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The Law Debenture Corporation
Annual Report 2020

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FY2020 Annual Report · The Law Debenture Corporation
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A N N U A L   R E P O R T
2020

The Law Debenture Corporation p.l.c.

A T   A   G L A N C E

A differentiated investment proposition

A PROUD HISTORY

132 years

of value creation for shareholders

STRENGTH AND DIVERSITY OF INCOME

34.0%

LONG-TERM DIVIDEND GROWTH

of total 2020 dividend funded by our Independent Professional Services business

42 years

of increasing or maintaining dividends to shareholders (116.5% increase in 
dividend over the last ten years)

CONSISTENT LONG-TERM OUTPERFORMANCE OF OUR BENCHMARK

87.3%

outperformance of our benchmark, the FTSE Actuaries All-Share Index,  
over ten years

Key statistics  

for the year ended 31 December 2020

666.2p

NAV per share

(2019: 702.2p)

787.2m1

Net Asset Value

(2019: 830.1m)

18.3%2

9.5%

Growth in fair valuation 

Independent Professional 

of IPS (2019: 21.0%)

Services business growth in  
earnings per share (2019: 8.5%)

-9.8%

3.6%

5.8%

6.2%

Benchmark total return  

NAV total return for the year 

Proposed increase in 2020 

Increase in share price 

for the year

(2019: 19.2%)

(with debt at par)

(2019: 19.4%)

dividend per share

in 2020 (2019: 20.4%)

(2019: 37.6%)

1  Please refer to page 37 for calculation of net asset value.

2  Increase in annual valuation of Independent Professional Services business, excluding change in surplus net assets.

lawdebenture.com  

Law Debenture is an investment trust and a leading provider of independent 

professional services, listed on the London Stock Exchange. From its origins in 

1889, it has diversified to become a Group with a unique range of activities in 

the financial and professional services sectors. The Group has two distinct areas 

of business:

Investment 
Portfolio

c. 83% of NAV

Independent Professional 
Services (IPS) business

c. 17% of NAV

Managed by James Henderson and Laura Foll 
of Janus Henderson

OBJECTIVE: LONG-TERM CAPITAL 

GROWTH IN REAL TERMS AND STEADILY 

INCREASING INCOME

–  Focused on long-term returns

–   Low ongoing charges ratio at 0.55%1 

compared to industry average of 1.02%2

–   Contrarian investment style:

  –   Out of favour equities standing at 

valuation discounts to their long-term 

historical average

  –   High quality companies with strong 

competitive advantage at attractive valuations

–   Selective, bottom-up approach

–   Diversified portfolio by sector  
(predominant UK weighting)

PENSIONS 

The longest 
established and 
largest UK 
provider of 
independent 
pension trustees

CORPORATE 
TRUST 

A leading 
independent 
corporate 
trustee across 
international 
capital markets

CORPORATE 
SERVICES

Range of 
outsourced 
solutions to 
corporates 
internationally

INTERNATIONAL PRESENCE: 

United Kingdom, New York, Ireland, Hong Kong, 
Delaware, and Channel Islands

All divisions have further potential for growth 
through the overall market growth for these 
services and market share gains, alongside better 
leveraging technology, strong relationships and  
a high quality brand

Significant, consistent income contribution from IPS gives greater flexibility in stock selection

1  Calculated based on data held by Law Debenture for the year ended 31 December 2020. 

2  Source: Association of Investment Companies (AIC) industry average (excluding 3i) as at 31 December 2020.

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A T   A   G L A N C E

Contents

A T   A   G L A N C E

C O R P O R A T E   G O V E R N A N C E

Financial summary and performance 

3 

The Board  

S T R A T E G I C   R E P O R T

Chairman’s statement  

Q&A with Denis Jackson, CEO 

4-5 

6-7 

Q&A with James Henderson and Laura Foll, 

Executive Leadership team 

Directors’ report  

Corporate governance report  

Covid-19 response 

Audit and Risk Committee report  

investment managers 

8-9

Annual remuneration report  

50-51

52

53-55

56-60

61-62

63-65

67-82

Chief Executive Officer’s review 

Investment managers’ review 

Fifteen largest holdings  

Classification of investments  

Investment portfolio valuation  

Changes in geographical distribution  

Company overview 

Calculation of net asset value  

(NAV) per share  

Long-term performance record  

Risk Management 

Viability statement 

Section 172(1) statement 

10-16

18-23 

24-25 

26 

28-31 

31 

32-36

37

38

39-45

46

47-49

F I N A N C I A L   S T A T E M E N T S

Independent auditor’s report  

84-90

Group income statement  

Statement of comprehensive income  

Statement of financial position  

Statement of changes in equity  

Statements of cash flows  

Notes to the accounts 

92

92

93

94-95

96

97-126

C O R P O R A T E   I N F O R M A T I O N

Alternative performance measures  

128-129

Company advisers and information  

Financial calendar  

Subsidiary company details 

130

131

131

Notice of annual general meeting (AGM) 

132-133

Summary of proposed amendments  

to the Articles of Association 

134-137

Explanatory notes to the notice of AGM 

138-139

Shareholder notes 

AGM online user guide   

140-141

142

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Change

(5.2)%

(5.1)%

(45.4)%

+9.5%

N/M

(29.7)%

N/M

+5.8%

+6.2%

31 December 2020 
£000

31 December 2019 
£000

830,139

Pence

702.17

22.18

8.54

(0.04)

30.68

79.27

26.00

650.00

%

0.48

5†

(7.4)

787,219

Pence

666.15 

12.12 

9.35 

0.09 

21.56 

(19.06)

27.50

690.00

%

0.55

9

3.6

1 year 
%

3.6

2.0

(9.8)

12.9

3 years 
%

5 years 
%

10 years 
%

15.6

13.2

(2.7)

24.3

6.4

59.1

53.0

28.5

67.3

13

147.8

134.7

71.9

174.8

29.4

Financial summary

Net assets1

Net Asset Value (NAV) per share at fair value1*

Revenue return per share

Investment portfolio

Independent professional services 

Group charges

Group revenue return per share

Capital (loss)/return per share

Dividends per share

Share price

Ongoing charges3*

Gearing3

Premium/(Discount)*

Performance

NAV total return2* (with debt at par)

NAV total return2* (with debt at fair value)

FTSE Actuaries All-Share Index Total Return4

Share price total return4*

Change in Retail Price Index4
0.9
   *  Items marked “*” are considered to be alternative performance measures and are described in more detail on page 128.

†  The 2019 gearing has been restated to reflect the revised approach to the calculation. Please see page 128 for more information.

1  Please refer to page 37 for calculation of net asset value.

2   NAV is calculated in accordance with the AIC methodology, based on performance data held by Law Debenture including fair value of the IPS business and long-term borrowings. NAV is 

shown with debt measured at par and with debt measured at fair value.

3   Source: AIC. Ongoing charges are based on the costs of the investment trust and include the Janus Henderson Investors’ management fee of 0.30% of NAV of the investment trust. There is 

no performance related element to the fee. Gearing is described in the strategic report on page 34 and in our alternative performance measures on page 128.

4  Source: Refinitiv Datastream.

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S T R A T E G I C   R E P O R T

Chairman’s statement

suspend or cut their dividends in order to protect their businesses 
over the long-term. The stable income provided by our IPS business 
means that we are not as dependent as many on the payouts from 
our underlying investments, illustrating the trust’s relative resilience 
in a downturn. The IPS business has funded over a third of our 
dividends to shareholders over the past eleven years. It continues 
to demonstrate a good performance at a time of significant 
market instability.

Furthermore, as with all investment trusts, we have the ability to 
hold back a portion of our income received each year. These revenue 
reserves help us to maintain or continue increasing our dividends 
in times of economic distress. At the start of 2020, we had one of 
the strongest reserves positions within the UK Equity Income sector 
with a Group retained earnings of £62.5m2.

Understandably, having regular, reliable income is now more 
important than ever for many of our shareholders. We listened 
to feedback from our investors and in July, transitioned to a 
quarterly dividend cycle, providing greater regularity around 
dividend payments. 

Subject to your approval, we propose paying a final dividend of 
8 pence per ordinary share. The dividend will be paid on 15 April 
2021 to holders on the register on the record date of 12 March 2021. 
This will provide shareholders with a total dividend of 27.5 pence per 
share for 2020 and represents a dividend yield of 3.8% based on our 
share price of 723p pence on 24 February 2021. 

As we have done this year, we will continue to listen and respond to 
feedback, to deliver value for our shareholders.

Our investment portfolio

Our experienced investment management team, led by James 
Henderson and Laura Foll, has left us well-positioned for future 
longer-term growth. The investment managers’ review on pages 18 
to 22 contains a more detailed explanation from James and Laura on 
the portfolio’s performance. 

Through these difficult times, your Board continues to support 
the investment managers’ strategy of investing in high-quality 
companies at attractive valuations, which offer good total return 
opportunities. With markets in their current state, the advantages 
of Law Debenture’s structure have been evident. The cash that we 
generate from our IPS business has allowed James and Laura to avoid 
potential value traps, as other income funds may be forced into a 
narrower selection of stocks to maintain their own dividend yield. 

IPS business

Within the IPS business, our diverse revenue streams have shown 
resilience in these difficult macroeconomic conditions.

During the period, we continued to deliver growth. Over the course 
of 2020, IPS grew its revenues by 8.5% while earnings per share grew 
by 9.5% compared to 2019. This is built on two previous years of good 
performance and, over the last three years, revenues have grown by 
27.1% and earnings per share by 29.7% in total. 

In what has been a challenging year, Law Debenture has shown good 
resilience and I am delighted to introduce our 2020 annual report.

Performance

2020 was a very difficult year. The impact of Covid-19 on our lives 
has been substantial and has led to significant economic volatility. 
Although the recent approval and rollout of new vaccines usher in 
hope, it is difficult to assess how long this period of instability will last. 

However, the strength and capabilities of your Company have been 
evident in these volatile times. During the period, our active investment 
managers have demonstrated the value in their stock-picking strategy. 
Despite the current backdrop, Law Debenture saw a share price total 
return of 12.9% in 2020, outperforming the FTSE Actuaries All-Share 
Index by 22.7%, which declined by 9.8%. Over the same period, your 
Company’s net asset value (with debt at par) grew 3.6%1 .

We are proud of this achievement and our ability to deliver on our 
aim of producing long-term capital growth and steadily increasing 
income for our shareholders. 

The Board remains strongly focused on longer-term performance. Over 
the three-year period to 31 December 2020, the NAV per share (with 
debt at par) total return was up 15.6%, which compares favourably with 
the 2.7% total return of the FTSE All-Share Index and, over ten years, 
your Company saw a NAV per share total return of 147.8%, outstripping 
the 71.9% total return for the FTSE All-Share Index.  

We are continuing to closely monitor and actively manage the 
impact of Covid-19 on our portfolio and clients. We are also taking 
the necessary precautions to protect both our employees and the 
communities in which we operate.

Dividend

Law Debenture has a proud history of maintaining or increasing its 
dividend payments for 42 years.

The Covid-19 crisis has highlighted the unique benefits that Law 
Debenture’s structure offers. The severe turbulence across global 
markets in 2020 caused a large proportion of listed companies to 

1   NAV is calculated in accordance with the AIC methodology, based on performance data held by Law Debenture including fair value of the IPS business and long-term borrowings. NAV is shown  

with debt measured at par and with debt measured at fair value.

2   Investec Securities analysis from 30 March 2020, based on Group Revenue Return, including professional services fees. Calculated on an annualised basis on dividend payments in respect of 

accounting years between 1 January 2011 and 31 December 2020. Group retained earnings were £62.5m as at 1 January 2020.

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Chairman’s statement continued

We maintained operational continuity throughout the Covid-19 
pandemic and did not furlough any employees, implement any pay 
cuts or make any redundancies related to Covid-19.

In December, we were pleased to announce the acquisition 
of a company secretarial business line (CSS) from Konexo 
UK, a division of Eversheds Sutherland (International) LLP, for 
£20 million. The acquisition was an important step forward 
in supporting Law Debenture’s strategy. The expansion of our 
existing company secretarial offering will enable us to grow in an 
attractive core business and meet increasing customer needs in a 
specialised market. 

The Board believes that the IPS business continues to have 
good prospects for further organic growth and we remain alert 
to opportunities presented by acquisitions which meet Law 
Debenture’s strict financial and strategic criteria. 

Environmental, Social and Governance (ESG) 
considerations

Robust governance, transparency and accountability are embedded 
in our corporate values. Within our IPS business, utilities’ consumption 
and business travel are critical aspects of our environmental and 
carbon footprint. In 2020, we were pleased to move into a new ‘green’ 
office and adopt paperless ways of working and we look forward to 
increasing our focus on ESG in 2021. The Board will be conducting a 
full internal review on ESG and we plan to monitor our emissions and 
evaluate carbon reduction targets, step up employee engagement and 
ensure individual voices continue to be heard. Many of our IPS activities 
constitute governance services and we strive to maximise the potential 
of all our colleagues and partners. 

This year there were several new appointments within our senior 
leadership, as covered later in this report. I am proud that we have 
strong female representation across our management team. We are 
working to ensure that ethnic diversity is appropriately represented 
within our organisation, but we acknowledge that there is more work 
to do. We are committed to progressing this further in 2021. 

Our investment managers have an ESG policy of discussing 
any material issues directly with their investee companies and 
monitoring for improvement. They are not afraid to exit positions 
where management fail to deliver expected improvements. In 
addition, James and Laura are always looking for companies that are 
actively seeking to address ESG issues. Holdings exposed to the need 
to decarbonise the global economy have performed extremely well 
during the year, including Ceres Power and ITM Power. ESG issues 
are considered both directly by James and Laura, and also by the 
experienced responsible investing team at Janus Henderson. While 
they do have quantitative metrics on ESG available for the portfolio, 
they are not at present explicitly screening companies out on ESG 
ratings as the data quality is sometimes unreliable. This will be kept 
under review.

The Board

I would like to thank our CEO, Denis Jackson, for his tireless efforts 
during 2020, particularly in relation to the acquisition of the CSS 
business and delivering another set of strong results for your 
Company. The Board worked closely with our CEO to restructure 
our Executive Leadership team. We were delighted to appoint Trish 

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Houston as our new COO and welcomed her as an Executive Director 
on the Board on 2 September. She is a chartered accountant with 
almost two decades of experience in financial services. Her in-depth 
sector knowledge will be invaluable as we continue to make progress 
against our stated growth strategy. 

Katie Thorpe stood down as CFO in October and was succeeded 
by Hester Scotton, who joined Law Debenture in 2019 as Head of 
Internal Controls and Group Money Laundering Reporting Officer. 
The management transition has gone well, with both Hester and 
Trish playing integral roles in our acquisition of CSS from Konexo UK. 
I look forward to working with them both as we look to continue our 
growth trajectory.

