man Companies Act 
2006 and the Group’s obligations in AIM, a market operated by the London Stock Exchange. The Audit 
engagement partner considered the experience and expertise of  the engagement team to ensure that the 
team had appropriate competence and capabilities to identify or recognise non-compliance with the laws 
and regulation. We evaluated management’s incentives and opportunities for fraudulent manipulation of  
the financial statements (including the  risk of  override controls), and determined that the principal risks 
were related to posting inappropriate journal entries to manipulate financial performance and management 
bias  through  judgements  and  assumptions  in  significant  accounting  estimates.  We  apply  professional 
scepticism  through  the  audit  to  consider  potential  deliberate  omission  or  concealment  of   significant 
transactions, or incomplete/inaccurate disclosures in the financial statements. 

In response to these principal risks, our audit procedures included but not limited to: 

• 

• 

• 
• 

enquiries of  management on the policies and procedures in place regarding compliance with laws 
and regulations, including consideration of  known or suspected instances of  non-compliance and 
whether they have knowledge of  any actual, suspected or alleged fraud; 
as the Group operates in the financial services industry, the Audit Engagement Partner considered 
the experience and expertise of  the engagement team to ensure that the team had the appropriate 
competence and capabilities; 
gaining an understanding of  the entity’s current activities and the scope of  its authorisation; 
inspection of  the Group’s regulatory and legal correspondence and review of  minutes during the 
year to corroborate inquiries made; 

•  obtaining an understanding of  internal controls established to mitigate risk related to fraud; 
•  discussion  amongst  the  engagement  team in  relation  to  the  identified laws  and  regulations and 
regarding  the  risk  of   fraud,  and  remaining  alert  to  any  indications  of   non-compliance  or 
opportunities for fraudulent manipulation of  financial statements throughout the audit; 
identifying and testing journal entries to address the risk of  inappropriate journals and management 
override of  controls; 

• 

•  designing audit procedures to incorporate unpredictability around the nature, timing and extent of 

• 

• 

our testing; 
challenging  assumptions  and  judgements  made  by  management  in  their  significant  accounting 
estimates (i.e. valuation of  acquired client portfolio, measurement of  goodwill and measurement 
of  provisions); and 
evaluating the overall presentation, structure and content of  the financial statements, including the 
disclosures, and whether the financial statements represent the underlying transactions and events 
in a manner that achieves a true and fair view.  

The primary responsibility for the prevention and detection of irregularities including fraud rests with those 
charged with governance and management. As  with any audit, there remains a risk of non-detection or 
irregularities, as these may involve collusion, forgery, intentional omissions, misrepresentations or override 
of internal controls. 

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

The purpose of our audit work and to whom we owe our responsibilities 
This  report  is made  solely  to  the  company’s members, as a body, in  accordance  with  the  terms of  our 
engagement letter. 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. 

Report on other legal and regulatory requirements 

We were appointed by the Board of Directors on 4 November 2022 to audit the financial statements for 
the year ended 31 December 2022 and subsequent financial periods. This is the second year we have been 
engaged to audit the financial statements of the Group.  

We have not provided non-audit services prohibited by the FRC’s Ethical Standard and have remained 
independent of the entity in conducting the audit. 

The audit opinion is consistent with the additional report to the Audit & Risk Committee. 

Christopher Rogers  

For and on behalf of 

Grant Thornton 
Chartered Accountants & Statutory Auditors 
Dublin, Ireland 
26 June 2024 

 
 
 
 
 
CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME 
FOR THE YEAR ENDED 31 DECEMBER 2023 

Revenue 

Administrative expenses 

Profit before other items 

OTHER ITEMS 

Bargain purchase gain 
Gains  on 
instruments  
Loss on disposals of subsidiaries 

revaluation  of 

financial 

Notes 
9 

10 

11 

5 

4 

Loss on disposal of fixed assets 

Finance costs 

Depreciation and amortisation 

14,15 

13 

Profit before taxation 

Taxation 

Profit after taxation 

OTHER COMPREHENSIVE INCOME 

Items that are or may be reclassified 
to profit or loss 

Foreign currency translation differences 
for foreign operations 
Total other comprehensive income 
Total comprehensive income for the 
year 
Profit attributable to: 

Owners of the Company 

Non-controlling Interests 

Total comprehensive income  
attributable to: 
Owners of the Company 

Non-controlling Interests 

Earnings per share basic (pence) 

Earnings per share diluted (pence) 

22 

22 

Year ended 
31 December 2023 
£000 

28,078 

(24,878) 

3,200 

- 

- 

- 

(96) 

(689) 

(1,973) 

442 

(25) 

417 

32 
32 

449 

417 

- 

417 

449 

- 

449 
0.70 

0.70 

Year ended 
31 December 
2022 
£000 
24,094 

(20,773) 

3,321 

327 

11 

(162) 

- 

(322) 

(1,597) 

1,578 

(724) 

854 

12 
12 

866 

844 

10 

854 

856 

10 

866 

1.42 

1.42 

The results for 2023 and 2022 relate to continuing activities.  

The notes on pages 34 to 69 form an integral part of these financial statements. 

28 

 
                                                                                                                                                                                                                                                            
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF FINANCIAL POSITION 
AS AT 31 DECEMBER 2023 

31 December 
2023 
£000 

31 December 
2022 
£000 

Notes 

ASSETS 

Non-current assets 

Property and office equipment 

Intangible assets 

Financial assets 

Deferred tax asset 

Total non-current assets 

Current assets 

Accrued income 

Trade and other receivables 

Receivables due from insurers 

Cash and cash equivalents 

Total current assets 

Total assets 

EQUITY 

Called up share capital 

Share premium account 

Retained earnings 

Other reserves 

Equity attributable to owners of the Company 

Non-controlling interests 

Total equity 

LIABILITIES 

Current liabilities 

Liabilities for current tax  

Trade and other payables 

Provisions 

Total current liabilities 

Non-current liabilities 

Other payables  

Deferred tax liabilities 

Total non-current liabilities 

Total liabilities and equity 

14 

15 

16 

13 

18 

28 

19 

20 

20 

20 

23 

28 

24 

13 

1,304 

21,444 

1,839 

39 

24,626 

3,078 

7,349 

27,441 

18,365 

56,233 

80,859 

59 

22,372 

14,443 

(2,279) 

34,595 

- 

34,595 

425 

13,271 

27,441 

41,137 

4,808 

319 

5,127 

80,859 

1,161 

22,125 

1,762 

58 

25,106 

860 

8,461 

488 

19,234 

29,043 

54,149 

59 

22,372 

14,382 

(1,843) 

34,970 

(68) 

34,902 

788 

12,517 

488 

13,793 

5,050 

404 

5,454 

54,149 

The notes on page 34 to 69 form an integral part of these financial statements.  

These financial statements were approved by the Board of Directors and authorised for issue on 26th June 2024 
and were signed on its behalf by: 

AR Kentish 
Chief Executive Officer 
26 June 2024

Peter Smith 
Non-Executive Director 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
COMPANY STATEMENT OF FINANCIAL POSITION 
AS AT 31 DECEMBER 2023 

ASSETS 

Non-current assets 

Property and office equipment 

Intangible assets 

Investments  

Total non-current assets 

Current assets 

Trade and other receivables 

Cash and cash equivalents 

Total current assets 

Total assets 

EQUITY 

Called up share capital 

Share premium account 

Retained earnings 

Other reserves 

Total equity attributable to equity shareholders 

LIABILITIES 

Current liabilities 

Trade and other payables 

Total current liabilities 

Non-current liabilities 

Other payables 

Total non-current liabilities 

Total liabilities and equity 

  Notes 

31 December 
2023 
£000 

31 December 
2022 
£000 

14 

15 

17 

18 

19 

20 

20 

21 

196 

2,581 

17,413 

20,190 

15,295 

2,324 

17,619 

37,809 

59 

22,372 

(1,490) 

162 

21,103 

214 

2,586 

17,013 

19,813 

15,923 

2,425 

18,348 

38,161 

59 

22,372 

(1,754) 

162 

20,839 

23 

12,444 

12,511 

24 

12,444 

12,511 

4,262 

4,262 

37,809 

4,811 

4,811 

38,161 

The notes on pages 34 to 69 form an integral part of these financial statements. 

These financial statements were approved by the Board of Directors and authorised for issue on 26th June 2024 
and were signed on its behalf by: 

AR Kentish 
Chief Executive Officer 

26 June 2024

Peter Smith 
Non-Executive Director 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STATEMENT OF CONSOLIDATED CASH FLOW 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

Year ended 
31 December  
2023 
£000 

Year ended 
31 December  
2022 
(restated) 
£000 

Notes 

442 

1,578 

OPERATING ACTIVITIES 

Profit for the year before tax  

ADJUSTMENTS FOR:  

Depreciation of property and office equipment 

Amortisation of intangible assets 

Loss on disposal of property and office equipment 

Unrealised gains on financial instruments 

Bargain purchase gain 

Taxation paid 

(Increase)/decrease in trade and other receivables including insurers 

(Increase)/decrease in accrued income  

Increase in trade and other payables including insurers 

Net cash generated from operating activities  

INVESTING ACTIVITIES  

Purchase of property and office equipment  

Increase in intangible assets 

Purchase of financial instruments 

Acquisition of non-controlling interests 

Additional consideration paid on prior acquisitions 

Consideration paid on acquisition of portfolio 

Net cash absorbed by from investing activities  

CASH FLOWS FROM FINANCING ACTIVITIES  

Proceeds from bank loan 

Repayments of bank loan 

Interest paid on bank loan 

Lease liabilities paid 

Dividends paid 

14 

15 

5 

14 

15 

6 

5 

23,24 

23,24 

20 

Net cash (absorbed by)/generated from financing activities 

(Decrease)/increase in cash and cash equivalents 

Effect of movements in exchange rates on cash and cash equivalents 

Cash and cash equivalents at the beginning of the year 

Cash and cash equivalents at the end of the year 

19 

620 

1,353 

96 

(77) 

- 

(454) 

(25,841) 

(2,218) 

28,541 

2,462 

(170) 

(672) 

- 

(400) 

(228) 

- 

(1,470) 

- 

(551) 

(405) 

(581) 

(356) 

(1,893) 

(901) 

32 
19,234 

18,365 

673 

924 

4 

(11) 

(327) 

(619) 

22,246 

558 

(19,737) 

5,289 

(165) 

(937) 

(1,734) 

(120) 

- 

(3,454) 

(6,410) 

4,463 

(550) 

(162) 

(724) 

(891) 

2,136 

1,015 

12 
18,207 

19,234 

The comparative cash flow movements for the year ended 31st December 2022 have been restated to aggregate 
and reclassify certain flows in order to be consistent with the presentation adopted in the year ended 31st December 
2023. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STATEMENT OF CONSOLIDATED CHANGES IN EQUITY 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

Share 
capital 
£000 

Share 
premium 
£000 

Retained 
earnings 
£000 

Treasury 
shares 
£000 

Foreign 
currency 
translation 
reserve 
£000 

Share 
based 
payments 
reserve 
£000 

Other 
reserve 
£000 

Balance at 1 January 2022 

59 

22,372 

14,429 

(549) 

(93) 

162 

TOTAL COMPREHENSIVE INCOME FOR THE PERIOD 

Profit for the year 

Other comprehensive income 

Foreign currency translation 
differences 

- 

- 

Transactions with owners, recorded directly in equity 

Acquisition of non-controlling 
interests 

Dividends paid 

- 

- 

- 

- 

- 

- 

844 

- 

- 

(891) 

- 

- 

- 

- 

- 

12 

- 

- 

- 

- 

- 

- 

Non-
controlling 
Interests 
£000 

Total 
Equity 
£000 

(452) 

35,928 

Total 
£000 

36,380 

844 

10 

854 

12 

- 

12 

- 

- 

- 

(1,375) 

(1,375)  

374 

(1,001) 

- 

(891) 

- 

(891) 

At 31 December 2022 and                   
1 January 2023 

59 

22,372 

14,382 

(549) 

(81) 

162 

(1,375) 

34,970 

(68) 