The Executive Leadership team was further strengthened with the 
promotion of Kelly Stobbs to General Counsel.

After nine years on the Board, Robert Laing will be stepping down 
as non-executive director and Chairman of the Remuneration 
Committee. We would like to thank him for his significant contribution 
to the Company over the years and wish him all the best in the future.

Report and accounts

Every year we reflect on the format and disclosure of the report 
and accounts, striving to improve how we communicate with 
shareholders. For 2020 you will notice we have presented additional 
disclosure within our risk management section and simplified 
our presentation of the remuneration report. We cannot ignore 
the impact of Covid-19 and have set out in full within the Strategic 
Report how we have responded to the pandemic to protect our 
key stakeholders. We will continue to listen to shareholders and 
analysts, reflecting on the areas they find important and evolving our 
reporting to make sure we have the appropriate level of transparency. 
We continue to develop an integrated ESG narrative and see this as 
the start of a journey and will be looking to continue to evolve our 
reporting into 2021 and beyond.

Looking forward

The Board is confident in the expertise of our investment managers 
and their strategy of investing in high-quality companies with strong 
competitive characteristics. Where the current valuation does not 
reflect the long-term prospects, these companies should continue 
to deliver attractive returns to shareholders.

The prospects of the IPS businesses remain positive due to their 
strong market positions and good reputation, supported by 
strong governance and regulatory drivers in the markets in which 
they operate.

Overall, the Board is confident that your Company is positioned 
to perform well in the long-term and our unique structure is well 
placed to serve shareholders searching for a reliable and growing 
income stream. 

In closing, we are grateful to our people for their tremendous work 
and efforts in delivering a good set of results in 2020 and for their 
ongoing dedication to our business. 

Robert Hingley 
Chairman
25 February 2021

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S T R A T E G I C   R E P O R T

Q&A with Denis Jackson, Chief Executive Officer

1.   How should shareholders be feeling 

about Law Debenture’s results in 2020? 

Despite the Covid-19 crisis, our business preserved shareholders’ 

capital, increased our dividend, and increased the earnings of our 

operating business. Not many businesses can say that about their 

performance in 2020. We performed well during the crisis but it 

is critical now that we use our position of strength to continue to 

build long-term capital growth and steadily increasing income. 

2.  What were the highlights for you?

Without question it was the way that all of our staff, unselfishly, 

and without any prompting from me, brought out the very best of 

our collective experience to solve the rapidly evolving needs of our 

clients. I am proud of the kindness that our staff showed to one 

another and the calm, measured and thoroughly professional way 

in which they applied themselves. We are lucky to have them. We 

will continue to invest in them and in their well-being.

3.   Where do you feel the Company could 

potentially have done better?

We need to ensure that investors and potential new investors 

understand us. This includes who we are, what we do and how 

we do it. We have a very loyal investor base who have supported 

us through all parts of the economic cycle. As our Group evolves, 

we must take them with us and attract a new generation of 

buyers of our stock.

4.   What, if any, learnings came from 

Covid-19 for the business?

I think that as much as we try to forecast, budget and plan, we 

can never predict what is just around the corner. During my 

career, I have experienced a stock market crash, the demolishing 

of the Berlin Wall, 9/11, the global financial crisis and now a global 

pandemic. With a strong balance sheet, a diverse set of revenue 

streams and a reputation for excellence, Law Debenture will 

always attract discerning clients. Law Debenture has once again 

shown resilience in a crisis; continued investment in a great 

technology team and a good disaster recovery plan have certainly 

proved their worth.

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Q&A with Denis Jackson, Chief Executive Officer continued

5.   Have there been any changes to your 

strategy/priorities for the IPS business 
going forward? 

8.   What do you see as the main challenges 
to sustainably grow all three divisions of 
the IPS business?

We have a strong brand built on trust and product excellence. 

We must ensure that we have the right people in place to both 

We need to maintain these pillars while adding ‘ease of use’ as a 

grow our business and deliver an excellent service to our clients.

9.   Given the macroeconomic backdrop, 
what medium-term growth are you 
targeting for the IPS business and how 
might the multiple develop over time in 
different scenarios?

In our annual report two years ago we stated that following a 

period of no growth between 2011 and 2017, mid to high single 

digit growth would be a sensible target and would represent 

significant progress. In the past three years, our IPS EPS has 

increased by 9.2%, 8.5% and 9.5% respectively. We are proud of 

this and believe that compound mid to high single digit growth 

continues to be an appropriate goal for our business. If we 

continue to execute well, compound our growth at mid to high 

single digits, and better educate analysts and investors about our 

business, we are confident we will achieve our goals of long-term 

capital growth and steadily increasing income.

third. When the Board interviewed me for the role just over three 

years ago, we agreed that we should look to radically reposition 

the role of technology in our business. Specifically the need to 

embed efficient technology into the way that all of our businesses 

interact with our clients. We have made progress from a low base 

but we still have much to do. It is critical that we quicken the pace 

of change. 

6.   How is the integration of the company 
secretarial business from Eversheds 
Sutherland (International) LLP 
progressing?

The transaction completed on the last working day in January 

2021. It is still early days, but we are off to a fast start. During 

our initial conversation with Eversheds last year, we stated that 

on completion of the acquisition we wanted to have the same 

excellent people, in the same offices, serving the same clients 

on similar terms. On Monday, 1 February 2021, all of our new staff 

were able to log on to their new machines, access the correct 

data and continue serving their clients. From a client continuity 

perspective we are in great shape. Successfully embedding a new 

business requires a significant amount of work, but this is well 

under way.

7.   Should we expect more acquisitions in 

the short or longer term?

As we have previously stated, we are open to growth through 

acquisitions. This very much remains the case.

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Q&A with James Henderson and Laura Foll 
investment managers

1.   The pandemic has caused disruption 

for all companies this year. How has this 
impacted your investment approach?

James:  Trends that were in place before the pandemic, such 
as the growth of online shopping and the decline in physical 

retailing, have been accelerated.  We have always focused on 

companies that provide an excellent product or service to the 

consumer.  Those companies have in their culture an ability to 

adapt to the situations in which they find themselves; in that 

sense the pandemic has not changed our approach. 

2.   What steps did you take in response to 

the outbreak of the pandemic?

Laura:  During Spring of 2020 when the first ‘lockdown’ happened 
the most material response from us was to be net investors, 

as we saw a wide range of opportunities across both new and 

existing holdings. February and March were the largest months 

for net investment and, by the end of March, we had invested an 

additional £36.8m in equities. This was then slowly unwound over 

the course of the year as valuations began to recover. 

3.   How do you think the long-term 

economic consequences of Covid-19 
will affect the portfolio and the type of 
stocks you choose?

James:  The long-term economic consequences will not be fully 
known for several years. The high level of indebtedness that the 

state has incurred could hold back long-term economic growth 

prospects in the UK. If interest rates rise substantially in coming 

years the cost of servicing that debt will act as a real drag on 

economic activity. 

However, the portfolio is not a proxy for the UK economy but 

rather a collection of individual companies that we believe will 

prosper even if there is an economic headwind. 

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Q&A with James Henderson and Laura Foll 
investment managers continued

4.   ESG is a topic that is of increasing 

importance for investors, how does this 
tie in with your investment process?

Laura:  ESG is a growing focus across the fund management 
industry. You would be hard placed to find a fund manager 

that does not say ESG is an increasingly important part of the 

investment process and we are no exception. I think where we 

some that continued operating without much impact, and some 

that were severely affected, but the overall blend meant that the 

net asset value was able to finish the year approximately flat. 

The key lesson for me in terms of appropriate capital structure is 

to fully appreciate the importance of a strong balance sheet in 

the face of ‘unknown unknowns’. This was a lesson many of our 

management teams had already learnt during the financial crisis, 

and therefore we went into this downturn with comparatively 

potentially differ is that we see ESG, particularly environmental 

strong balance sheets. 

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issues such as the need to reduce global emissions, as an 

opportunity as well as a risk. The portfolio performance in 2020 

demonstrates this – two of the top five performers were in 

alternative energy. 

5.   What will be the long-term implications 
from the Brexit deal on UK equities? 

James:  It is a big relief that there has been a deal on Brexit. This 
means goods will not be subject to punishing tariffs. Overseas 

9.   What is the outlook for UK dividends 

in 2021 and beyond? 

Laura:  We expect UK dividends to recover in 2021 relative to 
2020 levels, but not to reach 2019 levels. This is because some 

income payers in the UK, including the integrated energy 
companies, permanently rebased their dividends last year due 

to a combination of the oil price fall and the need to gradually 

reposition their portfolios towards renewable energy. Looking 

investors had been very worried about a no deal Brexit. Over 

further ahead, I think what we will see in the UK is a more 

the next year, they could increase their exposure to UK equities 

balanced market for UK equity income. Previously, UK dividends 

and this could be good for valuations. Longer term, however, it is 

were heavily dominated by a few large income payers for 

example, Royal Dutch Shell and BP, as well as large banks such as 

HSBC. I think companies that had previously had, in hindsight, too 

high payouts will take the opportunity to rebase their dividends 

to a level from which they can grow. This may mean the yield of 

the UK index being lower than historically, but there will still be 

an attractive income opportunity in the UK. There should also be 

scope for dividend growth from that newly rebased level. 

10.   What trends do you expect to see in 2021 
and how will these play a role in your 
approach to investing?

James:  The desire for an environmentally sustainable economy 
has become even more important to governments and 

individuals.  Therefore companies that are dealing with the issue 

of decarbonisation will rise to prominence if they can provide 

answers to the issue.  Companies involved in this area are well 

represented in the portfolio. 

unclear what the implications might be. 

6.   Where do you currently see the most 
attractive investment opportunities? 

Laura:  We are finding most opportunities in the UK. The UK has 
materially underperformed other global equity markets over the 

last five years and 2020 was no exception. This has led to a clear 

valuation discount between UK companies and overseas peers. 

Towards the end of 2020 there was a notable pick-up in takeover 

activity as private equity and overseas companies sought to 

exploit that valuation gap. We would not be surprised if we see 

further corporate activity in 2021. 

7.   What do you think are the key lessons 

to be learnt from the crisis? 

James:  Equity investment always carries risk of the unexpected 
occurring. However human ingenuity will overcome the 

problems. This has occurred over the last year with the 

pandemic’s arrival and fast tracking of vaccines to control it. 

8.   Has your approach to risk in the portfolio 

and what comprises an appropriate 
capital structure changed as a result 
of the crisis? 

Laura:  I think what this year demonstrated, more than ever, was 
the need for diversity in the portfolio and the role of diversity in 

mitigating risk. We had some businesses that thrived last year, 

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Chief Executive Officer’s review 

The Board at Law Debenture is focused on delivering for 

stakeholders over the longer-term and we are proud to have 

delivered a 117% increase in dividend over the last ten years with 

42 years of increasing or maintaining dividends to shareholders. 

This is all supported by the diversified nature of IPS revenues, 

which funded around 35% of dividends for the trust over the 

preceding 10 years.

At the AGM on 7 April 2020 when talking to the potential impact 

of lockdown on the IPS business we stated that “we would get a 

bloody nose, but overall the diversified mix of revenue streams 

would serve us well”. Almost one year on, that still feels like an 

appropriate assessment. IPS business net revenues for the full year 

were up 8.5% at £34.5m (2019: £31.8m) and earnings per share up 

by 9.5% to 9.35p (2019: 8.54p). At the start of 2019 we committed 

to shareholders that we would seek to grow our IPS business by 

mid to high single digits. Given everything that 2020 threw at 

us, we are proud to have been able to deliver growth within this 

targeted range. 

Our unique proposition as an investment trust is that the IPS 

business allows James and Laura increased flexibility in portfolio 

construction. This was highlighted in 2020. The combination of 

our strong reserves position and the resilience of the IPS revenues 

allowed our investment managers to maintain or increase 

exposures to great companies whose dividends are challenged in 

the short-term. Moreover, the strength of our diversified income 

Introduction

2020 was a year of significant turbulence 

and uncertainty, which saw companies 

around the world being forced to adapt 

quickly and nimbly to a continually 

changing environment. For the UK, the 

macroeconomic uncertainty caused by 

Covid-19, combined with an ongoing lack 

of clarity on its future relationship with 

the EU, our largest export market, saw the 

fastest contraction in economic activity of 

modern times. 

However, our generally robust performance 

through the year reflects well on our 

ability to withstand major operational and 

market challenges. It is with great pride 

that I can say I now feel more optimistic 

than ever about the longer-term growth 

trajectory of Law Debenture, the strength 

of our business model and quality of our 

investment managers, James Henderson 

and Laura Foll of Janus Henderson 

streams allowed us to invest into some 

emerging companies with excellent long-

term growth prospects who will not be 

paying dividends for many years. 

We have also invested in our central 

leadership team and functions to provide 

greater support to the IPS business. As 

part of this, I have built our Executive 

Leadership team. I am delighted to 

welcome Trish Houston as COO. During 

the year, Hester Scotton was promoted to 

CFO and Kelly Stobbs was promoted to 

General Counsel.

Taking each business in turn:

At the core of 

Law Debenture’s 

financial objectives  

are two keys aims;  

the first is to  

achieve long-term 

capital growth,  

the second is to steadily 

Corporate trust 

increase income for 

our shareholders. 

Law Debenture was founded 132 years 

ago to be a bond trustee. Our role as 

a bond trustee is to act, as a conduit, 

between the issuer of a bond and the 

bondholders themselves. Typical duties 

Investors. As a UK Equity Income Trust, this Company works to 

ensure shareholders can depend on us for regular, reliable income. 

We aim to gradually increase income, by increasing dividend 

payments in excess of inflation over time. 2020 was a year which 

showcased how the unique combination of our equity portfolio 

and leading global professional services business can drive value 

for us include being a point of contact between the issuer and 

its bondholders and receiving certain financial, security and 

covenant information from the issuer, for which we are usually 

paid an inflation-linked annual fee throughout the lifetime of 

the bond. We started 2020 with approximately £5m of annual 

revenues contractually secured.

for our stakeholders. 

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Our leading independent professional services business is built on three excellent foundations: 

our pensions, corporate trust and corporate services businesses.