34,902 

TOTAL COMPREHENSIVE INCOME FOR THE PERIOD 

Profit for the year 

Other comprehensive income 

Foreign currency translation 
differences 

- 

- 

Transactions with owners, recorded directly in equity 

Acquisition of non-controlling 
interests 

Dividends paid 

- 

- 

- 

- 

- 

- 

417 

- 

- 

(356) 

- 

- 

- 

- 

- 

32 

- 

- 

- 

- 

- 

- 

- 

- 

417 

32 

(468) 

- 

(468) 

(356) 

At 31 December 2023 

59 

22,372 

14,443 

(549) 

(49) 

162 

(1,843) 

34,595 

- 

- 

68 

- 

- 

417 

32 

(400) 

(356) 

34,595 

32 

 
 
 
 
 
 
STATEMENT OF COMPANY CHANGES IN EQUITY 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

Share 
Capital 
£000 

Share 
premium 
£000 

Retained 
earnings 
£000 

Share 
based 
payments 
reserve 
£000 

Total 
£000 

Balance at 1 January 2022 

59 

22,372 

(1,205) 

162 

21,388 

Profit for the year 

Dividends paid 

- 

- 

- 

- 

342 

(891)  

- 

- 

342 

(891) 

At 31 December 2022 and 1 January 2023 

59 

22,372 

(1,754) 

162 

20,839 

Profit for the year 

Dividends paid 

- 

- 

- 

- 

620 

(356)  

- 

- 

620 

(356) 

At 31 December 2023 

59 

22,372 

(1,490) 

162 

21,103 

33 

 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

1.  Reporting entity 

STM Group PLC (the “Company”) is a company incorporated and domiciled in the Isle of Man and is traded on AIM, 
a market operated by the London Stock Exchange. The address of the Company’s registered office is 1st Floor Viking 
House, St Paul’s Square, Ramsey, Isle of Man, IM8 1GB. The consolidated financial statements of the Group as at, 
and for the year ended, 31st December 2023 comprise the Company and its subsidiaries (see Note  30) (together 
referred to as the “Group” and individually as “Group entities”). The Group is primarily involved in financial services. 

2.   Basis of preparation 

The financial information has been prepared on the basis of the accounting policies set out in Note 3.  

(a)  Statement of compliance 

The  consolidated  financial  statements  have  been  prepared  in  accordance  with  International  Financial  Reporting 
Standards  (“IFRS”)  and  interpretations  adopted  by  the  International  Accounting  Standards  Board  (“IASB”)  and  in 
accordance with Isle of Man law. 

(b)  Going concern basis of accounting 

The Directors have prepared the financial statements on a going concern basis, as in their opinion the Group is able 
to meet its obligations as they fall due for a period of at least 12 months from the date of this report. In considering 
this requirement, the Directors have considered budgets and rolling cashflow forecasts for the forthcoming 18-month 
period and the level of professional indemnity insurance held by the Group. In addition, the risks included on the 
Group’s risk register that could impact on the Group’s liquidity and solvency over the next 12 months. These show 
that the Group should continue to be cash generative, and have sufficient resources to meet its business objectives, 
both in the short-term and in relation to its strategic priorities.  

Having due regard to these matters, the Directors have a reasonable expectation that the Group and Company have 
adequate resources to continue in operational existence for at least 12 months from the date of approval and signing 
of the financial statements. As such, the Board continues to adopt the going concern basis in preparing the financial 
statements. 

(c)  Functional and presentation currency 

These consolidated financial statements are presented in Pounds Sterling (£), rounded to the nearest £’000, which 
is the Company’s functional currency as this is the main currency in which it transacts business. Foreign operations 
are included in accordance with the policies set out in Note 3 (b)(ii). 

(d)  Use of judgments and estimates 

The preparation of financial statements requires management to make judgments, estimates and assumptions that 
affect the application of accounting policies and the reported amounts of assets, liabilities, income and expenses. 
Actual results may differ from these estimates. 

Estimates and underlying  assumptions are reviewed  on an ongoing  basis. Revisions to accounting estimates are 
recognised in the period in which the estimate is revised. 

(i)  Judgements 

Information  about  judgements  made  in  applying  accounting  policies  that  have  the  most  significant  effects  on  the 
carrying values of the assets and liabilities is included in the following notes: 

– 

– 

– 

Note 3(c) – Revenue recognition: timing of the satisfaction of performance obligations and recognition of revenue 
either over time or at a point in time; 

Note 15 – Determination of identifiable cash-generating units; and 

Note 28 – Determination as to whether a provision for potential customer detriment is required or should  be 
disclosed as a contingent liability. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

2.   Basis of preparation (continued) 

(d)  Use of judgments and estimates (continued) 

(ii)  Assumptions and estimates 

Assumptions and estimation uncertainties at 31st December 2023 that have a significant risk of resulting in a material 
adjustment to the carrying values of assets and liabilities in the next financial year are included in the following notes: 

– 

– 

Note  15  –  Measurement  of  goodwill:  the  key  assumptions  used  in  determining  whether  goodwill  has  been 
impaired at each annual impairment review; and 

Note 28 – Measurement of provisions: assumptions about the likelihood and magnitude of an outflow of resource 
in respect of customer claims for detriment. 

(e)  Basis of measurement 

The consolidated financial statements have been prepared on the historical cost basis, except where investments 
and other financial instruments are held at fair value. 

(f)  Employee benefit trusts 

The Company contributes to an employee benefit trust. It is deemed that this trust is controlled by the Company and 
is therefore included within the consolidated financial statements of the Group. 

3.  Material accounting policies 

The accounting policies set out below have been applied consistently to all periods presented in these consolidated 
financial statements. 

In addition, the Group adopted Disclosure of Accounting Policies (Amendments to IAS 1 and IFRS Practice Statement 
2) from 1st January 2023. The amendments require the disclosure of ‘material’, rather than ‘significant’, accounting 
policies.  Although  the  amendments  did  not  result  in  any  changes  to  the  accounting  policies  themselves,  they 
impacted the accounting policy information disclosed below. 

(a)  Basis of consolidation  

(i)  Subsidiaries 

Subsidiaries are entities controlled by the Group. The Group controls an entity when it is exposed to, or has rights 
to, variable returns from its involvement with the entity and has the ability to affect those returns through its power 
over the entity. The financial statements of subsidiaries are included in the consolidated financial statements from 
the date on which control commences until the date on which control ceases. Specifically, the results of subsidiaries 
acquired  or  disposed  of  during  the  year  are  included  in  profit  or  loss  from  the  date  the  Company  gains  effective 
control until the date when the Company ceases to control the subsidiary. Where necessary, adjustments are made 
to the financial statements of subsidiaries to bring the accounting policies used into line with the Group’s accounting 
policies. 

(ii)  Business combinations 

The Group accounts for business combinations using the acquisition method when the acquired set of activities and 
assets meets the definition of a business and control is transferred to the Group. In determining whether a particular 
set  of  activities  and  assets  is  a  business,  the  Group  assesses  whether  the  set  of  assets  and  activities  acquired 
includes, at a minimum, an input and a substantive process that together significantly contribute to the ability to create 
outputs. 

35 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(a) 

 Basis of consolidation (continued) 

(ii)  Business combinations (continued) 

The consideration transferred in a business combination is measured at fair value, which is calculated as the sum of 
the  acquisition-date  fair  values  of  assets  transferred  by  the  Group,  liabilities  incurred  by  the  Group  to  the  former 
owners  of  the  acquiree  and  the  equity  interest  issued  by  the  Group  in  exchange  for  control  of  the  acquiree.  Any 
goodwill that arises is tested annually for impairment. Any gain on a bargain purchase is recognised in profit or loss 
immediately.  Transaction  costs  are  expensed  as  incurred,  except  if  related  to  the  issue  of  debt.  Any  contingent 
consideration is measured at fair value at the date of acquisition and re-measured at each reporting date. Subsequent 
changes to the contingent consideration are adjusted against goodwill where a change in the fair value of contingent 
consideration is the result of additional information about facts and circumstances that existed at the acquisition date. 
These changes are accounted for as measurement period adjustments if they arise during the measurement period. 
Changes resulting from events after the acquisition date do not impact goodwill but are accounted for separately. 
The  subsequent  accounting  for  changes  in  the  fair  value  of  the  contingent  consideration  that  do  not  qualify  as 
measurement  period  adjustments  depends  on  how  the  contingent  consideration  is  classified.  Contingent 
consideration  that  is  classified  as  equity  is  not  remeasured  at  subsequent  reporting  dates  and  its  subsequent 
settlement is accounted for within equity. Other contingent consideration is remeasured to fair value at subsequent 
reporting dates with changes in fair value recognised in profit or loss.  

(iii)  Non-controlling interests (NCI) 

NCI, in subsidiaries are identified separately from the Group's equity therein.  Those interests of NCI that are present 
ownership interest entitling their holders to a proportionate share of net assets upon liquidation, are measured initially 
at  their  proportionate  share  of  the  acquiree’s  identifiable  net  assets  at  the  date  of  acquisition.  Subsequent  to 
acquisition, the carrying amount of the NCI is the amount of those interests at initial recognition plus the NCI share 
of subsequent changes in equity. NCI will be allocated its share of profit or loss and its share of each component of 
other comprehensive income in subsequent periods even if this results in the NCI having a deficit balance. NCI in 
subsidiaries  are  identified  separately  from  the  group's  equity  therein.    Those  interests  of  NCI  that  are  present 
ownership interest entitling their holders to a proportionate share of net assets upon liquidation are measured initially 
at their proportionate acquisition. 

(iv)  Transactions eliminated on consolidation 

Intra-group  balances  and  transactions,  and  any  unrealised  income  and  expenses  arising  from  intra-group 
transactions are eliminated in preparing the consolidated financial statements. 

(b) 

 Foreign currency  

(i)  Foreign currency transactions 

In preparing the financial statements of the group entities, transactions in currencies other than the entity's functional 
currency (foreign currencies) are translated to the functional currency at the exchange rate prevailing at the date of 
the transaction.  Non-monetary assets and liabilities that are measured in terms of historical cost in a foreign currency 
are not retranslated. The resulting gain or loss is recognised in the statement of comprehensive income.  

(ii)  Foreign operations 

The assets and liabilities of foreign operations, including goodwill and fair value adjustments arising on acquisition, 
are translated to sterling at exchange rates at the reporting  date. For the purposes of preparing the consolidated 
financial  statements,  the  assets  and  liabilities  are  translated  to  sterling  at  exchange  rates  at  the  reporting  date. 
Income  and  expense  items  are  translated  at  the  average  exchange  rates  for  the  period,  unless  exchange  rates 
fluctuate  significantly  during  that  period,  in  which  case  the  exchange  rates  at  the  date  of  transactions  are  used. 
Exchange differences arising, if any, are recognised in other comprehensive income and accumulated in a foreign 
exchange translation reserve (attributed to non-controlling interests as appropriate). 

36 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(b)  Foreign currency (continued) 

(ii)  Foreign operations (continued) 

Foreign exchange gains and losses arising from monetary items that in substance form part of the net investment in 
its foreign operations are recognised in other comprehensive income and are presented within equity in the foreign 
currency translation reserve. 

(c)  Revenue 

Revenue  is  derived  from  the  provision  of  services  as  described  in  Note  9  and  is  recognised  in  the  statement  of 
comprehensive  income  when  the  Group  completes  performance  obligations  and  transfers  control  over  a  good  or 
service to a customer.  

Revenue derived from pensions operating segment is split between the establishment fee and the management fee. 
The establishment fee is recognised in full at the time of processing the application so as to reflect the completion of 
the performance obligation such as processing their application and setting up the pension trust. The management 
fees, which are invoiced annually, cover both the provision of trustee services and the administration of the pension 
funds. The current treatment of these fees, based on the existing profile of the client portfolio, is to recognise 50% at 
the time of invoicing and to defer the balance over the year of each policy as each of the performance obligations 
are satisfied. 

(d)  Accrued income 

Accrued income represents billable time spent on the provision of services to clients which has not been invoiced at 
the reporting date. The accrued income is based on the number of applications received but for which an invoice has 
not been raised yet. 

(e)  Receivables from insurers 

Where the Group has professional indemnity insurance that would be receivable against a provision for an insurance 
claim payable an asset is recognised within receivables in the statement of financial position when there is reasonable 
certainty as to the recovery from the insurers. 

(f)  Property and office equipment 

(i)  Recognition and measurement 

Items of property and office equipment are measured at cost less accumulated depreciation and impairment losses. 
Cost includes expenditures that are directly attributable to the acquisition of the asset and bringing it into use. Gains 
and losses on disposal of an item of property and office equipment are determined by comparing the proceeds from 
disposal with the carrying amount of property and office equipment and are recognised net within other income in 
profit or loss.  

(ii)  Depreciation 

Depreciation is recognised in the statement of comprehensive income on a reducing balance basis over the estimated 
useful economic lives of each part of an item of property and office equipment. Leased assets are depreciated over 
the shorter of the lease term or the estimated useful economic life.  Depreciation commences once assets are in use. 

The rates in use are as follows:  

Office equipment 
Motor vehicles 
Right-of-use assets 

10% - 25% on a reducing balance basis 
25% on a reducing balance basis 
Over the life of the leases  

Depreciation methods, useful economic lives and residual values are reassessed at the reporting date. 

37 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(g)  Financial instruments 

(i) 

 Recognition and initial measurement  

Financial assets and financial liabilities are initially recognised when the Group becomes a party to the contractual 
provisions of the instrument.  

A  financial  asset  (unless  it  is  a  trade  receivable  without  a  significant  financing  component)  or  financial  liability  is 
initially measured at fair value plus, for an item not at fair value through profit or loss (“FVTPL”), transaction costs 
that are directly attributable to its acquisition or issue. A trade receivable without a significant financing component is 
initially measured at the transaction price.  

Derivative financial instruments are measured at FVTPL and are considered to fall within level 3 of the fair value 
hierarchy. 

Fair value hierarchy levels 1 to 3 are based on the degree to which the fair value is observable: 

• 

• 

• 

Level  1  fair  value  measurements  are  those  derived  from  quoted  prices  (unadjusted)  in  active  markets  for 
identical assets or liabilities; 

Level 2 fair value measurements are those derived from inputs other than quoted prices included within Level 1 
that are observable for the asset or liability, either directly (i.e. as prices) or indirectly (i.e. derived from prices); 
and 

Level 3 fair value measurements are those derived from valuation techniques that include inputs for the asset 
or liability that are not based on observable market data (unobservable inputs). 

All other financial assets are measured at amortised cost. 

(i)  Classification and subsequent measurement 

Financial assets 

On initial recognition, a financial asset is classified at amortised cost, fair value through other comprehensive income 
(“FVOCI”) or FVTPL.  

Financial assets are not reclassified subsequent to their initial recognition unless the Group changes its business 
model for managing financial assets, in which case all affected financial assets are reclassified on the first day of the 
first reporting period following the change in the business model. 

A financial asset is measured at amortised cost if it meets both of the following conditions and is not designated as 
FVTPL:  

– 

– 

it is held within a business model whose objective is to hold assets to collect contractual cash flows; and 

its contractual terms give rise on specified dates to cash flows that are solely payments of principal and interest 
on the principal amount outstanding.  

A  debt  investment  is  measured  at  FVOCI  if  it  meets  both  of  the  following  conditions  and  is  not  designated  as  at 
FVTPL:  

– 

– 

it is held within  a business model whose objective is  achieved by both collecting contractual cash flows and 
selling financial assets; and  

its contractual terms give rise on specified dates to cash flows that are solely payments of principal and interest 
on the principal amount outstanding.  

All  financial  assets  not  classified  as  measured  at  amortised  cost  or  FVOCI  as  described  above  are  measured  at 
FVTPL.  On  initial  recognition,  the  Group  may  irrevocably  designate  a  financial  asset  that  otherwise  meets  the 
requirements  to  be  measured  at  amortised  cost  or  at  FVOCI  as  at  FVTPL  if  doing  so  eliminates  or  significantly 
reduces an accounting mismatch that would otherwise arise.  

38 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(g)  Financial instruments (continued) 

(ii)  Classification and subsequent measurement (continued) 

Financial assets – Business model assessment 

The Group  makes an  assessment of the financial assets it holds to best reflect the way in which the business is 
managed and information is provided to management. The information may include:  

– 

– 

– 

the stated policies and objectives for the group of assets and the operation of those policies in practice;  

how the performance of the assets is evaluated and reported to the Group’s management; and 

the risks that affect the performance of the business and these assets and how those risks are managed. 

Transfers of financial assets to third parties in transactions that do not qualify for derecognition are not considered 
sales for this purpose, consistent with the Group’s continuing recognition of the assets. 

Financial assets that are held for trading or are managed and whose performance is evaluated on a fair value basis 
are measured at FVTPL.  

Financial assets – Subsequent measurement and gains and losses 

Financial assets at FVTPL  

These assets are subsequently measured at fair value. Net gains and losses, 
including any interest or dividend income, are recognised in profit or loss.  

Financial assets at amortised 
cost  

These  assets  are  subsequently  measured  at  amortised  cost  using  the 
effective  interest  method.  The  amortised  cost  is  reduced  by  impairment 
losses. Interest income, foreign exchange gains and losses and impairment 
are  recognised  in  profit  or  loss.  Any  gain  or  loss  on  derecognition  is 
recognised in profit or loss.  

Financial liabilities – Classification, subsequent measurement and gains and losses 

The Group’s financial liabilities are classified at amortised cost. They are subsequently measured at amortised cost 
using the effective interest method. Interest expense and foreign exchange gains and losses are recognised in profit 
or loss. Any gain or loss on derecognition is also recognised in profit or loss.  

(ii)  Derecognition  

Financial assets  

The  Group  derecognises  a  financial  asset  when  the  contractual  rights  to  the  cash  flows  from  the  financial  asset 
expire, or it transfers the rights to receive the contractual cash flows in a transaction in which substantially all of the 
risks  and  rewards  of  ownership  of  the  financial  asset  are  transferred  or  in  which  the  Group  neither  transfers  nor 
retains substantially all of the risks and rewards of ownership and it does not retain control of the financial asset.  

The Group enters into transactions whereby it transfers assets recognised in its statement of financial position but 
retains either all or substantially all of the risks and rewards of the transferred assets. In these cases, the transferred 
assets are not derecognised. 

39 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(g)  Financial instruments (continued) 

(iii)  Derecognition (continued) 

Financial liabilities  

The Group derecognises a financial liability when its contractual obligations are discharged or cancelled or expire. 
The  Group  also  derecognises  a  financial  liability  when  its  terms  are  modified  and  the  cash  flows  of  the  modified 
liability are substantially different, in which case a new financial liability based on the modified terms is recognised at 
fair value.  

On  derecognition  of  a  financial  liability,  the  difference  between  the  carrying  amount  extinguished  and  the 
consideration paid (including any non-cash assets transferred, or liabilities assumed) is recognised in profit or loss. 

(iv)  Offsetting financial assets and liabilities 

Financial assets and financial liabilities are offset, and the net amount presented in the statement of financial position 
when, and only when, the Group currently has a legally enforceable right to set off the amounts and it intends either 
to settle them on a net basis or to realise the asset and settle the liability simultaneously.  

(h)  Share capital 

Ordinary shares are classified as equity.  Costs directly attributable to the issue of the shares are recognised as a 
deduction from share premium. 

Treasury shares are those shares purchased by the STM Group Employee Benefit Trust (“EBT”) for distribution to 
executives  and  senior  management  within  the  Group,  which  have  yet  to  be  allotted  to  specific  employees.  The 
consideration paid, including any attributable incremental costs (net of income taxes), is deducted from the reserves 
attributable to the Group’s equity holders until the shares are cancelled or reissued via the Treasury Reserve. 

(i)  Leases 

At inception of a contract, the Group assesses whether a contract is, or contains, a lease. A contract is, or contains, 
a lease if the contract conveys the right to control the use of an identified asset for a period of time in exchange for 
consideration. To assess whether a contract conveys the right to control the use of an identified asset, the Group 
uses the definition of a lease in IFRS 16. 

At  commencement  or  on  modification  of  a  contract  that  contains  a  lease  component,  the  Group  allocates  the 
consideration in the contract to each lease component on the basis of its relative stand-alone prices.  

The Group recognises a right-of-use asset and a lease liability at the lease commencement date. The right-of-use 
asset is initially  measured  at cost, which comprises the  initial amount  of the  lease liability  adjusted for any lease 
payments made at or before the commencement date, plus any initial direct costs incurred and an estimate of costs 
to dismantle and remove the underlying asset or to restore the underlying asset or the site on which it is located, less 
any lease incentives received.  

The right-of-use asset is subsequently depreciated using the straight-line method from the commencement date to 
the end of the lease term. In addition, the right-of-use asset is periodically reduced by impairment losses, if any, and 
adjusted for certain re-measurements of the lease liability.  

The  lease  liability  is  initially  measured  at  the  present  value  of  the  lease  payments  that  are  not  paid  at  the 
commencement date, discounted using the Group’s incremental borrowing rate.  

The lease liability is measured at amortised cost using the effective interest method. It is re-measured when there is 
a change in future leases payments.  When the lease liability is remeasured in this way, a corresponding adjustment 
is made to the carrying amount of the right-of-use asset or is recorded in profit or loss if the carrying amount of the 
right-of-use asset has been reduced to zero.  

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(i)  Leases (continued) 

Where a lease has a term of less than 12 months or is of a value of less than £5,000, the Group applies the exemption 
not  to  recognise  right-of-use  assets  and  liabilities  for  these  leases.  The  Group  recognises  the  lease  payments 
associated with these leases as an expense on a straight-line basis over the lease term. 

(j)  Employee benefits 

The Group operates a defined contribution pension plan. Obligations for contributions to defined contribution pension 
plans are recognised as an expense in the income statement when they are due. 

(k)  Finance income and expenses 

Finance income comprises interest income on funds invested and dividend income. Interest income is recognised as 
it accrues using the effective interest method. Dividend income in the holding company is recognised when declared 
by the subsidiaries.  

Finance expense comprises interest on borrowings. Interest expense is charged to the income statement using the 
effective interest method. 

(l) 

Income tax expense 

Income tax expense comprises current and deferred tax. Income tax expense is recognised in the income statement.  

Current  tax  is  the  expected  tax  payable  on  the  taxable  income  for  the  year  using  enacted  tax  rates,  updated  for 
previous period adjustments. Taxable profit differs from net profit as reported in profit or loss because it excludes 
items of income or expense that are taxable or deductible in other years and it further excludes items that are never 
taxable or deductible. The Group’s liability for current tax is calculated using tax rates that have been enacted or 
substantively enacted by the end of the reporting period. 

Deferred tax is recognised using the balance sheet method, providing for temporary differences between carrying 
amounts of assets and liabilities for financial reporting purposes and for tax purposes. Deferred tax is not provided 
in respect of goodwill. Deferred tax is measured at the tax rates expected to be enacted when they reverse. 

Deferred  tax  liabilities  are  generally  recognised  for  all  taxable  temporary  differences  and  deferred  tax  assets  are 
recognised to the extent that it is probable that taxable profits will be available against which deductible temporary 
differences can be utilised. Such assets and liabilities are not recognised if the temporary difference arises from the 
initial recognition of goodwill or from the initial recognition (other than in a business combination) of other assets and 
liabilities in a transaction that affects neither the taxable profit nor the accounting profit.  In addition, a deferred tax 
liability is not recognised if the temporary difference arises from the initial recognition of goodwill. 

The carrying amount of deferred tax assets is reviewed at each reporting date and reduced to the extent that it is no 
longer probable that sufficient taxable profits will be available to allow all or part of the asset to be recovered. 

The  measurement  of  deferred  tax  liabilities  and  assets  reflects  the  tax  consequences  that  would  follow  from  the 
manner in which the Group expects, at the end of the reporting period, to recover or settle the carrying amount of its 
assets and liabilities. 