DIVISION

Pensions

Corporate trust

Corporate services

Total

Net revenue
2018 
£000

Net revenue
2019 
£000

Net revenue
2020 
£000

Growth
2019/2020 
%

9,488

8,362

11,734

29,584

10,598

9,024

12,167

31,789

11,479

10,788

12,226

34,493

8.3%

19.5%

0.5%

8.5%

We also earn revenue from ‘post issuance work’, such as 

went into ‘lockdown’. While we have seen some bankruptcies, 

documentation changes, which can arise over the life of the 

policymakers have provided a number of support mechanisms 

bond. The revenue and risk profile can change substantially 

that have enabled businesses to stay afloat in some form or 

when a bond issuer becomes stressed or a bond issue itself goes 

another. Unsurprisingly, this has led to a plethora of covenant 

into default. In these circumstances, the trustee may be required 

waivers and restructuring type work. The longer-term position 

to perform a material amount of extra work in order to optimise 

for many challenged companies and sectors remains unclear as 

returns for all bondholders. Such default scenarios may involve 

the global economy works its way through this crisis. 

the business incurring costs and can take many years to play out. 

That said, given a favourable result, this may lead to incremental 

revenues for the business. We do not wish any operating 

Highlights
We took on a significant number of new appointments in 

difficulties on any of the issuers in our portfolio. Nonetheless, the 

2020. We are proud to have been appointed by many of the 

countercyclicality of post issuance work with the economic cycle 

UK’s leading companies including BP, Legal & General, British 

has been demonstrated time and again throughout our history.

Telecom and Vodafone for various roles.

Our corporate trust team are considered and careful in taking 

Eliot Solarz, Head of Corporate Trust, continues to invest in his 

on new business. This disciplined approach has produced 

team and build on our reputation for technical knowledge, 

consistent profits for over a century. Our shareholders should 

speed and innovation. We will always play to our strengths and 

understand that short-term swings in our revenue (and in turn 

are able to compete highly effectively against global banks for 

our profit) may result from adopting a prudent approach to 

more complex products.

provisioning, as specific long-term default situations work their 

way through to a conclusion. 

Market dynamics
Following the challenging operating environment in 2019, 

remarkably the onset of Covid-19 and the actions of policy 

makers provided a favourable operating environment for this 

business.

The growth of our escrow offering in 2020 was particularly 
pleasing. Many of our investors who have purchased a home 

may be familiar with the concept of an escrow. In the case 

of a house purchase often a solicitor receives execution 

documentation from the various parties involved (e.g. buyer/

seller/bank/title company etc.) and the associated monies. 

Having satisfied themselves that all is in order, the solicitor then 

distributes the proceeds and documentation accordingly to the 

Primary market activity recovered well in 2020 and we were 

various parties. Eliot’s team does not perform escrows for house 

able to capture our fair share of roles on new bond issues. Our 

purchases, but the principles that underpin his team’s work in 

main market, Europe, had a particularly challenging 2019 with 

this area are in essence the same.

investment banking revenues down 14%, but recovered well in 

2020 with debt issuance revenues up 21%. 

The demand for rapid responses to Covid-19 exposed many 

procurement processes as being cumbersome and overly 

Post issuance work increased materially as many businesses 

engineered. Happily, our escrow offering, was able to move fast 

around the world saw their revenues severely challenged, 

and respond to rapidly evolving demand. Particularly pleasing 

or in some cases even evaporate completely, as economies 

was the role that we played on several PPE related escrows, 

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as various NHS trusts looked to urgently source supply from 

have no crystal ball when looking at 2021. That said, we have a 

around the world. In addition, we upped our profile on escrows 

broad suite of products, deep and long standing relationships 

related to M&A, pensions, litigation and commercial real estate 

with clients, law firms and financial institutions, which give us 

transactions. Our escrow balances ended the year over five 

confidence that we should continue to build on the gains made 

times higher than at the start of 2020.

in our corporate trust business over the past three years.

In 1910, we were trustee to the Kansai Railway in Japan and 

we continue to support long dated infrastructure financing. 

In 2020, we were appointed as the security trustee to the IFC 

backed Almaty Ring Road in Kazakhstan.

We continue to build on our expertise to support financings 

in renewable energy, as demonstrated by the case study on 

Falck Renewables. In addition, as the year ended, we signed as 

Security Agent for the IFC/ADB backed Nur Novi solar power 

project in Uzbekistan.

As we mentioned in last year’s review, social housing is an 

important and growing part of our book of business. We are 

thrilled to have been appointed as bond and security trustee 

on the £2.5 billion note programme launched by London and 

Quadrant during the year.

Falck Renewables SpA – first Italian 
equity-linked green bond

Our experience and knowledge in green finance was 

further enhanced in 2020. We were mandated as 

bond trustee on Falck Renewables SpA’s offering of 

€200 million 0% senior unsecured equity-linked green 

Pensions

Our pensions business completed its fourth successive year 

of positive growth with revenues up by 8.3% for the year. We 

continue to invest heavily in this business. 

Initially founded over 50 years ago as a pension trustee 

business, this remains very much at the core of our offering. 

More recently, we have expanded our governance offerings 

under our Pegasus brand to provide a much broader range of 

services from pensions secretarial through to fully outsourced 

pensions scheme management. We remain the largest and 

longest established independent professional pension trustee 

business in the UK. 

Market dynamics
In the short-term, the stresses placed on the world economy 

by Covid-19 have further highlighted the need for best in class 

pensions governance. At precisely the same time that scheme 

assets and liabilities were experiencing extreme volatility, 

sponsoring employer covenants came under significant strain 

as operating conditions for many businesses were severely 

disrupted. With the need to rapidly move the administrative 

monthly payment of pensions to a robust and secure remote 

bonds. Falck Renewables is a renewable energy company 

operating environment, the necessity for top quality scheme 

who design, build and manage plants that generate clean 

oversight was evident. That said, following a burst of activity 

energy. They plan to use the bond proceeds to finance 

in March and April in particular, the move to virtual meetings 

and/or refinance, in whole or in part, new or existing 

renewable energy assets with expected substantial 

environmental impact (Eligible Green Assets) in line 

with the 2018 Green Bond Principles published by the 

International Capital Markets Association and the May 

2020 Green Loan Principles published by the Loan 

Market Association.

This was the first Italian green convertible  

bond and highlights our involvement in 

new and innovative products. 

Outlook for our corporate trust business
As we have mentioned above, certain aspects of our corporate 

trust business are strongly countercyclical. Recent history 

tells us that, as the world economy recovered from the global 

financial crisis, our post issuance workload should remain at 

elevated levels for some time to come.

Levels of primary market activity are very difficult to predict. The 

see-saw of the past two years is clear evidence of this, and we 

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resulted in shorter meetings which reduced our time based 

charges. We expect that this will reverse somewhat as 

Government remote working requirements begin to fade away.

Over the medium-term, the Pensions Regulator’s drive towards 

a smaller number of better governed defined benefit schemes 

continues to build momentum and plays to our strengths. 
Consolidation provides an opportunity for smaller schemes to 

enhance their governance. A larger asset base may well give a 

scheme the financial resources to employ a professional trustee. 

Put simply, we act for under 5% of the 5,500 defined benefit 

schemes in the UK so there is plenty of room to grow our market 

share in what we believe is a growing market.

While the negative effects of Covid-19 will hopefully only be 

temporary, the Pensions Regulator backed the expansion 

of stewardship definitions and the advancement of ESG 

investment agendas are looking increasingly permanent. Best 

in class standards are rapidly evolving. There is significant 

opportunity for us to help our clients stay ahead of the game as 

the investing world addresses the impact on the environment 

and on society in general.

Chief Executive Officer’s review continued

Highlights
2020 was the year that our outsourced pensions executive 

service, Pegasus, came of age. Pegasus continued to see strong 

revenue growth in 2020 and we are confident that Pegasus 

will continue to increase our share of total pensions revenue. 

We have widely received positive feedback from our quickly 

growing client base. What has been particularly pleasing is 

our ability to execute relatively small appointments well, and 

nurture these into much broader relationships. Chief financial 

officers use tough operating conditions to focus capital 

allocation on activities that differentiate their specific company’s 

offering while simultaneously outsourcing essential but non-

core functions, such as Pensions Administration, where our 

Pegasus business can provide support to oversee such changes. 

Our Pegasus business has also fared well in the ‘temporary staff’ 

market where, for example, opportunities to provide maternity 

cover have added further strings to our bow. Our sole trustee 
solution continues to build momentum and resonates well 

with buyers looking for a ‘one stop shop’ approach to their 

governance needs.

On the trustee side we did much to enhance our reputation 

for innovation – see the adjacent case study on Premier 

Foods by way of example. Through transactions such as these 

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Landmark pensions agreement 
between Premier Foods plc and Premier 
Foods Pension Scheme – significantly 
improving the Group’s pension 
funding situation   

This transformational agreement is testament to our 

Pensions clients ‘getting things done with LawDeb’, our 

expertise in restructuring and commitment to thinking 

holistically and collaboratively, involving all stakeholders. 

Shares in the branded foods maker, which makes 

Mr. Kipling cakes, jumped 17% on the announcement.

A segregated merger of all the Group’s pension schemes, 

placing all the UK defined benefit schemes under one Trust 

was a strategy that LawDeb’s Managing Director of Pensions 

and Chair of the Premier Foods Pensions Scheme, Michael 

Chatterton, was instrumental in taking to and working 

up with the company in the belief that this new pensions 

agreement represents a more secure future for the Group’s 

pension scheme members.

we increasingly catch the eye of the discerning corporate 

The Board and pension trustees expect this will provide 

buyer, not just the pensions team. We also executed well 

greater funding certainty for Premier Foods’ pension 

and added to our expertise in longevity swaps, buy-ins and 

schemes’ members by leveraging the strength and scale 

buy-outs, such as the work we did for Baker Hughes (UK) and 

of the successful RHM pension scheme investment 

the British Bankers’ Association. Increasingly too, we have 

much to offer clients as they navigate the tricky pensions 

waters that lap against M&A activity, such as the work we 

have been appointed to undertake for Cobham. Finally, and 

without wishing ill on any firm, our experience of dealing with 

distressed and restructuring type situations, in both the public 

strategy. The net present value (NPV) of the pension deficit 

contributions could reduce from the current £300m-£320m 

by approximately 45% to £175m-£185m. The merger also 

provides an opportunity to improve the security available to 

all the schemes involved.

and private markets, continues to grow significantly. 

Duncan Leggett, Chief Financial Officer of Premier Foods, 

Outlook for our pensions business
A broad and stable set of foundations underpins the long-

term growth potential of our pensions business. An aging 

population, a growing middle class, a relatively recent 

auto-enrolment regime and strong moves by regulators to 

commented, “This is an innovative and ground-breaking 

initiative to address pension funding that is delivering huge 

value for the members and for the company. 

Law Debenture has been instrumental in  

working with the company to develop this 

professionalise the governance of schemes creates a sound 

strategy and help bring it to conclusion.”

platform on which to build. Our team is well placed to enable 

us to solve our clients’ problems. Our reputation has been hard 

won over five decades. We will continue to invest in our people 

and nurture the next generation of problem solvers in this 

growing market.

I would like to thank Michael Chatterton, Head of Pensions, 

and Mark Ashworth, Chairman of Pensions, for encouraging 

Corporate services 

Overall the diversification within the IPS revenue streams served  

us well in 2020, but our corporate services businesses were 

adversely affected by the pandemic. This revenue stream 

their team to continuously produce advantageous outcomes 

consists of three components: our company secretarial and 

for our clients.

accounting offering, the Safecall whistleblowing business and 

our service of process business. Year on year revenues of £12.2m 

were broadly flat.

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Chief Executive Officer’s review continued

Market dynamics
Company secretarial and accounting 
The growing market for company secretarial offerings is 

underpinned by three main factors. Firstly, ever increasing 

reporting demands on businesses from governments and 

regulatory authorities. Secondly, increased desire by corporations 

to focus their efforts on their particular unique value proposition 

and outsource critical but non-differentiating aspects of their 

business. Thirdly, the increasing speed of corporate lifecycles and 

a lowest cost proposition based around call centre staff following 

scripts, our offering is based on highly trained employees who 

follow a clearly defined process. Issues raised by employees were 

at record levels as they used our service to flag concerns around 

working conditions in particular.

Highlights 
Whistleblowing
We have received much unsolicited praise for our work during 

ever-changing market dynamics hand an advantage to those 

the year. Boards, General Counsels, Heads of Human Resource 

organisations that can access new markets quickly and simply. 

Management, Heads of Risk and Compliance and employers 

Expertise combined with ease of use will remain at the core of our 

have seen real value in the quality and timeliness of our work. 

ability to effectively compete in this market.

Highlights  
Company secretarial and accounting
We have been in this business in a modest way for well over 
twenty years and we understand it well. Our existing business, 

led by Mark Filer, grew soundly off a small base in 2020. 

Particularly noteworthy were roles on residential mortgage 

backed securitisations (RMBS), that we were appointed to for 

LendInvest, an increasingly disruptive property lending company 

in the UK. We further deepened our relationship with Atom 

However, the period from March until June 2020 was dominated 

by a ‘no new projects’ mentality as potential buyers adjusted to 

the uncertainties caused by Covid-19. Sales picked up as the year 

progressed and we ended with roughly the same number and 

same annual contract values of new wins as the prior year. We 
ended the year with revenues up approximately 11.3%. 

High quality clients that we were thrilled to onboard during 

the year included Brompton Cycles, Channel 4 (see the case 

study below), Co-op Food, Morgan Sindall and Wolseley 

(renamed Ferguson).

Bank, a fast growing UK challenger bank, where we acted on 

After 22 years at the helm Graham Long, who founded this 

their new RMBS issue. We were delighted to take on a significant 

business along with his late father Alan, will step back from the 

piece of work with one of the largest pension schemes in the UK, 

day-to-day running of this business during 2021. Safecall has 

the Universities Superannuation Scheme, to help them service 

been an amazing success story as Graham has taken this from 

an equity release funding platform. We also took on our largest 

just an idea to a market leading whistleblowing business that 

ever company secretarial appointment to date on the back of a 

helps employees from well over 500 companies all over the 

complex restructuring of a significant real estate portfolio.

world. As we look to accelerate our growth and adapt the use of 

On 29 January, 2021 we completed the acquisition of the company 

secretarial business of Konexo UK, a division of Eversheds 

Sutherland (International) LLP. This significantly expands our 

footprint in this exciting market.

technology to support this business, Graham felt that the next 

chapters should be written with the help of a fresh perspective. 

At this time, our search for a new Managing Director has just 

started and Graham will remain fully engaged to ensure a smooth 

transition. Our thanks to Graham, but not farewell just yet, as he 

We believe that we can increase our market share in this growing 

will continue to be Non-Executive Chairman of the Safecall Board.

market, and we are confident that there are significant avenues 

for us to explore across our c.450 new clients with respect to 

other Law Debenture offerings. The acquired business is headed 
by Andy Casey. We have very much enjoyed welcoming our new 

colleagues to Law Debenture and look forward to working closely 

with them in the future. 

Market dynamics 
Whistleblowing
Regulatory frameworks continue to be established. The UK 

parliament had its first reading of The Office of the Whistleblower 

Bill in 2020 and in 2021 the European Whistleblowing Directive 

Forbes.com name checks Safecall: 
“UK Broadcaster Channel 4 Promote 
Whistleblowing Facility”

In July Forbes published news of Safecall’s client, Channel 4, 

increasing its marketing of its whistleblowing service to 

allow easier access for production crews to call attention 

to incidents of racism, inappropriate or illegal behaviour, 

malpractice, bribery, fraud and flippancy around the new 

(the Directive) comes into force. The Directive requires that all 

Covid-19 guidelines. 

European companies with over 50 employees and €10million 

in turnover have a whistleblowing solution in place. ISO37002 

for Whistleblowing Management Systems is expected to be 

established in 2021. Despite the fact that this is a relatively new 

market, private equity investors have been quick to see its growth 

potential and have been consistently buying up operators and 

consolidating businesses. While many competitors have followed 

Channel 4 has been a Safecall client since 2015 and we 

are proud to work with them, as we do with 

organisations of all sizes, across various industry 

sectors globally, to ensure the successful 

implementation of our whistleblowing service. 

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We are proud to have delivered a 117% increase in dividend payments over the last 

ten years with 42 years of increasing or maintaining dividends to shareholders.

Service of process
Our service of process business, headed up by Anne Hills, is the 

highest volume transactional business with the least recurring 

These changes bring an increased scale to our operations and 

enhance our controls and security.

contractual revenues of all the IPS businesses. It is highly 

We are increasingly agile users of third party software applications 

correlated to the global economic cycle. Contractions in the 

to support our various businesses. We have also invested 

global economy mean that fewer commercial transactions are 

significantly in customising platforms to both simplify and 

completed, which in turn reduces the demand for a service 
process agent to complete documentation. In 2020, we 

experienced our toughest year since the global financial crisis. 

improve our clients’ user experience.

This past year saw the launch of a number of initiatives for 

our Safecall business. Potential clients can now purchase our 

Our history over many economic cycles in this area gives us 

Safecall whistleblowing services online. In addition, we have a 

confidence that as the world economy recovers, so too will our 

suite of e-learning modules that clients can roll out to all staff 

revenues. Our referral network has been nurtured over many 

that covers everything from the basics through to training for 

decades and is global. In the meantime, we continue to invest 

managers in how to appropriately handle whistleblowing cases. 

in enhancing our use of technology to create a seamless user 

We rapidly shifted classroom based training to online to meet 

experience for our clients in this high volume business. 

client demand, hosting 15 such events in the second half of 2020. 

Outlook for our corporate services business
We believe that the governance services businesses that combine 

to make up our corporate services offering all operate in markets 

that have sound long-term growth prospects. They are, after all, 

elements that make up the “G” in ESG. However, 2020 reminds us 

that even the most robust long-term businesses are not immune 

from unexpected short-term challenges. We have held our nerve 

and increased our investment in these business at a time when 

many competitors could simply not afford to do so, with the aim 

of ensuring we can meet the needs of our customers simply and 

to the highest of standards. 

Technology

These gains are hard earned, but we must quicken our pace of 

change. As we start 2021, we are determined to further enhance 

our operational efficiency and resilience, and to creatively evolve 

our products and services. We expanded our IT team in 2020 and 

will do so again in 2021. Increasingly, we are using technology to 

interface with our clients and our future success will depend on 

our ability to satisfy their rapidly accelerating demands.

Property

2020 was certainly an interesting year for the lease on our Head 

Office to expire. After plenty of searching we settled on a new 

lease for premises at 100 Bishopsgate, EC2N 4AG. Despite the 

challenges of 2020, this move was successfully completed 

If ‘Covid’ was the word of the year for 2020 then ‘Zoom’ must 

during the year. 

be a close second. If we could have received a pound for each 

The new building has excellent transport links as it is situated 

time we said “you’re on mute”, we would have all done rather 

across the street from Liverpool Street station. Importantly, the 

well. Surely one of the largest gains that the global economy will 

building has been designed to limit its impact on the environment, 

benefit from, as we emerge from the Covid-19 crisis, is the crash 

as shown on the diagram on page 17.

course in technology that we all received as we transitioned 

to fully remote working in March 2020. It was the digital era’s 

equivalent of a rapid mass literacy program.

An unintended consequence of the eleven months since 

lockdown last March has been a most thorough test of our 

remote working environment. It is clear we are able to work from 

I am delighted to report that our own technology platform was 

home. Some staff felt that there were productivity gains when 

up to the challenge. Having joined us in December 2018 our Chief 

the need arose to avoid distractions and spend an extended 

Technology Officer (CTO), David Williams, was front and centre 

period to complete a complex piece of client work. However, 

in ensuring that, after 131 years of being on site, our business was 

it is also clear that to work optimally we must retain a modern 

able to seamlessly transition to a virtual existence. Under David’s 

fit for purpose office environment. We are collectively more 

leadership, our growing technology team has transitioned much 

efficient and creative. We benefit from collaboration and we have 

of our outdated hosted infrastructure to cloud-based services. 

more fun. 

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Chief Executive Officer’s review continued

Prospects

Although it is impossible to predict when global economies and 

our everyday lives will return to normal post the turmoil that 

Covid-19 has brought, I remain optimistic in our longer-term 

outlook. Your Company is resilient and prospects remain bright 

with a strong and dedicated team. 

We closed the year in a solid position, despite the economic 

turmoil. Your Company continued to execute against its stated 

strategy of growing the IPS business. We acquired the company 

secretarial business of Konexo UK, taking an important step 

forward to cement our position in a growing and attractive 

sector. This strengthens our IPS business and its longer-term 

earnings outlook. We look forward to continuing to grow 

and develop the IPS business and build greater market share 

by seeking to further capitalise on the significant market 

opportunities available through both organic investment and 

disciplined acquisitions, where appropriate. 

Over the last three years we have shown an IPS compound 

annual growth rate (CAGR) of 8.3% and 9.1% respectively for 

revenue and earnings per share. There have been ups and 

downs by individual area but this correlates well with our mid to 

high single digit medium-term growth ambition.

It is in challenging times like these when good judgement 

and extensive knowledge is critical to a successful investment 

strategy and I am grateful that Law Debenture has been able to 

benefit from both James’s and Laura’s expertise and experience. 

I am confident that their focus on selecting strong business 

models and attractive valuation opportunities, coupled with a 

deep understanding of companies and industries, will enable 

them to continue to position the equity portfolio for future 

longer-term growth and outperformance.

On behalf of the Board, I would like to thank our shareholders for 

their continued support and confidence in our abilities during a 

particularly tumultuous time. At Law Debenture, we greatly value 

our culture and close partnership with clients. I would also like to 

express my deepest thanks to our employees; their commitment 

has shone through. I look forward to keeping you updated on the 

Group’s future operational and strategic achievements.

Denis Jackson 
Chief Executive Officer

25 February 2021

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In 2021, when Government guidance encourages a return to the 

workplace, we plan to allow employees to work up to two days 

per week from home with their manager’s approval. This allows 

our staff to retain flexibility and keep the gains of periodic remote 

working, while ensuring that for the majority of our time we are in 

a communal environment where we are most effective. 

Given our change in work patterns, our shift of much of our IT 

infrastructure to cloud-based services, and the huge digitalisation 

initiative, we were able to reduce our physical footprint by 

approximately one third.

Like a house move, an office move provides a wonderful 

opportunity to throw things away. In common with many 

professional services firms we had paper everywhere. It was a 

huge one-off project but we were able to digitalise many decades 

worth of materials. This makes retrieval easier, reduces demand 

for physical storage space and reduces our costs. 

As part of this process, we uncovered many items which 

showcased our rich history. These included a glorious 999 year 

lease on a property complete with wax seal signed six weeks 

before the Battle of Waterloo. Sadly the lease was not ours, rather 

it belonged to a client.

Having moved in during early December, we look forward to 

welcoming our staff and our clients to our new space as 2021 

unfolds. 

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www.100bishopsgate.com/sustainability

SOLAR ENERGY 
Photovoltaic panels and 
solar hot water panels are 
roof mounted to generate 
renewable electricity and 
heat energy respectively

OCCUPANCY SENSORS 
Efficient light fittings, zoning 
and automated controls

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HEALTH &  
WELLBEING
The building has been 
designed to be adaptable  
for future climate change  
to ensure thermal comfort  
for occupants

WATER 
Estimated 35,000m3   
of water saved p.a.

WASTE 
Greater than 90% of 
waste to be diverted 
from landfill

MANAGEMENT 
The project is targeting 
exemplary performance 
under the Considerate 
Constructors Scheme with  
a minimum score of 40

MATERIALS 
Targeting  
100% of  
materials  
responsibly  
sourced

C

ENERGY 
23.7% improvement over Part 
L 2013 predicted more than 
600 tonnes CO2 saved p.a 
(compared to Part L 2013)

TRANSPORT 
900 cycle storage spaces and 
lockers, additional showers 
and changing facilities

POLLUTION 
SUDS strategy to ensure the 
development has a neutral impact 
on surface water runoff through 
provision of attenuation tanks

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ECOLOGY 
362m2 green wall with a diverse flowering 
period to encourage invertebrates such as 
bees and butterflies. Provides nesting 
opportunities for various birds including 
swifts and sparrows

17

 
 
S T R A T E G I C   R E P O R T

Investment managers’ review

as Microsoft, had on average performed well and were trading on 

high valuations versus history, while we were finding a number of 

attractive valuation opportunities in the UK.

Our investment strategy 

We take a bottom-up approach, spending a great deal of time with 

the management teams of our portfolio companies, conducting 

detailed analysis of the strengths, weaknesses and growth 

prospects of those companies into which we invest your money. 

Were there to be a common theme amongst the diverse portfolio, 

it would be that the majority of companies held are market leaders 

in the product or service they are providing. This market leadership 

could be in the UK or on a global scale; it could be a small niche 

market such as UK paving stones (Marshalls) or a large global 

market such as oncology drugs (Bristol-Myers Squibb). What we 

are looking for is companies with excellent products or services 
and with experienced management teams that can help navigate 

different market environments. 

We are patient with our positions and invest for the long-term. We 

build up positions gradually. Having taken the decision to invest in 

a stock, we typically begin by investing around 30bps of overall net 

asset value, and then add to this over time, depending upon the 

risk profile of an individual stock.

Our long list of stocks allows us to moderate our position size 

where we perceive the investment case is higher risk than may be 

the case elsewhere in the portfolio. This means that we take a risk-

The equity portfolio

In a wholly unpredictable year, diversity within the investment 

portfolio was particularly important. This portfolio benefitted from 

its aim to be a ‘one stop shop’ for investors, by holding equities 

in a deliberately diverse collection of well-managed, market 

leading companies. While the majority of 

the portfolio (82%) was invested in the UK at 

year end, much of underlying revenues from 

the portfolio were derived from overseas. In 

addition to geographic diversity, the long list of 

holdings, 137 at year end, alongside the broad 

range of end market operations, meant that 

the portfolio held enough beneficiaries from 

the current environment to show growth of 

3.6% in absolute terms during the year, while 

the FTSE All-Share benchmark fell 9.8%. We 

will go on to discuss the largest contributors to 

performance in greater detail, but the need to 

decarbonise the global economy and the shift 

of much of consumer spending to online were 

common themes among the best performers. 

By the calendar year end we were roughly 

neutral net investors within the portfolio. 

However, during the course of the year we 

invested heavily in the Spring and, by the end 

of March, had invested £36.8m (net). This net 

investment was then gradually reduced as 

valuations rose, particularly in the final month 

We increased 

our leverage and 

repositioned our 

holdings over the 

course of the year 

to take advantage of 

comparatively low 

valuations within the 

UK market, particularly 

for domestic stocks. 

based approach to our position sizing, 

while ensuring that, if we get something 

right, the sizing is sufficient to influence 

the portfolio performance as a whole. 

Our patience keeps our portfolio turnover 

low, reducing the drag of dealing costs 

on returns to our investors. That patience 

has rewarded our shareholders; over 10 

years, the portfolio has outperformed the 

benchmark index by 69% (valuing debt 

at par).

ESG considerations in 
our investment strategy 

Responsible investing, incorporating 

ESG, has always been an integral 

feature of our process as we are long-

term investors. Therefore any material 

ESG issues are also material to the 

investment case. These issues are of 

growing prominence to both investors 

and companies and whilst they have 

of the year. Geographically, sales were concentrated in North 

always been an implicit part of the investment process, we are 

America, where on a net basis we sold £30.5m during the year, 

now explicitly both monitoring internally and discussing with 

while purchases were concentrated in the UK, where on a net basis 

company management teams any particular issues of concern. We 

we purchased £24.8m. This geographic difference was not driven 

have decided not to explicitly exclude any sectors, partly because 

by a macroeconomic view. The US stocks sold during the year, such 

the data quality on the more difficult to measure environmental 

18

lawdebenture.com 

Investment managers’ review continued

NAV total return (with debt at par)1

NAV total return (with debt at fair value)1

FTSE Actuaries All-Share Index total return2

1 year 
%

3.6

2.0

(9.8)

3 years 
%

15.6

13.2

(2.7)

5 years 
%

59.1

53.0

28.5

10 years 
%

147.8

134.7

71.9

1   NAV is calculated in accordance with AIC methodology, based on performance data held by Law Debenture including fair value of IPS business. NAV total return with debt at par excludes 

the fair value of long-term borrowings, where NAV total return with debt at fair value includes the fair value adjustment.

2  Source: Refinitiv Datastream, all references to ‘FTSE All-Share’ and ‘benchmark’ in this review refer to the FTSE Actuaries All-Share Index total return.

and social area is not robust, and partly because, in our view, it is 

change in consumer behaviour will remain long-term issues for the 

better to engage with companies to encourage better practices 

economy. In this economic environment we need to be invested in 

rather than to sell the shares. In addition to monitoring the risks 

companies that have a credible way forward to deal with a testing 

associated with ESG issues, we also aim to invest in companies 

economic backdrop.

that are seeking positively to address these challenges, such as 

the need to decarbonise the economy. One such area is hydrogen 

fuel cells, and portfolio performance this year has benefitted from 

UK market backdrop

exposure to this area.

Overview of 2020 

Prior to 2020, the UK equity market had underperformed 

other developed equity markets in the period following the EU 

referendum vote in 2016. 2020 was no exception, meaning that 

over a five-year period the UK equity market has underperformed 

The lessons the authorities learnt in the financial crisis of 2008/9 

Continental Europe by 38% and the US by 90%.