41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(l) 

Income tax expense (continued) 

Deferred tax assets and  liabilities are  offset when there is a legally enforceable right to set off current tax assets 
against current tax  liabilities and  when they relate to income  taxes  levied by  the same  taxation authority and the 
Group intends to settle its current tax assets and liabilities on a net basis. 

(m)  Intangible assets  

(i)  Goodwill 

Goodwill  represents  the  excess  of  the  cost  of  the  acquisition,  the  amount  of  any  non-controlling  interests  in  the 
acquiree and the fair value of the acquirer's previously held equity interest in the acquiree (if any) over the  Group's 
interest in the net fair value of the identifiable assets and liabilities of the acquire. Goodwill is not amortised but is 
measured at cost less accumulated impairment losses. On disposal of a cash-generating unit, the attributable amount 
of goodwill is included in the determination of the profit or loss on disposal. 

For the purpose of impairment testing, goodwill is allocated to each of the Group’s cash-generating units (or groups 
of cash-generating units) expected to benefit from the synergies of the combination. Cash-generating units to which 
goodwill has been allocated are tested for impairment annually, or more frequently when there is an indication that 
the unit may be impaired. If the recoverable amount of the cash-generating unit is less than the carrying amount of 
the unit, the impairment loss is allocated first to reduce the carrying amount of any goodwill allocated to the unit and 
then  to  the  other  assets  of  the  unit  pro-rata  on  the  basis  of  the  carrying  amount  of  each  asset  in  the  unit.  An 
impairment loss recognised for goodwill is not reversed in a subsequent period. 

(ii)  Product development 

Product development relates to internal development expenditure incurred in the development of the Group’s new 
products.  When  these  costs  meet  the  recognition  criteria  of  IAS  38  ‘Intangible  Assets’  they  are  capitalised  and 
amortised on a straight-line basis over a three-year period from product launch.  

(iii)  Client portfolio 

Client  portfolios  acquired  in  a  business  combination  are  recognised  separately  from  goodwill  and  are  recognised 
initially at their fair value at the acquisition date (which is regarded as their cost).  Subsequent to initial recognition it 
is amortised on a straight-line basis over the estimated useful life which is assessed at ten years. 

(iv)  IT development 

IT development relates to internal and external development expenditure incurred in the development of the Group’s 
IT systems. When these costs meet the recognition criteria of IAS 38 ‘Intangible Assets’ they are capitalised and 
amortised on a straight-line basis over a five-year period when a specific IT module comes into use.   

(n) 

Impairment 

(i)  Non derivative financial assets 

Financial instruments and contract assets  

The  Group  and  Company  measures  loss  allowances  for  Expected  Credit  Losses  (“ECL”)  on  financial  assets 
measured at amortised cost and contract assets.  

When determining whether the credit risk of a financial asset has increased significantly since initial recognition and 
when estimating ECLs, the Group considers reasonable and supportable information that is relevant and available 
without undue cost or effort. This includes both quantitative and qualitative information and analysis based on the 
Group’s historical experience and informed credit assessment.  

Lifetime ECLs are the ECLs that result from all possible default events over the expected life of a financial instrument.  

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(n) 

Impairment (continued) 

(i)  Non derivative financial assets (continued) 

Financial instruments and contract assets (continued) 

12-month ECLs are the portion of ECLs that result from default events that are possible within the 12 months after 
the reporting date (or a shorter period if the expected life of the instrument is less than 12 months).  

The maximum period considered when estimating ECLs is the maximum contractual period over which the Group is 
exposed to credit risk. Loss allowances for financial assets measured at amortised cost are deducted from the gross 
carrying amount of the assets and are recognised in the statement of comprehensive income. 

The Group measures loss allowances at an amount equal to lifetime ECLs, except for bank balances for which credit 
risk  has  not  increased  significantly  since  initial  recognition,  which  are  measured  at  12-month  ECLs.  The  Group 
considers the following as constituting an event of default for internal credit risk management purposes as historical 
experience indicates that financial assets that meet both of the following criteria are generally not recoverable: 

– 

– 

when there is a breach of the contractual credit terms by the debtor; and 

there is insufficient liquidity within the debtor’s pension assets.   

Write-off 

The  gross  carrying  amount  of  a  financial  asset  is  written  off  when  the  Group  has  no  reasonable  expectations  of 
recovering a financial asset in its entirety or a portion thereof. The Group individually makes an assessment with 
respect to the timing and amount of write-off based on whether there is a reasonable expectation of recovery. The 
Group expects no significant recovery from the amount written off. However, the Group may still follow procedures 
for recovery of financial assets that have been written off. 

(ii)  Non-financial assets 

The carrying amounts of the Group’s non-financial assets are reviewed at each reporting date to determine whether 
there is any indication of impairment. If any such indication exists then the asset’s recoverable amount is estimated. 
For  goodwill  which  has  an  indefinite  life,  the  recoverable  amount  being  the  higher  of  the  fair  value  less  costs  of 
disposal or value in use is estimated at each reporting date. 

An  impairment  loss  is  recognised  if  the  carrying  amount  of  an  asset  or  its  cash-generating  unit  exceeds  its 
recoverable amount. A cash-generating unit is the smallest identifiable asset group that generates cash flows that 
largely are independent from other assets and groups. Impairment losses are recognised in the income statement.  

Impairment losses recognised in respect of cash-generating units are allocated first to reduce the carrying amount 
of any goodwill allocated to the units and then to reduce the carrying amount of the other assets in the unit (group of 
units) on a pro-rata basis. 

(o)  Earnings per share 

The  Group  presents  basic  and  diluted  earnings  per  share  (“EPS”)  data  for  its  ordinary  shares.    Basic  EPS  is 
calculated by dividing the profit or loss attributable to ordinary shareholders of the Company by the weighted average 
number of ordinary shares outstanding during the period. Diluted EPS is determined by adjusting the profit or loss 
attributable to ordinary shareholders and the weighted average number of ordinary shares outstanding for the effects 
of  all  dilutive  potential  ordinary  shares,  which  comprise  the  effect  of  outstanding  options.  The  effects  of  potential 
ordinary  shares  are  reflected  in  diluted  EPS  only  when  their  inclusion  in  the  calculation  would  decrease  EPS  or 
increase the loss per share. 

43 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(p)  Deferred income 

Deferred  income  relates  to  the  element  of  fixed  fee  income  that  has  been  billed  in  advance  which  has  not  been 
earned  as  at  the  year  end  and  is  released  over  the  period  to  which  it  relates.  100%  of  the  balance  recorded  as 
deferred income at 31st December 2023 is expected to be included as revenue in the next financial year. 

(q)  Provisions 

Provisions are recognised when the Group has a present obligation (legal or constructive) as a result of a past event, 
it  is  probable  that  the  Group  will  be  required  to  settle  that  obligation  and  a  reliable  estimate  can  be  made  of  the 
amount of the obligation. 

The  amount  recognised  as  a  provision  is  the  best  estimate  of  the  consideration  required  to  settle  the  present 
obligation at the reporting date, taking into account the risks and uncertainties surrounding the obligation. Where a 
provision  is  measured  using  the  cash  flows  estimated  to  settle  the  present  obligation,  its  carrying  amount  is  the 
present value of those cash flows (when the effect of the time value of money is material). 

When some or all of the economic benefits required to settle a provision are expected to be recovered from a third 
party,  a  receivable  is  recognised  as  an  asset  if  it  is  virtually  certain  that  reimbursement  will  be  received  and  the 
amount of the receivable can be measured reliably.  

(r)  Dividend 

Dividends are recognised in the accounting period in which they are authorised and paid.  The interim dividend is 
recognised when it is paid and the final dividend is recognised when it has been approved by shareholders at the 
Annual General Meeting. Payment of a dividend is permissible in accordance with s57 of the Companies Act 2006 
(IOM) and the Articles of Association given that the solvency test has been met. 

(s)  Share based payments 

The grant-date fair value of equity settled share payment arrangements granted to employees is recognised as an 
expense,  with  a  corresponding  increase  in  equity,  over  the  vesting  period  of  the  awards.  Where  awards  have  a 
market-based  performance  condition  attached  the  accounting  charge  reflects  the  expected  achievement  against 
targets and there is no true-up for differences between expected and actual outcomes. 

(t) 

Insurance products 

The life assurance business account for insurance products as investment contracts as no significant insurance risk 
is attached to these contracts. The assets and liabilities of the contracts are included in the Group’s balance sheet 
only if it is deemed that control exists over the investment decision (see Note 8). 

(u)  Disputes and potential legal matters  

The  Group  may  at  times  be  involved  in  disputes  arising  in  the  ordinary  course  of  business.  In  accordance  with 
applicable  accounting  requirements,  the  Group  provides  for  potential  losses  that  may  arise  out  of  these  disputes 
when  the  potential  losses  are  probable  and  estimable.  Disputes  in  respect  of  legal  matters  are  subject  to  many 
uncertainties  and  the  outcome  of  individual  matters  cannot  be  predicted  with  certainty.  The  amount  of  any  such 
provision is based on a best estimate of the expenditure required to settle this. There may be occasions when either 
a potential loss is probable but difficult to quantify or a potential loss can be reliably quantified but is not probable. 
On both occasions a contingent liability would be disclosed.   

44 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

3.  Material accounting policies (continued) 

(v)   New standards and interpretations  

The Group has adopted Disclosure of Accounting Policies (Amendments to IAS 1 and IFRS Practice Statement 2) 
for the first time for the financial year commencing 1 January 2023. Standards, amendments, and interpretations to 
existing standards that are not yet effective and have not been early adopted by the Group. 

The following standards, interpretations and amendments to existing standards have been published by the IASB 
but are not effective for the period presented in the financial statements and the Group has decided not to early adopt 
them. 

Standard  
Amendments  to  IAS  1,  Classification  of  Liabilities  as  Current  or  Non-
Current 

Amendments to IAS 1, Non-current Liabilities with Covenants 

Amendments to IAS 7 and IFRS 7, Supplier Finance Arrangements 

Amendments to IFRS 16, Lease Liability in a Sale and Leaseback 

Amendments to IAS 21, Lack of Exchangeability 

Effective date, annual period 
beginning on or after  

1st January 2024 

1st January 2024 

1st January 2024 

1st January 2024 

1st January 2025 

None of the proposed amendments to IAS or IFRS noted above are expected to have any material impact on the 
Group. 

(w)   Cash and cash equivalents 

Cash and cash equivalents include cash balances with banks and, demand and short-term deposits which are readily 
convertible to known amounts of cash and are subject to an insignificant risk of changes in their fair value. Short term 
deposits have a maturity of three months or less from the date of acquisition. Cash and cash equivalents are carried 
at amortised cost in the statement of financial position. 

(x)   Investment in subsidiaries 

Investments in subsidiaries in the separate financial statements of STM Group PLC are accounted for at cost. 

4.  Disposal of subsidiaries  

There were no disposals of subsidiaries in the two years ended 31st December 2023 and 31st December 2022. The 
loss on disposal reported in 2022 comprised a reduction in the final consideration received in that year in respect of 
the  disposal  of  the  Group’s  Gibraltar  company  and  trustee  services  (“CTS”)  and  tax  compliance  business,  STM 
Fidecs Management Limited, and the Jersey based CTS business, STM Fiduciaire Limited, in 2021. The reduction 
arose from audited revenues for those businesses being lower than originally estimated. 

45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

5.  Acquisition of portfolios 

There were no acquisitions in 2023. 

On 31st August 2022, the Group acquired the portfolios, net assets and trustee companies of the SIPP and SSAS 
businesses  from  Mercer  Ltd  (“the  Portfolio”).  The  acquisition  of  the  Portfolios  was  complementary  to  the  Group's 
existing product offerings in the UK SIPP and SSAS markets and provided a solid platform for scalability, particularly 
for the Group’s SSAS operations, and efficiencies going forward.  In addition, it provided the Group with access to 
an expanded network of intermediaries who previously introduced clients to Mercer Ltd.  

The Group paid a gross cash consideration of £3,340,000 to acquire the Portfolios. Such consideration included the 
purchase of the net assets of the business which primarily related to fees yet to be collected from clients. 