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proved invaluable in dealing with the crisis brought about by 

Covid-19. Co-ordinated quantitative easing and fiscal stimulus 

saved the global economy from the extreme fall-out that might 

have happened as businesses were forced to close their doors as 

‘lockdown’ was imposed. The authorities’ actions stabilised markets 

and Law Debenture’s asset value was virtually unchanged on 

the year. The economy and its outlook, however, were impacted 

dramatically and we saw a rapid acceleration of existing structural 

trends. For instance the move in retailing from physical stores to 

online was already happening but it received an extraordinary 

boost. The desire for decarbonisation of the economy was well in 

motion but again the progression has been rapidly advanced by 

the desire to rebuild a more sustainable environment after the 

pandemic. These trends have had a massive effect on equity prices, 

with the best performing areas of the portfolio being in companies 

that are working towards the goal of decarbonisation, and the 

worst being the property companies that own retail space, along 

with aerospace companies. 

Economic backdrop
The UK economy contracted violently in March as the virus 

THE UK HAS UNDERPERFORMED OTHER GLOBAL EQUITY 
MARKETS

250

210

190

170

150

130

110

90

70

D ec 2 0 2 0
M ar 2 0 2 0
S e p 2 0 2 0
Ju n 2 0 2 0
D ec 2 016
D ec 2 018
D ec 2 019
D ec 2 015
M ar 2 016
M ar 2 018
M ar 2 019
S e p 2 016
S e p 2 018
S e p 2 019
D ec 2 017
M ar 2 017
S e p 2 017
Ju n 2 016
Ju n 2 018
Ju n 2 019
Ju n 2 017

UK

US

Europe ex UK

Japan

Source: Refinitiv Eikon. £, total return, rebased to 100 as at 31st December 2015. Indices 

used – FTSE All-Share, S&P 500, MSCI Europe ex UK, Nikkei 225.

The reasons for this underperformance include the uncertain 

took hold and ‘lockdown’ was enforced. The gradual easing of 

future trading relationship with the EU and the sector composition 

restrictions saw a rapid recovery in economic activity that was 

of the UK market, with comparatively more in underperforming 

further aided by the prospect of a limited free trade deal with the 

sectors such as energy, and comparatively less in outperforming 

European Union. However, by the year end the re-imposition of 

sectors such as technology. During 2020 there was also a larger 

‘lockdown’ meant the pick-up in activity lost momentum. During 

contraction in UK GDP following the pandemic than in other major 

this period there has been an extraordinary shift to private saving 

economies. With the UK economy forecast to grow strongly in 

and the state increasing its borrowing. This can be done as interest 

2021 (5.3% on consensus numbers), and a free trade agreement 

rates remain very low. However, a great deal of production has 

on goods reached with the EU, these overhangs on the UK equity 

been lost, some capital spend programmes have been deferred 

market could be lifting at a time when UK companies are trading 

and unemployment has risen. The economy has materially shrunk; 

at a stark valuation discount to their global peers. The above graph 

UK GDP on consensus is estimated to have contracted 11.3% in 

shows the discount of the UK market relative to the US and Europe 

2020. Some economic activity will recover relatively quickly. 

on cyclically adjusted price/earnings. The UK also trades at a 

However, higher government debt and the losers from structural 

discount using other valuation methods such as price/book.

19

 
S T R A T E G I C   R E P O R T

Investment managers’ review continued

CYCLICALLY ADJUSTED P/E ACROSS REGIONS

historical revenue reserve, allowed the Board to confidently grow 

50

45

40

35

30

25

20

15

10

5

0

the dividend 5.8% year on year.

From a capital perspective, the below-benchmark portfolio yield at 

the start of 2020 insulated the portfolio from being overly exposed 

to among the worst performers last year. The best illustration 

of this is the comparative performance of the FTSE 350 High 

Yield index and the FTSE 350 Low Yield index last year, where it 

can be seen that on average higher yielding stocks substantially 

underperformed.

While 2020 was a challenging year for UK dividends, in the 

latter half of the year there were reasons for optimism on the UK 

8
9
9
1

9
9
9
1

0
0
0
2

1
0
0
2

2
0
0
2

3
0
0
2

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

dividend outlook. Many companies held in the portfolio which had 

suspended dividends in the first half of the year, chose to resume 

UK

US

Europe ex UK

Source: Refinitiv Eikon as at 7 December 2020. Indices used: UK – FTSE All-Share, US – FTSE 

North America, Europe ex UK – FTSE Europe ex UK.

Income backdrop
In prior years, we have emphasised the unique advantage of 

paying and in some cases catch up on missed payments. In the 

banking sector, while dividends remained forcibly suspended 

by the regulator, there were clear indications from management 
teams that when restrictions were lifted they would seek to 

resume dividends. Following updated guidance from the regulator, 

we expect modest dividends to resume.

Law Debenture’s structure, with the income generated by the 

In 2021, we expect investment income from the portfolio to rise, 

IPS business allowing greater flexibility to invest in lower or zero 

but not to reach 2019 levels. Some companies held, including Royal 

dividend yield stocks within the investment portfolio. This allows 

Dutch Shell and BP, have permanently rebased their dividends lower 

us to focus on capital generation, while knowing that historically 

as they seek to transition their portfolios gradually away from fossil 

approximately a third of the Trust’s income has been provided by 

fuels towards renewable energy. Other companies (such as those 

the IPS business. In a year when investment income fell 38% to 

exposed to the aerospace industry) continue to have limitations 

£18.1m (2019: £29.2m) as a result of the pandemic (approximately 

on their trading as a result of the pandemic and therefore will not 

in line with the fall seen in the wider UK market), this greater 

return to paying dividends until 2022 at the earliest.

flexibility provided by the growing income from the IPS business 

helped the Trust from both an income and a capital perspective.

From a shareholder perspective, the share of Group income 
generated by the IPS business this year grew to 43.4%1. Therefore 
the fall in investment income was partially offset by growing 

income from the IPS business. This, combined with the large 

COMPARATIVE PERFORMANCE OF THE FTSE 350 HIGH YIELD 
INDEX AND THE FTSE 350 LOW YIELD INDEX

105

100

95

90

85

80

75

70

65

60

D ec 2 019

Ja n 2 0 2 0

Fe b 2 0 2 0

M ar 2 0 2 0

A pr 2 0 2 0

M ay 2 0 2 0

Ju n 2 0 2 0

Jul 2 0 2 0

A u g 2 0 2 0

S e p 2 0 2 0

O ct 2 0 2 0

N ov 2 0 2 0

D ec 2 0 2 0

FTSE 350 High Yield

FTSE 350 LowYield

Source: Refinitiv Eikon. £, total return, rebased to 100 as at 31 December 2019.

1  Calculated on IPS contribution to total earnings per share for year end 31 December 2020. 

20

lawdebenture.com   

Top five contributors

The following five stocks produced the largest absolute 
contribution for 2020:

Stock

Ceres Power

ITM Power

Herald Investment Trust

Rio Tinto

Royal Mail

Share price 
total return (%)

Contribution 
(£m)

403.8

626.1

51.7

21.5

49.2

33.5

13.3

6.0

3.6

3.4

Source: Share price total returns from Bloomberg, all in £.

Portfolio attribution 

There were broadly two themes to the best performers during 

the year; companies exposed to the need to decarbonise the 

global economy, and companies exposed to the shift of much of 

consumer spending online.

Ceres Power, which designs hydrogen fuel cells, and ITM Power, 
which produces electrolysers that can be used to generate ‘green 

Investment managers’ review continued

hydrogen’ from renewable energy, were both among the best 

performers. In both cases the technology has existed for some 

loan losses (HSBC). GlaxoSmithKline in the table above is the 
exception to this, with earnings expectations remaining largely 

time, but one of the catalysts for the shares performing well was 

unchanged during the year as a result of its defensive end 

they both received external validation from strong commercial 

markets (vaccines, pharmaceuticals and consumer healthcare). 

partnerships; Ceres agreed a manufacturing licence agreement 

The underperformance could be due to lower earnings growth 

with Bosch, and later in the year Doosan in South Korea, while 

than pharmaceutical peers as they continue to invest heavily in 

ITM Power formed a partnership with industrial gas producer 

research and development in order to improve their pipeline. We 

Linde. These commercial partnerships came at a time when many 

continue to view this as a long-term opportunity and it remains a 

developed economies are increasingly willing to make substantial 

top ten holding.

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investments in ‘green technology’ in order to meet future 

environmental targets.

Both Herald Investment Trust and Royal Mail benefited from the 
accelerated move ‘online’ in 2020. Herald invests predominantly 

in technology shares, which performed exceptionally well 

last year as businesses shifted to working remotely and were 

increasingly reliant on cloud computing, and consumer spending 

moved increasingly online. Royal Mail had for many years seen a 

gradual decline in letters and an increase in parcel delivery; this 

trend was accelerated last year, allowing them to progress with 

their reconfiguration of the delivery network and reallocation of 

costs towards parcels.

Top five detractors

Portfolio activity

What we have been buying
The most material decision during the year was to be net investors 

during the peak of the market weakness in Spring. March was 

the most active month for net investment, where we invested an 

additional £14.8m in the portfolio.

The investment process aims to identify market leading, well-

managed businesses and invest at the point of which they are out 

of favour. There was an abundance of these opportunities during 

the Spring. We invested broadly, adding to both existing positions 
such as Aviva, and establishing new positions such as Anglo 
American and Marks & Spencer. While there was deliberately no 
commonality in these additions in terms of geography or end-

The following five stocks produced the largest negative 
impact on the portfolio valuation for 2020:

market exposure, we focused purchases on companies that would 

benefit from a global economic recovery following the pandemic. 

Stock

Royal Dutch Shell

Hammerson

GlaxoSmithKline

BP

HSBC

Share price 
total return (%)

Contribution 
(£m)

(43.8)

(82.4)

(20.6)

(46.0)

(36.0)

(12.3)

(9.2)

(7.3)

(6.9)

(5.7)

Source: Share price total returns from Bloomberg, all in £.

The worst performing stocks during the year were broadly 
those exposed to a fall in economic activity, whether via the 

fall in the oil price as transportation fuel demand fell markedly 
(Royal Dutch Shell, BP in the table above) or those exposed 
to further declines in already low interest rates and uncertain 

This modest shift in the portfolio towards sectors that are more 

cyclical can be seen in the sector composition at year end, with 

a higher weighting in, for example, materials and oil and gas 

than the previous year. It is also evident in the top five purchases 

detailed below, which are spread between financials, materials 

and oil and gas.

What we have been selling
Sales during the year were predominantly for either valuation 
reasons or driven by corporate activity. For example Microsoft, 
which had for a number of years been the largest overseas holding 

in the portfolio, performed well following the pandemic and in our 
view there were better valuation opportunities elsewhere. Ceres 
Power was reduced following strong performance, partially in 
order to fund other investments in the alternative energy sector 
such as AFC Energy.

In our view the long-term positives of the UK market have been forgotten with the 

political uncertainty in recent years, but continue to represent a valuation opportunity for 

long-term investors. We therefore remain happy with approximately 80% of the portfolio 

invested in the UK as at the end of December.

21

 
 
S T R A T E G I C   R E P O R T

Investment managers’ review continued

The position in insurer RSA was sold following a takeover offer 
from overseas peers. Towards the end of the year there was a 

Outlook 

notable pick-up in takeover activity in the UK, with another of the 
portfolio’s holdings (Elementis) also receiving a takeover approach. 
This is a theme that we expect to continue in the current year 

Structural changes that are happening in the economy throw up 

opportunities, as well as severe challenges for companies. The 

speed of the change has accelerated as a result of Covid-19, but 

while there continues to be a valuation gap between UK and other 

reflects the longer-term trend that intellectual capital has been 

developed equity markets.

Five largest purchases

The largest five purchases during the year are detailed 
below:

Stock

M&G

Barclays

Anglo American

Aviva

BP

Five largest sales

 Total purchased 
(£m)

7.4

7.1

6.9

6.7

6.3

replacing physical assets as the driving force for corporate success. 

The shelf life of intellectual capital can be short. This is the reason 

behind the need for an active rather than a passive approach to 

portfolio management. We will retain a broad and relatively long 

list of stocks. We are always on the lookout for stocks that are 

reasonably valued and have characteristics that cannot be found in 

the UK. The focus, though, will be predominantly in the UK as this 

is where value can be found. The companies will be serving a wide 

range of end markets. Diversity is important in order to achieve a 

reasonable level of consistency in returns.

The companies held are adapting to the challenging economic 

backdrop. The key is to have excellent products and services that 

remain relevant to the customer. This usually means an emphasis 

on research and productive capital expenditure. Therefore the 

portfolio is about the individual companies, and it is not a proxy 

for the economy. The overall valuation of the stocks held remains 

undemanding using history as a guide. Therefore, the intention 

is to retain a reasonable level of gearing so that the portfolio 

is fully exposed to the opportunities that can be found in the 

The largest five sales during the year are detailed below:

equity market.

Stock

Ceres Power

AstraZeneca

Flutter Entertainment

Microsoft

RSA Insurance

James Henderson and Laura Foll
Investment managers

25 February 2021

 Total sold 
(£m)

21.4

13.3

12.0

10.9

10.7

Investment managers ESG case study: Severn Trent

The investment managers held a call in 2020 with the new Chair of water company Severn Trent covering a broad range of ESG 

issues, including board composition and succession planning, human capital, health and safety, customer service and climate 

change. Severn Trent is using a 30-year time horizon to model detailed climate and weather predictions. The company saw 

increased water consumption during the warm weather in 2020, while the shift to working from home has also seen a change 

in consumption patterns. As a result, the company is building more resilience into their systems. 

Severn Trent has strong leadership across the senior executive team and was well prepared to respond to the 

challenges presented by Covid-19. The UK Government is seeking advice from the CEO on how to manage a 

company in a socially distanced environment. While the water sector has faced significant controversies over the 

industry’s track record for customer service and environmental management, we regard Severn Trent as an 

industry leader on ESG issues.

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Portfolio by sector and value

Portfolio by sector 
2020

Portfolio by sector 
2019

Oil and gas  11.6%

Basic materials  9.3%

Industrials  22.0%

Consumer goods  6.2%

Health care  5.2%

Consumer services  8.9%

Telecommunications  1.9%

Utilities  4.8%

Financials  28.5%

Technology  1.6% 

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Oil and gas  9.7%

Basic materials  6.4%

Industrials  23.2%

Consumer goods  5.2%

Health care  8.9%

Consumer services  10.2%

Telecommunications  1.1%

Utilities  4.0%

Financials  28.9% 

Technology  2.4% 

Geographical distribution 

Geographical distribution 

of portfolio by value 
2020

of portfolio by value 
2019

United Kingdom  82.1%

North America  5.4%

Europe  10.1%

Japan  1.1%

Other Pacific  0.9%

Other  0.4%

United Kingdom  80.7%

North America  8.3%

Europe  7.8%

Japan  1.1%

Other Pacific  0.9%

Other  1.2%

23

 
S T R A T E G I C   R E P O R T

Fifteen largest holdings: investment rationale 

as at 31 December 2020

Rank 
2020 Company

1

Ceres Power

% of 
portfolio 

Approx 
Market Cap.

Valuation 
2019 
£000

Purchases
£000

Sales
£000

Appreciation/ 
(Depreciation)
£000

Valuation  
2020 
£000

2.99

£2.7bn

12,052

—

(21,368)

33,513

24,197

Ceres Power operates as a fuel cell technology and engineering business. The technology is fuel flexible and is licensed to partners 

including Bosch, Weichi, Minra and Doosan. Therefore, strong revenue growth is expected in coming years. The desire to push towards 

lowering carbon emissions drives the need for fuel cell technology to be adopted. Their fuel cell is being used to power buses in China as 

well as data centres in the UK. The adoption of this new technology is rapidly spreading. 

2

GlaxoSmithKline

2.77

£70.2bn

29,792

—

—

(7,314)

22,478

GlaxoSmithKline is one of the world’s largest pharmaceutical, vaccine and consumer healthcare companies. GSK currently trades at 

a discount to the global pharmaceutical sector. Whilst they have world leading consumer healthcare and vaccines businesses, the 

pharmaceutical division has lagged behind others, for example in innovative oncology drugs. With a new CEO in place, along with a new 

Head of Pharmaceuticals and a new Head of Research, they are re-investing in research and development and focusing on innovative 

products. Given the long development time within pharmaceuticals it will take years for this change to become fully evident but we are 

seeing early stages of an improved drug pipeline. 

3

Rio Tinto

2.53

£77.2bn

16,884

—

—

3,628

20,512

Rio Tinto is one of the world’s largest mining companies with a particular focus on iron ore, aluminium and copper. Their mines are well 

positioned on the cost curve, often at the lowest cost quartile globally, meaning that they can continue to be highly cash generative 

despite volatile commodity prices. This cash generation combined with a strong balance sheet has resulted in an attractive ordinary 

dividend payment, combined with some special dividends in recent years. Dividends have continued to be paid in 2020 despite a 

volatile demand backdrop for commodities.

Following the Juukan Gorge site destruction, Janus Henderson extensively engaged with the Rio Tinto board and management team. 

We continue to be of the view that Rio has high levels of corporate governance relative to mining peers and took appropriate action 

following the disaster to replace management and improve standards.

4

Herald Investment Trust

2.16

£1.4bn

12,580

—

(1,073)

5,998

17,505

Herald is a global technology focused investment trust managed by Katie Potts, who launched the Trust in 1994. Its technology focus 

brings worthwhile diversity to the portfolio and it has been an excellent performer over time.

5

Royal Dutch Shell 

1.94

£52.2bn

27,994

—

—

(12,251)

15,743

Royal Dutch Shell is a vertically integrated oil and gas company. Following a fall in the oil price in 2020, the Board took the decision to 

rebase the dividend by two thirds and further reduce capital and operating expenditure. At the rebased level the dividend is covered 

by free cash flow at the current oil price and is in a position to grow if the oil price recovers. Shell are perceived to be among the leaders 

within integrated oil and gas companies in the transition to renewable energy. We expect further detail on their renewable energy 

strategy early in 2021.

6

BP

1.79

£60.8bn

15,091

6,285

—

(6,852)

14,524

BP is a vertically integrated oil and gas company. Under a new CEO, BP have announced ambitious plans to reach net zero carbon 

emissions by 2050 and gradually transition away from fossil fuels towards renewable energy. The cash generation from their oil and gas 

business should enable this transition to take place, while also continuing to fund cash returns to shareholders via dividends (and likely 

share buybacks in the future).

7

Prudential Corp

1.55

£37.1bn

13,506

—

—

(925)

12,581

Prudential Corp is a leading provider of insurance products in Asia, with additional operations in the US. In 2019 Prudential spun off 

its M&G division, which constituted its UK business. This brings a clearer focus to the company and enhances its growth prospects. The 

savings market in Asia is immature and has strong growth drivers. In our view the franchise value of their Asian business is not fully 

reflected in the current share price. The business will simplify further as they plan to list a portion of their US business on the market in 

early 2021.

8

National Grid

1.5

£30.1bn

13,307

—

—

(1,118)

12,189

National Grid are a regulated utility company with operations in both the UK and the US. The need to reduce global carbon emissions 

is likely to increase demands on electricity networks and this could lead to faster regulated asset growth in future driven by the need to 

increase grid capacity. The position brings defensive qualities and continues to pay an attractive dividend yield.

24

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Fifteen largest holdings: investment rationale continued 
as at 31 December 2020

Rank 
2020 Company

% of 
portfolio 

Approx 
Market Cap.

Valuation 
2019 
£000

Purchases
£000

9

Morgan Advanced Materials

1.47

£0.9bn

11,095

974

Sales
£000

—

Appreciation/ 
(Depreciation)
£000

Valuation  
2020 
£000

(95)

11,974

Morgan Advanced Materials is a specialist materials producer for a wide variety of end markets including transportation, healthcare, 

industrials and semiconductors. Under a relatively new management team they have simplified the business via divestments, 

strengthened the balance sheet and invested in new product development. Industrial end markets in 2020 were challenging. However, 

management have responded to end market weakness by permanently reducing costs such as closing manufacturing facilities. In our 

view, when sales recover the margins generated will be higher than prior to the pandemic.

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HSBC

1.46

£83.1bn

15,606

1,955

—

(5,680)

11,881

HSBC are a global bank with a substantial presence in Hong Kong and mainland China. Their geographic focus brings worthwhile 

diversity to the portfolio. As a result of Covid-19 they have suspended their dividend following guidance from the regulator, and the level 

of future loan impairments is difficult to forecast. However, the shares are trading at a material discount to book value which, in our view, 

suggests a degree of uncertainty is already reflected in the share price. The new management team also have a ‘self-help’ opportunity to 

scale back their relatively lower returning US and European businesses in order to improve the overall group returns.

11

ITM Power

1.41

£3.0bn

2,295

1,160

(5,285)

13,318

11,488

ITM Power designs and manufactures integrated systems for energy storage and clean fuel production. It is a world leader in electrolysis, 

allowing ‘green hydrogen’ to be produced using electricity from renewable energy and water. Their products should allow ITM Power to 

capture growth from increased hydrogen usage. A large new plant will be commissioned this year to satisfy growing demand with their 

project partner, Linde.

12

Severn Trent

1.41

£5.6bn

12,575

—

—

(1,135)

11,440

Severn Trent is a UK water utility. It is one of the best quality water companies in the UK on metrics such as preventing leakages as it has 

a well invested network. The position brings defensiveness to the overall portfolio and the dividend yield remains attractive.

13

Accsys Technologies

1.37

£0.3bn

8,218

—

—

2,913

11,131

Accsys Technologies focuses on the sustainable transformation of wood through acetylation (creating a natural sealant to protect 

against erosion). It is scaling up production with a new plant, which will be commissioned in 2021, to satisfy the strong demand for 

their products. 

14

Aviva

1.36

£13.6bn

5,380

6,665

—

(1,037)

11,008

Aviva is a diversified insurer that writes life and non-life insurance. Under a new chief executive, they are focusing the business on 

geographies where they have strong market positions and are divesting assets in more peripheral geographies. The shares trade with 

a conglomerate discount relative to insurance peers and a more focused group would, in our view, merit a higher valuation. The shares 

continue to pay an attractive dividend yield to shareholders. 

15

Anglo American*

1.34

£37.6bn

—

6,838

—

4,072

10,910

Anglo American is a diversified mining company with exposure to commodities including copper, iron ore, diamonds and platinum. It 
is well positioned to benefit from the need to decarbonise the global economy. For example, it is significantly exposed to copper where 

demand is likely to grow driven by its use in electric vehicles and renewable energy. Anglo American are also among the leaders within 

the mining sector on environmental targets, aiming to be carbon neutral in their own operations by 2040.

*Anglo American was first purchased on 12 March 2020.