The acquisition was accounted for using the acquisition method. Transaction costs incurred on the acquisition totalled 
£150,000  and  were  expensed  within  administrative  expenses  in  the  Consolidated  Statement  of  Comprehensive 
Income for the year ended 31st December 2022.   

Details of the fair value of the client portfolio, assets and liabilities acquired are set out as follows: 

Client portfolios 
Fixed assets 
Accrued income 
Debtors(1) 
Prepaid assets 
Liabilities 
Total identifiable net assets acquired 

Fair value 
recognised on 
acquisition 
£’000 
2,757 
10 
107 
831 
28 
(66) 
3,667 

Fair value 
adjustments 
£’000 
2,757 
- 
- 
- 
- 
- 
2,757 

Previous carrying 
value 
£’000 
- 
10 
107 
831 
28 
(66) 
910 

Note 1: The fair value of debtors was approximately the gross contractual amount at the acquisition date. 

At acquisition the Group performed  a valuation  on the client portfolios acquired  using the  market approach. As a 
result, client portfolio assets of £1,543,000 relating to the SIPP portfolio and £1,214,000 related to the SSAS portfolio 
were recognised.  

A bargain purchase gain arose as a result of negotiations due to the previous revenue recognition policy being more 
aggressive than, and an adjustment being necessary to align that policy with, the Group’s more conservative policy. 
This has resulted in the fair value of the identifiable net assets being higher than the cash consideration paid as noted 
below:  

Total consideration transferred 
Fair value of identifiable net assets 
Bargain purchase gain 

£’000 
3,340 
(3,667) 
(327) 

The  bargain  purchase  gain  was  attributable  to  the  Portfolio  acquired  and  was  recognised  in  the  consolidated 
statement of comprehensive income for the year ended 31 December 2022. 

From the effective date of acquisition to 31st December 2022, the SIPP and SSAS portfolios generated revenue of 
£821,000  and  incurred  a  loss  of  £145,000.  If  the  acquisition  had  occurred  on  1st  January  2022,  management 
estimates that the impact on the consolidated revenue and profit before tax for the year ended 31st December 2022 
would have been £2,243,000 and a loss of £99,000 respectively. 

In addition, the Group paid deferred cash consideration of £217,000 during the year (2022: £114,000) relating to the 
final payment for the acquisition of the Berkeley Burke companies completed in 2020. The consideration paid in 2023 
was £161,000 higher than the amount provided as at 31st December 2022 due to the collection and onward remittance 
of trade receivables due to the seller under the relevant share purchase agreements but not previously provided.  

46 

 
 
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

5. Acquisition of portfolios (continued) 

The Group also paid additional net consideration in 2023 of £11,000 in respect of the companies and SIPP and SSAS 
portfolios acquired from Mercer Limited in 2022. 

As these acquisitions were completed more than twelve months prior to the dates of payment in the current reporting 
period, the aggregate amount of £172,000, net of the amount provided at 31st December 2022, has been written off 
to administrative expenses in 2023. 

6.  Acquisition of non-controlling interests 

As part of the acquisition of Carey Administration Holdings Limited (“Options”) in 2019, the Group entered into call 
option  agreements  to  acquire  the  non-controlling  interests  (“NCIs”)  in  Options  Corporate  Pensions  UK  Limited 
(“OCPUK”) and Options UK Personal Pensions LLP (“OSUK”) from the current owner of the NCIs. The call options 
were exercisable in 2022 with the exercise prices based on the audited financial statements of these entities for the 
year ended 31st December 2021.  

On 9th November 2022, the Group issued the Exercise Notices to the current owner of the NCIs for acquiring the 
additional interests in OCPUK and OSUK.  

Options Corporate Pensions UK Limited 

On  30th  November  2022,  the  Group  completed  the  transaction  to  acquire  an  additional  20%  interest  in  OCPUK, 
increasing  its  ownership  from  80%  to  100%.  The  carrying  amount  of  OCPUK’s  net  liabilities  in  the  Group’s 
consolidated financial statement on the date of acquisition was £1,870,000. 

Carrying amount of NCIs acquired (£1,870,000 x 20%) 
Exercise of OCPUK’s call option 
Cash consideration paid to NCIs 
A decrease in equity attributable to owners of the Company 

£’000 
374 
881 
120 
1,375 

The decrease in equity attributable to owners of the Company was recognised in the other reserve for the year ended 
31st December 2022.  

Options Pensions UK LLP 

On 12th January 2023, the Group completed the transaction to acquire an additional 30% interest in OSUK, increasing 
its ownership from 70% to 100%. The carrying amount of OSUK’s net liabilities in the Group’s consolidated financial 
statement on the date of acquisition was £227,000. 

Carrying amount of NCIs acquired (£227,000 x 30%) 
Exercise of OSUK’s call option 
Cash consideration paid to NCIs 
A decrease in equity attributable to owners of the Company 

£’000 
68 
- 
400 
468 

The decrease in equity attributable to owners of the Company has been recognised in the other reserve for the year 
ended 31st December 2023.  

47 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

7.  Segmental Information 

STM Group has three reportable segments: Pensions, Life Assurance and Other Services. Each segment is defined 
as  a  set  of  business  activities  generating  a  revenue  stream  and  offering  different  services  to  other  operating 
segments. The Group’s operating segments have been determined based on the management information reviewed 
by the CEO and Board of Directors (the “Board”). 

The Board assesses the performance of the operating segments based on turnover generated. The performance of 
the operating segments is not measured using costs incurred as the costs of certain segments within the Group are 
predominantly centrally controlled and therefore the allocation of these is based on utilisation of internally calculated 
proportions. Management believes that this information and consequently profitability could potentially be misleading 
and would not enhance the disclosure above. 

The following table presents the turnover information regarding the Group’s operating segments: 

Operating segment 

Pensions 
Life Assurance 
Other services 
Total 

Turnover 

2023 
£000 
23,474 
4,039 
565 

28,078 

Analysis of the Group’s turnover information by geographical location is detailed below: 

Geographical segment 

Gibraltar 
Malta 
United Kingdom 
Other 
Total 

Turnover 

2023 
£000 
6,112 
7,146 
14,358 
462 

28,078 

2022 
£000 
18,421 
5,001 
672 
24,094 

2022 
£000 
7,324 
7,178 
9,110 
482 
24,094 

8.  Life Assurance Operating Segment 

These consolidated financial statements include the results for STM Life Assurance PCC PLC and London & Colonial 
Assurance PLC, two 100% owned subsidiaries whose principal activities are that of the provision of life assurance 
services. These companies are licenced to carry on linked long-term insurance business under the Financial Services 
(Insurance Companies) Act by the Gibraltar Financial Services Commission.  

For  the  purposes  of  these  consolidated  financial  statements,  only  the  shareholders’  funds  and  surpluses  that 
emerges  on  the  long-term  funds  have  been  included.  The  assets  invested  by  the  Life  Assurance  clients  are 
determined  by  either  the  clients  or  their  advisers  and  are  segregated  from  the  assets  and  liabilities  of  other 
clients. Therefore, the Group considers that it does not control the investment decision nor does it bear any financial 
risk in respect of that decision and, therefore, the investment assets and associated liabilities to the customers should 
not  be  presented  within  the  consolidated  statement  of  financial  position.  The  total  revenue  of  the  Group  of 
£28,078,000 (2022: £24,094,000) included £4,039,000 (2022: £5,001,000) relating to revenues attributable to the life 
assurance businesses. 

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

9.  Revenue 

Revenue from provision of retirement and life assurance 
solutions and related administrative services 
Interest and investment income 
Total revenue 

31 December 2023 
£000 

31 December 2022 
£000 

24,338 
3,740 
28,078 

23,563 
531 
24,094 

10.  Administrative expenses 

Included within administrative expenses are personnel costs as follows: 

Wages and salaries 
Social insurance costs 
Pension contributions 
Total personnel expenses 

Average number of employees 

Group 
Average number of people employed  
(including executive directors)  

Company 
Average number of people employed  
(including executive directors) 

11.  Profit before other items 

31 December 2023 
£000 
12,263 
1,045 
398 
13,706 

31 December 2022 
£000 
11,633 
484 
104 
12,221 

31 December 2023 
Number 

31 December 2022 
Number 

293 

285 

31 December 2023 
Number 

31 December 2022 
Number 

33 

32 

Profit before other items of £3,200,000 (2022: £3,321,000), was arrived at after charging the following to the income 
statement: 

(Loss)/profit on disposal of property and office equipment 
Directors’ remuneration  
Auditors’ remuneration for audit services 

The directors’ remuneration report is included on page 20. 

31 December 2023 
£000 
(96) 
588 
450 

31 December 2022 
£000 
4 
663 
472 

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

12.  Reconciliation of reported to adjusted measures 

Reported measure 

Add: adjustment due to revenue 
recognition policy change on 
acquisition 

Add: integration and acquisition cost 

Add: Professional advisory costs 
incurred in relation to the proposed 
acquisition of the Company 

Add: write-off of debtors related to prior 
year disposals 

Less: bargain purchase gain on 
acquisition  

Less: loss on disposal of companies 
and trust management 
Add: costs of strategic reviews 
Add: senior management exit costs, 
non-recurring professional costs and 
other non-recurring costs  

Revenue 

2023 
£000 

2022 
£000 

28,078 

24,094 

Profit before other 
items 

2023 
£000 

3,200 

2022 
£000 

3,321 

Profit before tax 

2023 
£000 

442 

2022 
£000 

1,578 

- 

- 

- 

- 

- 

- 
- 

- 

505 

- 

- 

- 

- 

- 
- 

- 

505 

390 

- 

- 

- 

- 

505 

390 

- 

- 

1,202 

761 

- 

- 
135 

- 

- 

- 

- 
- 

1,202 

761 

- 

(327) 

135 

162 
- 

526 

470 

526 

470 

Adjusted measure 

28,078 

24,599 

5,824 

4,686 

3,066 

2,778 

Adjusted measures exclude non-recurring costs and other exceptional items including bargain purchase gains that do 
not form part of the normal course of business. 

13.  Taxation 

Current tax expense 

Deferred tax expenses/(income) 

Release of deferred tax assets on leases as per IFRS 16 

Release of deferred tax liabilities on intangible assets 

Total tax expense 

31 December 2023 
£000 

31 December 2022 
£000 

91 

19 

(85) 

25 

766 

18 

(60) 

724 

50 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

13.  Taxation (continued) 

Reconciliation of existing tax rate 

Profit before tax for the year 

Income tax using the Company’s domestic rate  
Effect of tax rates in other jurisdictions 
Release of deferred tax assets on leases as per 
IFRS 16 
Release of deferred tax liabilities on intangible 
assets 
Total tax expense 

2023 
% 

- 

0.00% 
20.59% 

4.30% 

(19.23%) 
- 

31 December 
2023 
£000 

442 

- 
91 

19 

2022 
% 

- 

0.00% 
48.54% 

1.14% 

(85) 
25 

(3.80%) 
- 

31 December  
2022 
£000 

1,578 

- 
766 

18 

(60) 
724 

Effective tax rate (%) 

- 

5.66% 

- 

45.88% 

The effective tax rate for UK increased to 25% from 1 April 2023. The effective tax rates in Malta and Gibraltar are 5% 
and  12.5%  respectively.  The  Group  effective  tax  rate  is  lower  in  the  year  ended  31st  December  2023  than  the 
jurisdictional effective tax rate due to the writeback of tax over provided for in prior years. However, in the year ended 
31st  December  2022,  the  Group  effective  tax  rate  was  higher  than  the  jurisdictional  effective  tax  rate  because  tax 
losses brought forward or incurred in that year in some jurisdictions could not be utilised by the profitable subsidiaries 
in other jurisdictions and dividends remitted to the holding company by overseas jurisdictions were higher than in the 
prior year thus resulting in a higher tax charge on these. 