2525

 
S T R A T E G I C   R E P O R T

Classification of investments 

based on market values as at 31 December 2020

North  
America 
%

Europe 
%

Rest of the 
world 
%

Oil and gas
Alternative energy

Oil and gas producers

Oil equipment services and distribution

Basic materials
Chemicals

Forestry and paper

Mining

Industrials
Aerospace and defence

Construction and materials

Electronic and electrical equipment

General industrials

Industrial engineering

Industrial transportation

Support services

Consumer goods 
Automobiles and parts

Food and drug retailers

Food producers

Household goods and home construction
Personal goods

Tobacco

Health care
Health care equipment and services

Pharmaceuticals and biotechnology

Consumer services
General retailers

Media

Travel and leisure

Financials
Banks
Equity investment instruments

Financial services

Life insurance/assurance

Nonlife insurance

Real estate investment trusts

Real estate investments and services

Technology
Software and computer services

Technology hardware and equipment

Telecommunications
Fixed line telecommunications

Mobile telecommunications

Utilities
Electricity

Gas, water and multiutilities

TOTAL 2020
TOTAL 2019

26

lawdebenture.com  

U.K. 
%

 1.36 

 4.32 

 4.60 

 10.28 

 1.78 

 1.01 

 5.17 

 7.96 

 4.18 

 4.49 

 2.88 

 1.30 

 2.58 

 1.37 

 2.40 

—

 0.68 

 0.38 

 1.06 

—

—

—

—

—

—

—

—

 1.94 

—

—

 19.20 

 1.94 

—

 0.74 

—

 1.49 
 0.54 

 0.58 

 3.35 

 0.87 

 2.77 

 3.64 

 3.23 

 2.34 

 1.39 

 6.96 

 5.51 
 3.83 

 5.76 

 4.09 

 2.38 

 2.98 

 0.91 

 25.46 

—

—

—

 0.49 

 0.52 

 1.01 

 1.02 

 3.08 
 4.10 

 81.96 
80.75

 0.84 

—

—

—
—

—

 0.84 

—

 0.70 

 0.70 

—

—

—

—

—
—

—

—

—

—

—

—

—

 0.89 

 0.89 

—

—

—

—

—
—

 5.43 
8.30

—

 0.26 

—

 0.26 

 1.33 

—

—

 1.33 

—

—

—

 0.36 

—

—

 0.55 

 0.91 

 0.23 

—

 0.43 

—
 0.21 

—

 0.87 

—

 0.84 

 0.84 

—

 0.34 

 1.57 

 1.91 

 0.84 
—

 0.41 

—

 0.47 

—

—

 1.72 

 0.43 

 0.24 

 0.67 

 0.11 

 0.82 

 0.93 

 0.70 

—
 0.70 

 10.14 
7.83

Total 
2020 
%

 1.36 

 5.26 

 4.98 

 11.60 

 3.11 

 1.01 

 5.17 

 9.29 

 4.18 

 4.49 

 2.88 

 1.66 

 4.52 

 1.37 

 2.95 

Total 
2020 
£000

Total 
2019 
%

Total 
2019 
£000

 11,079 

 42,711 

 40,479 

 94,269 

 25,311 

 8,168 

 42,010 

 75,489 

 33,928 

 36,432 

 23,434 

 13,448 

 36,706 

 11,104 

 23,916 

 7.46 

 61,340 

—

 2.21 

 9.67 

 2.16 

 1.02 

 3.24 

 6.42 

 4.13 

 6.34 

 1.53 

 2.94 

 4.87 

 1.11 

 2.29 

—

 18,114 

 79,454 

 17,732 

 8,419 

 26,656 

 52,807 

 33,971 

 52,140 

 12,525 

 24,158 

39,990 

 9,089 

 18,778 

 22.05 

 178,968 

 23.21 

 190,651 

 2.22 

 0.74 

 0.43 

 1.49 
 0.75 

 0.58 

 6.21 

 0.87 

 4.31 

 5.18 

 3.23 

 2.68 

 2.96 

 8.87 

 6.35 
 4.70 

 6.17 

 4.09 

 2.85 

 3.43 

 0.91 

 18,032 

 6,016 

 3,507 

 12,116 
 6,132 

 4,739 

 50,542 

 7,097 

 34,950 

 42,047 

 26,228 

 21,740 

 24,084 

 72,052 

 51,586 
 38,213 

 50,102 

 33,207 

 23,204 

 27,809 

 7,400 

 1.82 

 0.31 

 0.43 

 1.70 
—

 0.98 

5.24

 1.05 

 7.79 

 8.84 

 1.88 

 3.30 

 4.97 

 10.15 

 6.18 
 4.13 

 3.40 

 1.69 

 3.97 

 5.64 

 3.93 

 14,910 

 2,534 

 3,499 

 13,952 
—

 8,079 

42,974

 8,608 

64,098 

 72,706 

 15,462 

 27,105 

40,946 

 83,513 

50,890 

 33,916 

28,048 

 13,916 

32,633 

 46,442 

 32,315 

 28.50 

 231,521 

 28.94 

238,160 

 0.43 

 1.13 

 1.56 

 0.60 

 1.34 

 1.94 

 1.72 

 3.08 
 4.80 

 3,502 

 9,184 

 12,686 

 4,852 

 10,887 

 15,739 

 13,959 

 25,025 
 38,984 

 812,297 
—

 1.66 

 0.78 

 2.44 

—

 1.13 

 1.13 

 0.70 
 3.26 

 3.96 

 13,676 

 6,450 

 20,126 

—

 9,325 

 9,325 

 5,825 
 26,775 

32,600 

 100.00 

662,593

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

 1.15 

—

—

—
—

—

 1.15 

—

—

—

—

—

—

—

—
 0.87 

—

—

—

 0.45 

—

 1.32 

—

—

—

—

—

—

—

—
—

 2.47 
3.12

 100.00 
—

The above table excludes bank balances and short-term deposits

Photo credit: Charles Hosea

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27

 
S T R A T E G I C   R E P O R T

Investment portfolio valuation 

based on market values as at 31 December 2020

Holding name

Ceres Power

GlaxoSmithKline

Rio Tinto

Herald Investment Trust

Royal Dutch Shell

BP

Prudential Corp

National Grid

Morgan Advanced Materials

HSBC

ITM Power

Severn Trent

Accsys Technologies

Aviva

Anglo American

RELX

BHP

DS Smith

Royal Mail

Direct Line Insurance

Land Securities

Dunelm

Hipgnosis Songs Fund

M&G

Rolls Royce

Hill & Smith

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

NatWest

Hiscox

BAE Systems

Standard Chartered

IP Group

Urban Logistics REIT

AFC Energy

Standard Life Aberdeen

Mondi

Caterpillar

Johnson Service Group

Cummins

Lloyds Banking Group

Senior

Croda

Balfour Beatty

St Modwen Properties

28

lawdebenture.com  

UK

UK

UK

UK

UK

UK

UK

UK

UK

USA

UK

USA

UK

UK

UK

UK

UK

Location

Sector

Industry

£000

Oil equipment services and distribution

24,197

Pharmaceuticals and biotechnology

Basic Materials

Mining

Oil and gas

Health Care

Financials

Oil and gas

Oil and gas

Financials

Utilities

Industrials

Financials

Oil and gas

Utilities

Industrials

Financials

Equity investment instruments

Oil and gas producers

Oil and gas producers

Life insurance/assurance

Gas, water and multiutilities

Electronic and electrical equipment

Banks

Gas, water and multiutilities

Construction and materials

Life insurance/assurance

Oil equipment services and distribution

11,488

Basic Materials

Mining

Consumer Services

Media

Basic Materials

Mining

Industrials

Industrials

Financials

Financials

General industrials

Industrial transportation

Nonlife insurance

Real estate investment trusts

Consumer Services

General retailers

Financials

Financials

Industrials

Industrials

Equity investment instruments

Financial services

Aerospace and defence

Industrial engineering

Financials

Financials

Industrials

Financials

Financials

Financials

Oil and gas

Financials

Banks

Nonlife insurance

Aerospace and defence

Banks

Financial services

Real estate investment trusts

Alternative Energy

Financial services

Basic Materials

Forestry and paper

Industrials

Industrials

Industrials

Financials

Industrials

Industrial engineering

Support services

Industrial engineering

Banks

Aerospace and defence

Basic Materials

Chemicals

Industrials

Financials

Construction and materials

Real estate investments and services

7,400

22,478

20,512

17,505

15,743

14,524

12,581

12,189

11,974

11,881

11,440

11,131

11,008

10,910

10,755

10,588

10,548

10,466

10,368

10,254

10,068

10,035

9,898

9,401

9,372

9,297

9,213

8,991

8,798

8,784

8,765

8,730

8,580

8,457

8,168

7,982

7,953

7,801

7,652

7,576

7,561

7,469

%

2.99

2.77

2.53

2.16

1.94

1.79

1.55

1.50

1.47

1.46

1.41

1.41

1.37

1.36

1.34

1.32

1.30

1.30

1.29

1.28

1.26

1.24

1.24

1.22

1.16

1.15

1.14

1.13

1 . 1 1

1.08

1.08

1.08

1.07

1.06

1.04

1.01

0.98

0.98

0.96

0.94

0.93

0.93

0.92

0.91

Toyota Motor Corporation

Japan

Consumer Goods

Automobiles and parts

Investment portfolio valuation continued 

based on market values as at 31 December 2020

Holding name

Barclays

Applied Materials

Smith & Nephew

Location

Sector 

UK

USA

UK

Financials

Technology

Health Care

Industry

Banks

Technology hardware and equipment

Health care equipment and services

Scottish Oriental Smaller Cos

Pacific

Financials

Equity investment instruments

Marks & Spencer

UK

Consumer Services

General retailers

Irish Continental Group

Ireland

Consumer Services

Travel and leisure

USA

Consumer Goods

Automobiles and parts

Consumer Goods

Household goods and home construction

6,815

Financials

Financial services

Basic Materials

Chemicals

Industrials

Construction and materials

Germany

Basic Materials

Chemicals

UK

UK

UK

UK

Ireland

Ireland

USA

Financials

Life insurance/assurance

Consumer Goods

Food and Drug Retailers

Industrials

Electronic and electrical equipment

Consumer Services

Media

Consumer Services

Travel and leisure

Utilities

Electricity

Health Care

Pharmaceuticals and biotechnology

International Consolidated Airlines UK

Consumer Services

Travel and leisure

Canada

Oil and gas

Oil and gas producers

Industrials

Electronic and electrical equipment

Consumer Goods

Household goods and home construction

5,301

General Motors

Watkin Jones

Provident Financial

Elementis

Marshalls

Linde

Chesnara

Tesco

Spectris

Euromoney

Ryanair

EQTEC

Bristol-Myers Squibb

Gibson Energy

TT Electronics

Taylor Wimpey

Hammerson

IMI

Ibstock

Halfords

British American Tobacco

SigmaRoc

Meggitt

Boku

SSE

Studio Retail Group

Unilever

Vodafone

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

UK

Financials

Industrials

Industrials

Real estate investment trusts

Industrial engineering

Construction and materials

Consumer Services

General retailers

Consumer Goods

Tobacco

Industrials

Industrials

Industrials

Utilities

Construction and materials

Aerospace and defence

Support services

Electricity

Consumer Services

General retailers

Consumer Goods

Personal goods

Telecommunications

Mobile telecommunications

Koninklijke DSM

Netherlands

Basic Materials

Chemicals

Oxford Sciences Innovation

UKULM

Financials

Financial services

Weir Group

BT Group

UK

UK

Industrials

Industrial engineering

Telecommunications

Fixed Line Telecommunications

Muenchener Rueckver

Germany

Financials

Nonlife insurance

SIMEC Atlantis Energy

International Personal Finance

UK

UK

Utilities

Financials

Electricity

Financial services

BAWAG

Austria

Financials

Banks

Grit Real Estate Income Group

Other

Financials

Real estate investment trusts

£000

7,261

7,253

7,097

7,077

6,951

6,949

6,849

6,780

6,732

6,728

6,627

6,115

6,016

5,988

5,891

5,807

5,667

5,666

5,493

5,491

5,472

5,201

5,097

4,951

4,806

4,739

4,729

4,665

4,571

4,499

4,402

4,392

4,233

4,193

4,077

3,979

3,968

3,845

3,794

3,790

3,670

3,624

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%

0.89

0.89

0.87

0.87

0.86

0.86

0.84

0.84

0.83

0.83

0.83

0.82

0.75

0.74

0.74

0.73

0.71

0.70

0.70

0.68

0.68

0.67

0.65

0.64

0.63

0.61

0.59

0.58

0.58

0.57

0.56

0.55

0.54

0.54

0.52

0.52

0.50

0.49

0.49

0.47

0.47

0.47

0.45

0.45

29

 
S T R A T E G I C   R E P O R T

Investment portfolio valuation continued 

based on market values as at 31 December 2020

Holding name

Location

Sector

Industry

Foresight Solar Fund

Telecom Italia RSP

UK

Italy

Financials

Equity investment instruments

Telecommunications

Mobile telecommunications

Nestle

Switzerland

Consumer Goods

Food producers

Phoenix Group Holdings

UK

Financials

Life insurance/assurance

Prosus

Babcock

Indus Gas

UniCredit

Redde Northgate

Cellnex Telecom

Carnival

Roche

Schlumberger

Allied Minds

SIG Combibloc

Vivendi

Marstons

Worldline

Amundi

Ilika

Mirriad Advertising

Novo Nordisk

Augean

Total 

ASML

Faurecia

Nexi

Morses Club

CNH Industrial

Moncler

Ricardo

Velocys

Grifols

Kier

Centrica

Netherlands

Technology

Software and computer services

UK

UK

Italy

UK

Spain

UK

Industrials

Oil and gas

Financials

Industrials

Aerospace and defence

Oil and gas producers

Banks

Support services

Telecommunications

Mobile telecommunications

Consumer Services

Travel and leisure

Switzerland

Health Care

Pharmaceuticals and biotechnology

USA

UK

Oil and gas

Financials

Financial services

Oil equipment services and distribution

3,048

Switzerland

Industrials

General industrials

France

Consumer Services

Media

UK

France

France

UK

UK

Consumer Services

Travel and leisure

Industrials

Financials

Oil and gas

Support services

Financial services

Alternative Energy

Consumer Services

Media

Denmark

Health Care

Pharmaceuticals and biotechnology

UK

Industrials

Support services

France

Oil and gas

Oil and gas producers

Netherlands

Technology

Technology hardware and equipment

France

Consumer Goods

Automobiles and parts

Italy

UK

UK

Italy

UK

UK

Industrials

Financials

Industrials

Support services

Financial services

Industrial engineering

Consumer Goods

Personal goods

Industrials

Oil and gas

Support services

Oil equipment services and distribution

Spain

Health Care

Pharmaceuticals and biotechnology

UK

UK

Industrials

Utilities

Construction and materials

Gas, water and multiutilities

Koninklijke KPN

Netherlands

Telecommunications

Fixed Line Telecommunications

Brockhaus Capital Management

Germany

Financials

Financial services

Premier Oil

Renold

Logistics Development Group

Tullow Oil

LDIC Investments

Carclo

Providence Resources

UK

UK

UK

UK

UK

UK

UK

Oil and gas

Industrials

Industrials

Oil and gas

Other

Oil and gas producers

Industrial engineering

Industrial transportation

Oil and gas producers

Other

Basic Materials

Chemicals

Oil and gas

Oil and gas producers

30

lawdebenture.com  

£000

3,570

3,559

3,507

3,503

3,502

3,488

3,346

3,122

3,105

3,095

3,076

3,064

3,006

2,900

2,765

2,759

2,612

2,579

2,499

2,328

2,294

2,137

2,124

1,931

1,886

1,828

1,795

1,742

1,740

1,710

1,679

1,447

1,425

1,396

884

743

736

734

639

591

213

198

156

%

0.44

0.44

0.43

0.43

0.43

0.43

0.41

0.38

0.38

0.38

0.38

0.38

0.38

0.37

0.36

0.34

0.34

0.32

0.32

0.31

0.29

0.28

0.26

0.26

0.24

0.23

0.23

0.22

0.21

0.21

0.21

0.21

0.18

0.18

0.17

0 . 1 1

0.09

0.09

0.09

0.08

0.07

0.03

0.02

0.02

Investment portfolio valuation continued 

based on market values as at 31 December 2020

Holding name

DistributionNOW

Better Capital (2012)

Location

Sector

Industry

USA

UK

Oil and gas

Financials

Oil equipment services and distribution

Equity investment instruments

Permanent TSB

Ireland

Financials

Banks

£000

66

25

3

%

0.01

0

0

812,297 

100.00 

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Changes in geographical distribution

Valuation 
31 December 
2019  
£000

 664,021 

 68,182 

 64,409 

 8,693 

 7,237 

 9,774 

 822,316 

Purchases 
£000

129,219

3,513

39,921

—

—

 1,178 

173,831

United Kingdom

North America

Europe

Japan

Other Pacific

Other

* Please refer to note 2 on page 102.

Costs of  
acquisition 
£000

Sales  
proceeds 
£000

Appreciation/ 
(depreciation)* 
£000

Valuation 
31 December 
2020 
£000

(98,200)

(28,706)

 665,800 

(534)

(2)

(52)

—

—

—

(33,771)

(33,574)

—

—

(1,363)

(588)

(166,908)

6,234

11,639

604 

(160)

(5,965)

(16,354)

 44,156 

 82,343 

 9,297 

 7,077 

 3,624 

%

82.1

5.4

10.1

1.1

0.9

0.4

 812,297 

100.0

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Company overview

Who we are

From its origins in 1889, Law Debenture has diversified to become a Group with a unique range of activities in the financial and 

professional services sectors. Law Debenture is an investment trust with two distinct lines of business: an investment portfolio and a 

leading provider of independent professional services. 

Law Debenture shares are intended for private investors in the UK (retail investors), professionally advised private clients and institutional 

investors. When choosing an investment trust, shareholders typically accept the risk of exposure to equities but hope that the pooled 

nature of an investment trust portfolio will give some protection from the volatility in share price movements that can sometimes affect 

individual equities.

Our objective

Our objective for the investment trust is to achieve long-term capital growth in real terms and steadily increasing income. The aim is 

to achieve a higher rate of total return than the FTSE Actuaries All-Share Index through investing in a diversified portfolio of stocks and 

ownership of the IPS business.

Our business model

Our business model is designed to position the Company to the best advantage in the investment trust sector. 

Investment Portfolio  
(c. 83% of NAV)

Independent Professional Services 
(c. 17% of NAV)

The Company’s portfolio will typically contain between 70 and 150 

Operating through wholly owned subsidiary companies, all 

listed investments. The portfolio is diversified in order to spread 

of which are listed at note 14 to the accounts, we provide 

investment risk with no obligation to hold shares in any particular 

pension trustee executives, outsourced pension services, 

type of company, industry or geographical location. The IPS 

corporate trust services and corporate services to companies, 

business does not form part of the investment portfolio.

agencies, organisations and individuals throughout the world. 

Whilst performance is measured against local and UK indices, the 

composition of these indices does not influence the construction 

of the portfolio. As a consequence, it is expected that the 

The services are provided through offices in the UK, Dublin, 

New York, Delaware, Hong Kong, the Channel Islands and the 

Cayman Islands.

Company’s investment portfolio and performance will deviate from 

Group employees are employed by L.D.C. Trust Management 

the comparator indices.

Limited and Safecall Limited (in the UK) or a locally incorporated 

entity (in the overseas jurisdictions). As part of their duties, a 

number of the employees provide services to the investment 

trust and their time is charged to the trust, forming a part of the 

ongoing charges.

More details about the performance of the IPS business in 

2020 are given in the Chief Executive Officer’s review on pages 

10 to 16.

Our unique structure allows our investment managers to focus on capital 

generation, while knowing that historically approximately one-third of 

the Trust’s income has been provided by the IPS business.

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Total Shareholder Return

Investment Portfolio

Independent Professional Services

• 

Invests in a diverse equity portfolio

•  T rusted, professional,  

•  Earns capital returns and dividends

•  Low ongoing charges

independent, third party

•  Generates re-occuring fees

•  Cost base kept under control

• 

 Profits give a dividend stream 

which increases the ability for 
the Group to pay dividends 

to shareholders

•  Tax efficient

Our strategy – implementation

We aim to deliver the investment trust’s objective by skilled 

implementation of the investment strategy, complemented 

by maintaining and operating our IPS business profitably and 

safely, while keeping it distinct from the portfolio. The operational 

independence of the IPS business means that it can act flexibly 

and commercially. It provides a regular flow of dividend income 

to the Company. This helps the Board to smooth out equity 

dividend peaks and troughs, means that the investment manager 

does not have to be constrained by choosing stocks just for 

United Kingdom

North America

Europe

Japan

Other Pacific

Other

Minimum 
%

Maximum 
%

55

0

0

0

0

0

100

20

10

10

10

10

yield and is an important element in delivering the objective of 

Liquidity and long-term borrowings are managed with the aim 

steadily increasing income for shareholders. In turn, some of the 

of improving returns to shareholders. The policy on gearing is to 

tax relief at the investment trust level arising from our debenture 

adopt a level of gearing that balances risk with the objective of 

interest and excess costs, which would otherwise be unutilised, 

increasing the return to shareholders, in pursuit of its investment 

can be transferred to the IPS business, thus reducing the overall 

objective. More information on gearing can be found on 

tax liability of the Group. 