51 

 
 
 
 
 
Total 
£000 

8,006 

165 

10 
(6) 

8,175 
859 

(5,924) 

3,110 

6,343 

673 

(2) 

7,014 
620 

(5,828) 

1,806 

- 

- 
- 

5,585 
689 

(4,705) 

1,569 

4,605 

487 

- 

5,092 
455 

(4,705) 

842 

2 

- 
- 

492 
- 

(15) 

477 

380 

20 

- 

400 
20 

(4) 

416 

92 
61 

493 
727 

1,161 
1,304 

STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

14.  Property and office equipment 

Motor 
Vehicles 
£000 

Office 
Equipment 
£000 

Leasehold 
Improvements 
£000 

Right-of-use 
Assets 
£000 

Note 

490 

5,585 

Group 
Costs 

At 1st January 2022 

Additions 
Acquired  through  business 
combination 
Disposals 
At 31st December 2022 and                 
1st January 2023 
Additions 

 5 

Disposals 

At 31st December 2023 

Depreciation 

At 1st January 2022 

Charge for the year 

Disposals 
At 31st December 2022 and           
1st January 2023 
Charge for the year 

Disposals 

At 31st December 2023 

Net Book Value 

At 31st December 2022 

At 31st December 2023 

15 

- 

- 
- 

15 
- 

(15) 

- 

12 

1 

- 

13 
2 

1,916 

163 

10 
(6) 

2,083 
170 

(1,189) 

1,064 

1,346 

165 

(2) 

1,509 
143 

(15) 

(1,104) 

- 

2 
- 

548 

574 
516 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

14.  Property and office equipment (continued) 

Company 
Costs  

At 1st January 2022 

Additions  

At 31st December 2022 and 1st January 2023 

Additions  

Disposal 

At 31st December 2023 

Depreciation 

At 1st January 2022 

Charge for the year 

At 31st December 2022 and 1st January 2023 

Charge for the year 

At 31st December 2023 

Net book value 

At 31st December 2022 

At 31st December 2023 

Office 
Equipment 
£000 

771 

10 

781 
14 

- 

795 

532 

35 

567 
32 

599 

214 

196 

53 

 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

15.  Intangible assets 

Group 
Costs  

Note 

Goodwill 
£000 

Client 
Portfolio 
£000 

Product 
Development 
£000 

IT 
Development 
£000 

Total 
£000 

At 1st January 2022 

14,109 

5,742 

Additions 
Acquired through business 
combination 
At 31st December 2022 and            
1st January 2023 
Additions 

5 

At 31st December 2023 

Amortisation and impairment 

At 1st January 2022 

Charge for the year 

At 31st December 2022 and 1st 
January 2023 
Charge for the year 

At 31st December 2023 

- 

- 

14,109 
- 

14,109 

824 

- 

824 
- 

824 

- 

2,757 

8,499 
- 

8,499 

1,717 

574 

2,291 
850 

3,141 

Carrying amounts 

At 31st December 2022 

At 31st December 2023 

13,285 

13,285 

6,208 

5,358 

Impairment testing for cash-generating units containing goodwill 

701 

30 

- 

731 
- 

731 

445 

30 

475 
57 

532 

256 

199 

2,242  22,794 

907 

937 

- 

2,757 

3,149  26,488 
672 

672 

3,821  27,160 

453 

320 

3,439 

924 

773 
446 

4,363 
1,353 

1,219 

5,716 

2,376  22,125 

2,602  21,444 

All goodwill relates to acquisitions made and reflects the difference between the fair value of the identifiable net asset 
value of those acquisitions and the fair value of the consideration paid for those acquisitions.  

Goodwill represents the excess of the cost of the acquisition, the amount of any non-controlling interests in the acquiree 
and the fair value of the acquirer's previously held equity interest in the acquiree (if any) over the Group's interest in the 
net fair value of the identifiable assets and liabilities of the acquire. Goodwill is not amortised but is measured at cost 
less  accumulated  impairment  losses.    Additionally,  on  disposal  of  a  cash-generating  unit  (“CGU”),  the  attributable 
amount of goodwill is included in the determination of the profit or loss on disposal.  

Goodwill is allocated to the smallest identifiable group of assets that generate largely independent inflows. Management 
have assessed the number of CGUs and determined that there are four identifiable CGUs, which are also operating and 
reportable segments. CGUs are determined based on whether the entity is a separate and distinct entity and/or whether 
that entity is management as a standalone business unit. 

54 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

15.  Intangible assets (continued) 

Impairment testing for cash-generating units containing goodwill (continued) 

The carrying amount of goodwill allocated to each of the CGUs is as follows: 

STM Life 
LCA 
FLHP 
Options - Berkeley Burke acquisition 

Total 

2023 
£000 

1,256 
7,735 
3,698 
596  

13,285 

2022 
£000 

1,256 
7,735 
3,698 
596  

13,285 

The Group tests goodwill annually for impairment or more frequently if there is an indication that a CGU or group of 
CGUs may be impaired. The annual impairment assessment is made by comparing the carrying amount of the CGU 
or group of CGUs to which goodwill has been allocated with the recoverable amount of the CGU or group of CGUs.  

The recoverable amount of each CGU or group of CGUs as at 31st December 2023 has been determined based on 
a value in use calculation using cash flow projections from financial budgets prepared for the subsequent three years 
and which have been approved by the Board. The subsequent two years’ cashflows have been calculated based on 
the following assumptions thereby providing a five-year estimate of prospective net cashflows: 

Percentage ranged from: 

Revenue growth rates and attrition 

Expense increases and inflation rates 

2023 
% 

2022 
% 

-1.5% - 2% 

-1.5% - 4% 

-2% - 3% 

-3% - 4% 

The  range  of  revenue  growth  and  attrition  rates,  and  those  for  expense  increases  and  inflation,  has  narrowed  in 
comparison with 2022,to bring the assumptions for certain business units in line with those  used elsewhere in the 
Group. As goodwill is considered to have an indefinite life the year 5 net cashflow has been extrapolated to perpetuity. 
A  post-  tax  discount  rate  of  13.5%  (2022:  14%)  has  been  used  in  discounting  the  projected  cashflows.    It  was 
concluded that the fair value less costs of disposal did not exceed the value in use. 

As  a  result  of  this  analysis,  no  impairment  charge  has  been  recognised  in  either  of  the  two  years  ended 
31st December 2023 or 31st December 2022.  

Key assumptions used in value in use calculations and sensitivity to changes in assumptions 

The calculation of the value in use for the CGUs is most sensitive to the following assumptions: 

•  Revenue growth rates and customer attrition rates 
• 
•  Discount rates 

Expense increases and inflation rates 

Revenue growth rates and attrition – a higher decline in revenue growth rates and/or an increase in attrition rates 
would result in a further impairment charge being required. A 1% reduction in both revenue growth and attrition rates 
would result in a potential impairment charge of approximately £199,000 (2022: £185,000).  

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

15.  Intangible assets (continued) 

Key assumptions used in value in use calculations and sensitivity to changes in assumptions (continued) 

Expense increases and inflation rates – management has considered the possibility of increased inflation resulting 
in higher than anticipated costs and an increase in expenses growth rates would result in potential impairment. A 1% 
increase in the expense growth rates would result in a potential impairment charge being required of approximately 
£50,000 (2022: £nil).  

Discount rates – discount rates represent the current market assessment of the risks specific to each CGU, taking 
into  consideration  the  time  value  of  money  and  individual  risks  of  the  underlying  assets  that  have  not  been 
incorporated in the cash flow estimates. The discount rate calculation is based on the specific circumstances of the 
Group and its operating segments and is derived from its weighted average cost of capital (“WACC”). The WACC 
considers both debt and equity. The cost of equity is derived from the expected return on investment by the Group’s 
investors. The cost of debt is based on the interest-bearing borrowings the Group is obliged to service. Segment-
specific risk is incorporated by applying individual beta factors. The beta factors are evaluated annually  based on 
publicly available market data. Adjustments to the discount rate is made to factor in the specific amount and timing 
of the future tax flows in order to reflect a pre-tax discount rate. A 1% increase in the WACC would result in a potential 
impairment charge of approximately £173,000 (2022: £229,000). 

Management  also  considered  the  potential  impact  of  a  scenario  that  combines  adverse  changes  in  all  three  key 
metrics, namely where the revenue growth rate reduces by 1%, expenses increase by 1% and the WACC increases 
by 1%. This would result in a potential impairment charge of approximately £510,000 (2022: £1,194,000). 

Client portfolio 

Client  portfolio  assets  acquired  in  a  business  combination  are  recognised  separately  from  goodwill  and  are 
recognised  initially  at  fair  value  at  the  acquisition  date  and  subsequently  assessed  annually  for  impairment.  The 
Group’s  client  portfolios  are  amortised  over  the  useful  lives  which  have  been  determined  to  be  ten  years.  Client 
portfolios acquired through acquisitions are as follows: 

London & Colonial Services Ltd 

STM Nummos Life SL 

Harbour Pensions Ltd 

Options Corporate Pensions UK Limited 

Options UK Personal Pensions LLP 

Options SSAS Limited 

Options EBC Limited 

SIPP portfolio acquired from Mercer Ltd 

SSAS portfolio acquired from Mercer Ltd 

Total 

Acquisition date 
October 2016 

 January 2018 

February 2018 

February 2019 

February 2019 

August 2020 

August 2020 

August 2022 

August 2022 

31 December 
2023 
£000 
283 

31 December 
2022 
£000 
383 

173 

453 

359 

615 

199 

795 

1,389 

1,092 

5,358 

215 

545 

429 

735 

229 

915 

1,543 

1,214 

6,208 

56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

15.  Intangible assets (continued)  

Company 
Costs  
At 1st January 2022 
Additions 
At 31st December 2022 and 1st January 2023 
Additions 
At 31st December 2023 

Amortisation and impairment 
At 1st January 2022 
Charges for the year 
At 31st December 2022 and 1st January 2023 
Charges for the year 
At 31st December 2023 

Carrying amounts 
At 31st December 2022 
At 31st December 2023 

16.  Financial assets 

Group 
Financial instrument designated at FVTPL 
Total 

Product 
Development 
£000 

IT 
Development 
£000 

474 
30 
504 
- 
504 

233 
30 
263 
57 
320 

241 
184 

1,899 
888 
2,787 
445 
3,232 

179 
263 
442 
393 
835 

2,345 
2,397 

Total 
£000 

2,373 
918 
3,291 
445 
3,736 

412 
293 
705 
450 
1,155 

2,586 
2,581 

31 December 
2023 
£000 
1,839 
1,839 

31 December 
2022 
£000 
1,762 
1,762 

The financial instrument designated at FVTPL represents UK sovereign debt instrument with a stated interest rate of 
2% and is held for trading. 

This investment has been classified as Level 1 as its value is derived from quoted prices in active market. 

17.  Investments  

Company – Investments in subsidiaries 

Acquisitions of the Company 

Shares in group undertakings  

Balance at start of year  
Acquisition of non-controlling interests (Note 6) 
Dormant entities closure 
Balance at end of year 

57 

31 December 
2023 
£000 

31 December 
2022 
£000 

17,013 
400 
- 
17,413 

16,013 
1,001 
(1) 
17,013 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

18.  Trade and other receivables 

Group 
Trade receivables 
Prepayments 
Other receivables 
Total 

Company 
Receivables due from related parties  
Other receivables 
Total  

31 December 
2023 
£000 
3,915 
1,691 
1,743 
7,349 

31 December 
2023 
£000 
13,930 
1,365 
15,295 

31 December 
2022 
£000 
4,266 
999 
3,196 
8,461 

31 December 
2022 
£000 
13,708 
2,215 
15,923 

Amounts due from related parties comprise intercompany balances which are unsecured, interest free and repayable 
on demand. 

The Group’s exposure to credit risks and impairment losses related to trade and other receivables (excluding accrued 
income) are described in Note 26. 

19.  Cash and cash equivalents 

Group 
Bank balances 

Company 
Bank balances 

31 December 
2023 
£000 
18,365 

31 December 
2023 
£000 
2,324 

31 December 
2022 
£000 
19,234 

31 December 
2022 
£000 
2,425 

The Group has a secured bank loan liability of £4,813,000 (2022: £5,363,000) which is included within Trade and 
Other Payables in Notes 23 and 24. Details of the security held is set out in Note 23. 

Within cash and cash equivalents held by the Group there is a balance of £4,209,000 (2022: £2,903,000) which is 
not available for use by the Group. This mainly represented the blocked accounts that form part of Options Corporate 
and Options SIPP regulatory requirements and the funds collected on behalf of clients but yet to be paid across to 
the respective clients or relevant authority bodies.  

20.  Capital and reserves 

Authorised, called up, issued and fully paid 
59,408,088 ordinary shares of £0.001 each  
(2022: 59,408,088 ordinary shares of £0.001 each) 

31 December 
2023 
£000 

31 December 
2022 
£000 

59 

59 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

20.  Capital and reserves (continued) 

Ordinary Shares 

Ordinary shares carry full voting rights; full dividend rights; full rights as respects capital, to participate in a distribution 
(including on winding up); no redemption rights. 

Share premium 

There were no new shares issued  during  either  of the two years ended  31st December 2023  and 31st December 
2022.  The  balance  of  the  share  premium  account  as  at  31st  December  2023  amounted  to  £22,372,000  (2022: 
£22,372,000). 

Other reserves 

Other reserves are made up of: 

Treasury reserves 
Foreign Currency translation reserve 
Share based payments reserve 
Other reserve 
Total other reserves 

Treasury shares 

Note 

21 
6 

31 December 
2023 
£000 
549 
49 
(162) 
1,843 
2,279 

31 December 
2022 
£000 
549 
81 
(162) 
1,375 
1,843 

The treasury shares relate to those shares purchased by the STM Group Employee Benefit Trust (EBT) for 
allocation to executives. The trustees of the Employee Benefit Trust held 1,089,780 ordinary shares of £0.001 each 
in the Company at 31st December 2023 and at 31st December 2022. The shares held may be used to satisfy 
awards made to employees and/or senior executives, such as conditional share awards granted under a long-term 
incentive plan. The balance held on the treasury shares account as at 31st December 2023 amounted to £549,000 
(2022: £549,000). 

Translation reserve 

The  translation  reserve  comprises  all  cumulative  foreign  currency  differences  arising  from  the  translation  of  the 
financial  statements  of  foreign  operations.  The  balance  at  31st  December  2023  amounted  to  a  negative  £49,000 
(2022: negative £81,000), with the movement of £32,000 in 2023 (2022: £12,000) representing the foreign currency 
differences arising from the translation of the financial statements of foreign operations during the year. 

Dividends  

The following dividends were declared and paid by the Group during the year:  

Nil pence per qualifying ordinary share (2022: 1.50 pence per qualifying 
ordinary share) 

31 December 
2023 
£000 

31 December 
2022 
£000 

- 

891 

After the respective reporting dates the following dividends were proposed by the Directors. The dividends have not 
been provided for and there are no income tax consequences. 

Nil pence per qualifying ordinary share (2022: 0.60 pence per qualifying 
ordinary share)  

59 

31 December 
2023 
£000 

31 December 
2022 
£000 

- 

356 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

21.  Share based payments 

There was no Long-Term Incentive Plan in place during the year. As such the charge for the year which has been 
recognised within the share-based payment reserve is £Nil (2022: £Nil). The share-based payments reserve at 31st 
December 2023 amounted to £162,000 (2022: £162,000). 

22.  Earnings per share 

Earnings per share for the year from 1st January 2023 to 31st December 2023 is based on the profit attributable to 
owners of £417,000 (2022: £844,000) divided by the weighted average number of £0.001 ordinary shares outstanding 
during the year of 59,408,088 basic (2022: 59,408,088) and £59,408,088 dilutive (2022: 59,408,088) in issue. 

23.  Trade and other payables 

Group 
Deferred income 
Trade payables 
Bank loan (secured) 
Deferred consideration 
Lease liabilities 
Other creditors and accruals 
Total 

Company 
Owed to related parties 
Bank loan (secured) 
Accruals 
Other creditors  
Total 

31 December 
2023 
£000 
3,664 
1,970 
550 
- 
304 
6,783 
13,271 

31 December 
2023 
£000 
8,980 
550 
302 
2,612 
12,444 

31 December 
2022 
£000 
3,842 
882 
552 
56 
570 
6,615 
12,517 

31 December 
2022 
£000 
10,131 
552 
731 
1,097 
12,511 

Amounts owed to related parties comprise intercompany balances which are unsecured, interest free and repayable 
on demand. 

Deferred income consists of fixed fee revenues billed in advance to clients which have not yet been earned as at the 
year end.  

The Company signed a credit facility with Royal Bank of Scotland (International) Ltd for £5.5 million in 2020, with 
drawn down being completed in September in 2022 to fund  the acquisition of the Mercer portfolios (Note 5). The 
facility  has  a  5-year  term  from  November  2020,  with  capital  repayments  structured  over  ten  years  and  a  final 
instalment to settle the outstanding balance in full at the end of the 5 years. The balance outstanding on this facility 
as at 31st December 2023 was £4.8 million (2022: £5.4 million). Interest on the loan is charged at 3.5% per annum 
over the Sterling Relevant Reference Rate on the outstanding balance. Prior to fully drawing down the loan interest 
was paid on the undrawn balance at a rate of 1.75% per annum over the Sterling Relevant Reference Rate. 

The facility is subject to customary cashflow to debt service liability ratios and EBITDA to debt service liability ratio 
covenants tested quarterly and is secured by a capital guarantee provided by a number of non-regulated holding 
subsidiary companies within the Group and debentures over these companies.  

The Group’s exposure to liquidity risk related to trade and other payables is described in Note 26.  

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

24.  Other payables – amounts falling due in more than one year 

Group 
Lease liabilities                                                       
Bank loan (secured) 
Other payables 
Total 

Company 
Bank loan (secured) 

25.  Financial risk management 

31 December 
2023 
£000 
546 
4,262 
- 
4,808 

31 December 
2022 
£000 
143 
4,811 
96 
5,050 

31 December 
2023 
£000 
4,262 

31 December 
2022 
£000 
4,811 

The Group has exposure to the following risks from its use of financial instruments: 

•  Credit risk 
•  Liquidity risk 
•  Market risk 
• 
•  Currency risk 
•  Regulatory risk 
•  Capital management 

Interest rate risk 

This note presents information about the Group’s exposure to each of the above risks, the Group’s objectives, policies 
and  processes  for  measuring  and  managing  risk,  and  the  Group’s  management  of  capital.  Further  quantitative 
disclosures are included throughout these consolidated financial statements. 

The Board of Directors has overall responsibility for the establishment and oversight of the Group’s risk management 
framework. The Board has an Audit and Risk Committee, which is responsible for developing and monitoring the 
Group’s risk management policies.   

The Group’s risk management policies are established to identify and analyse the risks faced by the Group, to set 
appropriate risk limits and controls, and to monitor risks and adherence to limits.  Risk management policies and 
systems are reviewed regularly to reflect changes in market condition and the Group’s activities. The Group, through 
its  training  and  management  standards  and  procedures,  aims  to  develop  a  disciplined  and  constructive  control 
environment in which all employees understand their roles and obligations. 

(a)  Credit risk 

Credit risk is the risk of financial loss to the Group if a customer or counterparty to a financial instrument fails to meet 
its contractual obligations and arises principally from the Group’s receivables from clients. 

Trade and other receivables 

The  Group’s  exposure  to  credit  risk  is  influenced  mainly  by  the  individual  characteristics  of  each  client.    The 
demographics of the Group’s client base, including the default risk of the country in which the clients operate, has 
less of an influence on credit risk. There is no one client to which a significant percentage of the Group’s revenue 
can be attributed. The level of liquidity of customer investments determines the level of credit risk associated with 
each customer. The liquidity of customers is monitored at each anniversary date. 

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

25.  Financial risk management (continued) 

(b)  Liquidity risk 

Liquidity risk is the risk that the Group will not be able to meet its financial obligations as they fall due.  The Group’s 
approach to managing liquidity is to ensure, as far as possible, that it will always have sufficient liquidity to meet its 
liabilities when due, under both normal and stressed conditions.  The Group believes its exposure to liquidity risk is 
minimal given its current cash balances and existing financial obligations. 

(c)  Market risk 

Market risk is the risk that changes in market prices, such as foreign exchange rates, interest rates and equity prices 
will  affect  the  Group’s  income  or  the  value  of  its  holdings  of  financial  instruments.  The  object  of  market  risk 
management  is  to  manage  and  control  market  risk  expenses  within  acceptable  parameters,  while  optimising  the 
return. The Group does not have a significant exposure to market risk. 

(d) 

Interest rate risk 

The Group has one bank  borrowing at the year end, as detailed  in Note 23. A  change of 100 basis points in  the 
relevant underlying interest rate would have increased or decreased equity and profit or loss by £51,000 before tax 
(2022: £34,000). 

(e)  Currency risk 

The Group has a small exposure to currency risk in relation to its investment in STM Nummos. This is mitigated by 
the fact that the assets and liabilities held by STM Nummos are in its functional currency of Euros (€). It has a further 
currency risk in relation to the expenses incurred in Malta as these are in Euros. A change of 100 basis points in the 
Euro to Sterling  exchange  rate would have  increased or decreased equity and  profit  or loss by £27,000  after tax 
(2022: £28,000) This is mitigated by the fact that clients are invoiced in its and the Group’s functional currency of 
Sterling (£). 

The Company has minimised exposure to foreign exchange rates, with the majority of transactions being carried out 
in its functional currency of Pounds Sterling (£). 

(f)  Regulatory risk 

The Group is subject to laws, regulations, and specific solvency requirements in the various jurisdictions in which it 
operates. The Group has established policies and procedures aimed at compliance with local laws and regulations. 

(g)  Capital management 

The Board’s policy is to maintain a strong capital base, which is defined as share capital and retained earnings, so 
as to maintain investor, creditor and market confidence and to sustain future development of the business.   

Furthermore, certain of  the Company’s subsidiaries are licensed by the respective jurisdictions regulators and as 
such all comply with the regulatory capital requirements set by each respective regulatory body. 

The Group manages its capital to ensure that the entities in the Group will be able to continue as a going concern, 
while maximising the return to stakeholders through optimisation of the debt and equity balance. The capital structure 
of  the  Group  consists  of  debt,  which  includes  a  bank  loan  as  per  Notes 23  and  24,  and  equity  attributable  to 
shareholders, comprising share capital, reserves and retained earnings as disclosed. The Board reviews the capital 
structure and as part of this review, considers the cost of capital and the risks associated with each class of capital. 
In addition, the Board considers the liquidity and solvency of the Group on an ongoing basis. 

The Group monitors capital using a ratio of “adjusted net debt” to “adjusted equity”. For this purpose, adjusted net 
debt is defined as total liabilities, comprising interest-bearing loans and borrowings less cash and cash equivalents 
net of the balances which are not available for use by the Group (Note 19). Adjusted equity comprises all components 
of equity. 

62 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

25.  Financial risk management (continued) 

(g)  Capital management (continued) 

The Group’s adjusted net debt to equity ratio at 31st December 2023 suggests that the Group has sufficient liquidity 
to meet its obligations as they fall due. Net debt compared to equity at 31st December 2022 was as follows: 

Total liabilities 
Less: net cash and cash equivalents available 
Adjusted net debt 
Total equity attributable to owners of the Company 
Adjusted net debt to equity ratio 

31st December 
2023 
£000 
18,823 
(14,156) 
4,667 
34,595 
13% 

31st December 
2022 (restated) 
£000 
18,759 
(16,331) 
2,428 
34,970 
7% 

Total liabilities above are stated after excluding provisions for customer redress of £27,441,000 (2022: £488,000) as 
these are exactly matched buy amounts recoverable from the Group’s insurers. The comparative for total liabilities 
has been adjusted accordingly as such provisions were not excluded in the financial statements of the Group for the 
year ended 31st December 2022, as the amount involved was not material. 

The net cash and cash equivalents available excludes the balances not available for use by the Group of £4,209,000 
(2022: £2,903,000) as more fully explained in Note 19.   

26.  Financial Instruments 

Credit risk 

Exposure to credit risk 

The carrying amount of financial assets represents the maximum credit exposure. The Group’s maximum exposure 
to credit risk at the reporting date was: 

Financial instrument designated as FVTPL 
Trade and other receivables 
Cash and cash equivalents 
Total 

Carrying amount 

31st December 
2023 
£000 
1,839 
7,349 
18,365 
27,553 

31st December 
2022 
£000 
1,762 
8,461 
19,234 
29,457 

The Group’s maximum exposure to credit risk on trade and other receivables relating to one entity or group of related 
entities  amounts  to  less  than  10%  of  the  overall  trade  receivables  amount  as  at  31st December  2023  and  31st 
December  2022.  Segmental  disclosures  are  included  in  Note  7  reflecting  the  Group’s  operating  segment  and 
geographic concentration.   

The Group limits its exposure to credit risk by investing only in liquid debt securities issued by the UK government. 
The financial instrument designated at FVTPL held by the Group is rated as investment grade. 

Impairment on trade and other receivables is determined applying an ECL model as discussed in Note 3(n).  

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

26.  Financial Instruments (continued) 

Credit risk (continued) 

The ageing of the Group’s trade receivables at the reporting date was: 

Gross 
receivables 
31st 
December 
2023 
£000 
1,398 
350 
198 

Individual 
Impairment 
31st 
December 
2023 
£000 
- 
- 
- 

2,570 
4,516 

(601) 
(601) 

Total 
£000 
1,398 
350 
198 

1,969 
3,915 

Gross 
receivables 
31st 
December 
2022 
£000 
933 
464 
333 

Individual 
Impairment 
31st December 
2022 
£000 
- 
- 
- 

Total 
£000 
933 
464 
333 

3,060 
4,790 

(524) 
(524) 

2,536 
4,266 

Not past due 
Past due 0–30 days 
Past due 31–120 days  
More  than  120  days 
past due 
Total 

Standard credit terms are 30 days from the date of issuing the fee note. 

The movement in the allowance for impairment in respect of trade receivables during the period was: 

Balance at start of year 
Movement in expected credit loss allowance  
Balance at end of year 

31st December 
2023 
£000 
524 
77 
601 

31st December 
2022 
£000 
174 
350 
524 

Based on historic default rates and knowledge of the customers, the Group believes that no impairment allowance is 
necessary in respect of the trade receivables.  

Liquidity Risk 

The Group holds sufficient liquid assets, including cash at bank, to enable it to meet its liabilities as they fall due. The 
following  are  the  Group’s  contractual  maturity  liabilities.  The  amounts  are  gross  and  undiscounted  and  include 
contractual interest payments and exclude the impact of netting arrangements. 

31st December 2023 
Non-derivative financial liabilities  
Trade payables 
Bank loan (secured) 
Lease liabilities 
Other creditors and accruals 
Total 

Carrying 
amounts 
£000 

Contractual 
cash flow 
£000 

6 months 
or less 
£000 

6-12 
months 
£000 

1-4 years 
£000 

1,970 
4,812 
850 
6,783 
14,415 

1,970 
5,013 
844 
6,783 
14,610 

1,970 
330 
194 
6,783 
9,277 

- 
327 
110 
- 
437 

- 
4,356 
540 
- 
4,896 

64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

26.  Financial Instruments (continued) 

Liquidity Risk (continued) 

31st December 2022 
Non-derivative financial liabilities  
Trade payables 
Bank loan (secured) 
Deferred consideration 
Lease liabilities 
Other creditors and accruals 
Total 

Fair value hierarchy 

Carrying 
amounts 
£000 

Contractual 
cash flow 
£000 

6 months or 
less 
£000 

6-12 months 
£000 

1-4 years 
£000 

882 
5,363 
56 
713 
6,615 
13,629 

882 
5,682 
56 
736 
6,615 
13,971 

882 
336 
56 
363 
6,615 
8,252 

- 
333 
- 
226 
- 
559 

- 
5,013 
- 
147 
- 
5,160 

The  following  table  shows  a  reconciliation  from  the  beginning  balances  to  the  ending  balances  for  fair  value 
measurements in Level 3 of the fair value hierarchy.  

Financial assets - call options 
Balance at 1st January 
Settlement (Note 6) 
Balance at 31st December 

27.  Leases 

31st December 
2023 
£000 
- 
- 
- 

31st December 
2022 
£000 
881 
(881) 
- 

In  relation  to  leases  under  IFRS  16,  the  Group  has  charged  depreciation  and  interest  expenses.  The  Group 
recognised £455,000 (2022: £487,000) of depreciation charges and £41,000 (2021: £53,000) of interest expenses 
from these leases during the year ended 31st December 2023. The Group recognised £72,000 (2022: £61,000) of 
expenses relating to short-term leases or leases that can be cancelled with no penalties and £6,000 (2022: £6,000) 
of expenses for leases of low-value assets, excluding short-term leases, for the year ended 31st December 2023.  

The total cash outflow for leases for the year ended 31st December 2023 was £660,000, including short-term lease 
cash outflows of £78,000 (2022: £791,000, including short-term lease cash outflows of £67,000). 

Lease liabilities 

Non-cancellable lease liabilities as per IFRS 16 are payable as follows: 

Less than one year 
Between one year and five years 
More than five years 
Total 

31st December 
2023 
£000 
304 
540 
- 
844 

31st December 
2022 
£000 
589 
147 
- 
736 

The maturity analysis of lease liabilities is disclosed in Note 26. Right-of-use assets are disclosed in Note 14. 

The Group leases a number of offices from which they operate, the largest of which are the offices in Gibraltar, Cardiff 
and Milton Keynes with the leases terminating in 2028, 2025 and 2024 respectively. 

65 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

28.  Provisions, receivables due from insurers and contingent liability 

As stated in Note 3(q) and as required by IFRS, provisions are recorded when there is a present legal or constructive 
obligation as a result of a past event, for which it is probable that an outflow of economic benefits will be required to 
settle the obligation, and where a reliable estimate can be made of the amount of the obligation. As stated in Note 2 
this requires judgement and the use of assumptions about the likelihood and magnitude of any cash outflow. The 
Group  analyses  its  exposure  based  on  available  information,  including  consultation  with  professional  indemnity 
insurers and external legal advisors where appropriate, to assess any potential liability.  

Provisions and receivables due from insurers 
Customer redress in relation to UK SIPP claims 
Other claims 
Total  

Customer redress in relation to UK SIPP claims 

31st December 
2023 
£000 
27,441 
- 
27,441 

31st December 
2022 
£000 
- 
488 
488 

During the year ended 31st December 2023, numerous claims from clients arising across various policy years and 
investments were settled and the cost covered in full by the professional indemnity insurance in place for the relevant 
policy years based on the relevant reserving held. In addition, a Judicial Review heard on 16 and 17 April 2024 that 
affected a further cohort of cases rejected the Group’s appeal against the previous determination by the Financial 
Ombudsman Service and upheld the original ruling. These events have enabled a reasonably materially accurate 
assessment  to  be  done  of  the  potential  liability  relating  to  the  remaining  open  cases  and  legal  claims  in  similar 
circumstances. In accordance with IAS 37, a provision of £27,441,000 (2022: £nil) has been made in the financial 
statements for the year ended 31st December 2023 with a corresponding receivable from insurers as these are fully 
covered by professional indemnity insurance. 

With reference to the prejudicial exemption allowed under IAS 37, the Group will not disclose any further information 
about the contingent liability, including any details about current and potential claims as these claims are ongoing. 

On the basis of present information, amounts already recognised and the availability of insurance coverage, it is the 
opinion of the Group that the ultimate determination of complaints received to date will not have a material adverse 
effect on the consolidated financial position of the Group. However, it is possible that future results of operations or 
cash flows for any annual period could be materially affected by an unfavourable resolution of these matters. 

Other claims 

As  at  31st  December  2022  there  were  potential  claims  in  respect  of  the  historic  trading  of  STM  Malta  Pensions 
Services Limited. These claims were estimated based on present information available at the time and a provision 
made. This was covered by professional indemnity insurance net of relevant insurance case excesses and thus was 
also reflected as a receivable due from insurers. Following progress made on these claims during the year ended 
31st  December  2023,  the  provision  (and  corresponding  receivable  from  insurers)  has  reduced  to  £Nil  (2022: 
£488,000).  

General 

With reference to the prejudicial exemption allowed under IAS 37, the Group will not disclose any further information 
about the contingent liability, including any details about current and potential claims as these claims are ongoing. 

66 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

29.  Related Parties 

Transactions with Key Management Personnel and Directors’ compensation 

There were no Key Management Personnel other than the Board of the Company. Key Management Personnel and 
Directors’ compensation comprised: 

Directors’ remuneration 

Share-based payments 

Total 

31st December 
2023 
£000 
588 

31st December 
2022 
£000 
663 

- 

588 

- 

663 

Key Management Personnel and Director transactions  

Trusts and related parties connected to Key Management Personnel and the Directors held 12% of the voting shares 
of the Company as at 31st December 2023 (2022: 12%). 

The  Company  received  dividends  of  £4,093,236  (2022:  £4,716,863)  from  STM  Malta  Limited,  £836,847  (2022: 
£100,000) from STM Fidecs Limited and £1,894,302 from London & Colonial Holdings Limited (2022: £Nil). 

67 

 
 
 
 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

30.  Group Entities 

Principal subsidiaries 

At 31st December 2023 the Company owned the following subsidiaries which are regarded as the principal trading 
operations of the Group. 

Country of 
incorporation 

STM Fidecs Life, Health and 
Pensions Limited 

Gibraltar 

STM Fidecs Central Services Limited 

Gibraltar 

STM Nummos SL 

Spain 

STM Life Assurance PCC plc 

Gibraltar 

STM Nummos Life SL 

Spain 

STM Malta Pension Services Limited 

Malta 

London & Colonial Assurance PCC 
PLC 

Gibraltar 

London & Colonial Services Limited 

England 

London & Colonial Central Services 
Limited 

London & Colonial (Trustee Services) 
Limited 

Options Corporate Pensions UK 
Limited 

England 

Gibraltar 

England 

Options UK Personal Pensions LLP 

England 

Options SSAS Limited 

Options EBC Limited 

England 

England 

Ownership interest 
31st 
31st 
December 
December 
2022 
2023 
100% 
100% 
indirectly 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

100% 
indirectly 

70% 
indirectly 

100% 
indirectly 

100% 
indirectly 

Activity 
Administration of clients’ 
assets 

Services and 
Administration 

Administration of clients’ 
assets 

Life Assurance company 

Administration of client 
assets 

Administration of client 
assets 

Life Assurance Company 

Administration of clients’ 
assets 

Administration of clients’ 
assets 

Administration of clients’ 
assets 

Administration of clients’ 
assets 

Administration of clients’ 
assets 

Administration of clients’ 
assets 

Administration of clients’ 
assets 

31.  Non-adjusting subsequent events 

On 14th June 2024, the Company announced that the Group had signed a commercial agreement with Smart Pension 
Limited  (“Smart”)  under  which  members  transferring  from  of  the  Group’s  Options  Workplace  Master  Trust  would, 
subject to approval by the Trustees and the Pensions Regulator, transfer to Smart’s Master Trust with Smart paying 
a consideration for such transfers to the Group. It is anticipated that, over a two-year period, this consideration is 
likely to amount to circa £4.7million. In addition, the Group also entered into an introducer’s agreement with Smart at 
the same time, whereby any new members introduced to Smart by the Group’s existing or new intermediary contacts 
would lead to introductory commission income for the Group. The agreement is in place for a maximum period of 
three years, and management estimates that the quantum of such additional introductory commission could lie in the 
range of £1.0 million to £5.0 million over the three-year period.  

68 

 
 
 
 
 
 
 
 
 
 
STM GROUP PLC 
NOTES TO THE FINANCIAL STATEMENTS 
FOR THE YEAR FROM 1 JANUARY 2023 TO 31 DECEMBER 2023 

31.   Non-adjusting subsequent events (continued) 

On 12th January 2023, the Group completed the acquisition of the remaining external 30% interest in Options UK 
Personal Pensions LLP, increasing its ownership from 70% to 100% (Note 6). A decrease in equity attributable to 
owners  of  the  Company  has  been  recognised  in  the  other  reserve  amounted  to  £468,000.  Subsequent  to  this 
acquisition, all subsidiaries are wholly owned. 

69