The way in which we implemented the investment strategy 

during 2020 is described in more detail in the CEO’s review on 

pages 12 to 16 and the investment managers’ review on pages 

18 to 22.

Performance against KPIs is set out at pages 3 to 31, which contain 

comprehensive tables, charts and data to explain performance 

both over the year under review and over the long-term.

Our strategy – guidelines

There are some guidelines, set by the Board, on maximum or 

minimum stakes in particular regions and all stakes are monitored 

page 34. Investments may be held in, inter alia, equity shares, 

collective investment products including open ended investment 

companies (OEICs), fixed interest securities, interests in limited 

liability partnerships, cash and liquid assets. Derivatives may 

be used but only with the prior authorisation of the Board. It is 

permissible to hedge against currency movements on both the 

capital and income account, and to lend stocks up to 30% of the 

NAV, subject again to prior authorisation of the Board. Trading 

in suspended shares and short positions are not permitted. No 

more than 15% of gross assets will be invested in other UK listed 

investment trusts. During 2020, the Board took the decision to 

remove the cap on UK investments given our AIC classification 

in the UK Equities Sector. However, the Company’s investment 

activities are subject to the following limitations and restrictions:

in detail by the Board at every scheduled Board meeting in order 

• 

 No investment may be made which raises the aggregate value 

to ensure that sufficient diversification is maintained.

of the largest 20 holdings, excluding investments in collective 

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Company overview continued

investment vehicles that give exposure to the Japan, Asia/

administration. Law Debenture’s latest published level of ongoing 

Pacific or emerging market regions, to more than 40% of the 

charges shown on page 3 is one of the lowest in the marketplace. 

Company’s portfolio, including gilts and cash. 

No performance fees are paid to the investment manager.

• 

 The value of a new acquisition in any one company may not 

exceed 5% of total portfolio value (including cash) at the time 

the investment is made. Further additions shall not cause a 

single holding to exceed 5%, and Board approval must be 

sought to retain a holding, should its value increase above the 

5% limit (that approval to be sought at the next Board meeting). 

• 

 The Company applies a ceiling on effective gearing of 50%. 

While effective gearing will be employed in a typical range 

of 10% net cash to 20% gearing, the Board retains the ability 

to reduce equity exposure so that net cash is above 10% if 

deemed appropriate.

• 

  The Company may not make investments in respect of which 

there is unlimited liability.

Fee structure and ongoing charges

Our portfolio of investments is managed under delegation by 

James Henderson and Laura Foll of Janus Henderson Investors 

(Janus Henderson) under a contract terminable by either side 

on six months’ notice. On a fully discretionary basis, Janus 

Henderson is responsible for implementing the Company’s 

investment strategy and fees are charged at 0.30% of the value 

Capital structure – simple and mainstream

Law Debenture’s capital structure is transparent. We have only 

one class of share – ordinary shares – and each share has the same 

rights as every other share.

The Company conducts its affairs so that its ordinary shares are 

capable of being recommended by independent financial advisors 

to retail investors in accordance with relevant FCA rules.

Our ordinary shares are, we consider, mainstream investment 

products because they are shares in an investment trust. The 

Company intends to continue conducting its affairs for the 

foreseeable future so that the ordinary shares can continue to be 
categorised as a mainstream investment.

Transparency 

In order to assist shareholders to understand the nature of the 

underlying investments they are buying into when investing in Law 

Debenture shares, we publish our entire portfolio monthly – with 

additional monthly updates on the composition of the top ten 

holdings in the portfolio. During the course of 2020, we also began 

publishing a daily NAV.

of the net assets of the Group (excluding 

the net assets of IPS), calculated on the 

basis adopted in the audited financial 

statements. This means that the Company 

continues to maintain one of the 

most competitive fee structures in the 

investment trust sector. This, combined 

with the strong performance of Janus 

Henderson over the years as our investment 

manager, has led the Board to conclude 

that the continuing appointment of Janus 

Henderson as the Company’s investment 

manager remains in the best interests of 

shareholders. Equity investment needs to 

be considered over the longer term and 

Janus Henderson has delivered positive 

returns over many years.

The agreement with Janus Henderson 

does not cover custody which is the 

responsibility of the depositary (see section 

on regulatory compliance in the Directors’ 

Law Debenture’s 

latest published level 

of ongoing charges 

is one of the lowest 

in the marketplace at 

0.55%. No performance 

fees are paid to the 

Gearing

Investment trusts have the benefit of being 

able to ‘gear’ their portfolios according to 

market conditions. This means that they 

can raise debt (either short or long-term) 

to generate funds for further investment.

These funds can be used to increase the 

size of the portfolio, or assets from within 

the portfolio can be sold to reduce debt 

and even be ‘negatively geared’. This means 

selling assets to hold cash so that less than 

100% of the Company’s assets are invested 

in equities. At 31 December 2020, our 
gearing was 9% (2019: 5% restated†).

investment manager.

There has been no change in the 

Company’s gearing policy, with effective 

gearing typically employed in a range of 

10% net cash to 20% gearing. 

report, page 53). Nor does it cover the preparation of data 

associated with investment performance, or record keeping, both 

of which are maintained by the Company. 

Borrowings

Investment trusts are required to publish their ongoing charges. 

The Company has two debentures (long dated sterling 

This is the cost of operating the trust and includes the investment 

denominated financing) details of which are at page 120. The 

management fee, depositary and custody fees, investment 

weighted average interest payable on the Company’s structural 

performance data, accounting, company secretary and back office 

borrowings is 4.589% (2019: 4.589%).

† Please refer to gearing/(net cash) note on page 128.

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Company overview continued

Breakdown of employees by sex

NAV total return with debt at Fair Value

We report that at the 2020 year end:

• 

• 

 two Directors of the Company were female (2019: two);

 50% of the senior managers of the Group were female (2019: 

31%) (senior manager being any individual with responsibility 

for planning, directing or controlling an activity of one of 

the subsidiary companies or a key central business function, 

excluding the CEO and the COO); and 

• 

 50% (2019: 50%) of the Group employees were female.

Future trends and factors

1 year

3.6%

3 years

15.6%

5 years

59.1%

10 years

147.8%

Premium/(discount)

Year end

High for year

Low for year

31 December 2020

31 December 2019

3.6%

6.6%

(19.0)%

(7.4)%

(4.8)%

(11.6)%

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Law Debenture will continue to strive to deliver its business 

objectives for both the investment trust and the IPS business. 

Ongoing expenses ratio

The Chairman’s statement, the investment managers’ 

review and the CEO’s review (all of which form part of this 

strategic report) respectively set out the Company’s views on 

future developments.

Brexit

During the course of 2020, the UK went through the transition 

period and came to a trade deal for good with the EU. The Board 

continues to believe that the UK’s decision to leave the EU does 

not present a threat to the Group’s business model, the viability 

statement, or its ability to continue producing accounts on a going 

concern basis.

Performance and related data

Pages 3, 13 and 18 to 22, which contain performance and related 

data, form a part of this strategic report. 

Key performance indicators (KPIs) and 
alternative performance measures

Year ended 31 December 2020

Year ended 31 December 2019

0.55%

0.48%

Alternative Performance Measures as defined under ESMA 

guidelines have been adopted and these are described in detail on 

page 128.

Share price and NAV

Investment trusts can trade at a discount (where the share price 

is lower than the combined value (NAV) of the underlying assets), 

or at a premium (where the share price trades at a higher level 

than the underlying NAV). Investment trust investors need to 

understand these concepts as well as examine the underlying 

portfolio and the way in which it is managed, to decide whether or 

not an investment trust share represents “good value”. 

Law Debenture’s responsibilities  
as an institutional shareholder

The Company recognises that in delivering its objective to produce 

long-term capital growth and a steadily increasing income, it must 

The KPIs used to measure the progress and performance of the 

ensure that its investment strategy is delivered with due emphasis 

Group are:

• 

• 

• 

 NAV total return per share (combining the capital and income 

returns of the Group) and how this compares, over various time 

intervals, with relevant indices;

 the discount/premium in share price to NAV; and

on the need to ensure that investee companies are acting in 

accordance with accepted standards of corporate governance. The 

Company has therefore adopted the following policy.

Law Debenture will normally support incumbent management 

and vote in favour of resolutions proposed by the boards of 

companies in which it has a shareholding, but will vote against 

 the cost of running the portfolio as a percentage of its value.

management or withhold a vote where appropriate.

Since the objective of the investment trust is measurable solely in 

financial terms, the Board does not consider that it is appropriate 

to adopt non-financial KPIs. The financial measures adopted as 

KPIs are part of our financial reporting obligations. 

The Board determines the Company’s investment strategy but 

does not issue express instructions to the investment manager on 

transactions in particular shares. Where Law Debenture believes 

that incumbent management is failing in its duties, Law Debenture 

(or on its behalf, the Company’s investment manager) may attempt 

to enter into dialogue with the company concerned in an attempt 

to alter the management’s position.

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Company overview continued

Where this is not possible, or where incumbent management 

number is reached by taking the return, including profit attribution 

declines to alter its behaviour, Law Debenture will consider voting 

on ordinary activities before interest and taxation of £12.2m from 

against resolutions proposed by the management. Further, if it 

note 7 on page 105 and adding back the depreciation charge for 

is deemed necessary or desirable, the Company would consider 

property plant and equipment of £1.2m and the amortisation of 

acting collectively with other institutional investors to try and 

intangible assets of £59,000 shown in note 3 on page 103.

achieve a particular goal.

The calculation of the IPS valuation and methodology used 

Janus Henderson, on Law Debenture’s behalf, monitors companies 

to derive it are included in the annual report at note 14. In 

in which Law Debenture is invested, and from time to time may 

determining a calculated basis for the fair valuation of the IPS 

discuss matters of corporate responsibility with such companies. 

business, the Board has taken appropriate external professional 

The Janus Henderson corporate governance unit will notify Law 

advice. The multiple applied in valuing the IPS business is based 

Debenture’s investment managers, who in turn may notify Law 

on comparable companies sourced from market data, with 

Debenture, should matters arise that might lead the Company 

appropriate adjustments to reflect the difference between the 

to consider intervening, abstaining or voting against a particular 

comparable companies and IPS business in respect of size, 

proposal. During the year, the Company abstained or voted 

liquidity, margin and growth. A range of multiples is then provided 

against one or more resolutions at 30 shareholder meetings of 

by the professional valuation firm, from which the Board selects 

investee companies.

The Company will not hold shares in companies whose ethical 

and environmental practices are in its view likely to damage the 

performance of the business to the detriment of its shareholders.

The Company does not believe that conflicts arise between 

its duties as an institutional shareholder and the IPS work 

undertaken by the IPS business. The investment manager has 

complete discretion as to portfolio decisions and as a matter of 

policy, has no access to ‘non-public’ knowledge about any of the 

activities of the IPS business.

Janus Henderson remains a signatory to the 2012 UK Stewardship 

Code and intends to sign up to the 2020 UK Stewardship Code. 

As the Company’s investment manager, Janus Henderson makes 

the day-to-day investment decisions and is therefore best placed 

an appropriate multiple to apply. The multiple selected for the 

current year is 9.4x, which represents a discount of almost 30% on 

the mean multiple across the comparable businesses, to reflect the 

relative size of the IPS business and the fact that it is unlisted. 

The comparable companies used, and their recent performance, 

is presented in the table below:

Company

Law Deb IPS

Intertrust N.V.

Sanne Group plc

Revenue  
LTM 1 
(£m)

LTM EV/
EBITDA  
31 Dec 
2020

Revenue 
CAGR 
2016-2020

EBITDA 
margin 
LTM

35

518

170

9.4x

11.2x

7%

44%

12%

33%

19.6x

28%

29%

to engage with portfolio companies and discharge stewardship 

SEI Investments Company

1,286

15.1x

3%

28%

obligations. The Board is of the view that becoming a signatory to 

the Stewardship Code would unnecessarily duplicate the work of 

the investment manager and therefore continues to rely on Janus 

Henderson in this regard.

Valuation of our IPS business

Accounting standards require us to consolidate the income, costs 

1  LTM refers to the trailing 12 months ‘results’ which are publicly available.

Source: Capital IQ.

Valuation guidelines require that the fair value of the IPS business 

be established on a stand-alone basis. Therefore, the valuation 

does not reflect the value of Group tax relief applied from the 

investment trust to the IPS business, which reduced the tax charge 
by £1,549,000 (2019: £1,120,000). It is hoped that our initiatives to 

and taxation of our IPS business into the Group income statement 

inject growth into the IPS business will result in a corresponding 

on page 92. The assets and liabilities of the business are also 

increase in valuation over time. As stated above, management is 

consolidated into the Group column of the statement of financial 

aiming to achieve mid to high single digit growth in 2020. The 

position on page 93. A segmental analysis is provided in note 7 

valuation of the business has increased by £44.9m/49.6% since the 

(page 105) to these accounts which shows a detailed breakdown 

first valuation of the business as at 31 December 2015.

of the split between the investment portfolio, IPS business and 

Group charges.

In order to assist investors, the Company restated its historical 

NAV in 2015 to include the fair value of the IPS business for the last 

Consolidating the value of the IPS business in this way failed 

ten years. This information is provided in the annual report within 

to recognise the value created for the shareholder by the IPS 

the 10-year record on page 38.

business. To address this, from December 2015, the NAV we 

have published for the Group has included a fair value for the 

standalone IPS business. 

Long-term borrowing

The current fair value of the IPS business is calculated based upon 

historical earnings before interest, taxation, depreciation and 

amortisation (EBITDA) for 2020, with an appropriate multiple 

applied. The EBITDA for the IPS business for 2020 was £13.3m. This 

The fair value of long-term borrowings held by the Group is 

disclosed in note 21 to the accounts. The methodology of fair 

valuing all long-term borrowings is to benchmark the Group debt 

against A rated UK corporate bond yields. 

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Calculation of net asset value (NAV) per share

Calculation of NAV per share

The table below shows how the NAV at fair value is calculated. The value of assets already included within the NAV per the Group statement 

of financial position that relate to the IPS business are removed (£23.5m) and substituted with the calculation of the fair value and surplus net 

assets of the business (£136m). An adjustment of £52.2m is then made to show the Group’s debt at fair value, rather than the book cost that 

is included in the NAV per the Group statement of financial position. This calculation shows a NAV fair value for the Group as at 31 December 

2020 of £787.2m or 666.15 pence per share:

Net asset value (NAV) per Group statement of financial position

Fair valuation of IPS: EBITDA at a multiple of 9.4x (2019: 9.2x)

Surplus net assets

Fair value of IPS business

Removal of assets already included in NAV per financial statements

Fair value uplift for IPS business

Debt fair value adjustment

NAV at fair value

31 December 2020

31 December 2019

£000 Pence per share

£000 Pence per share

726,994 

125,349 

10,605 

135,954 

(23,547)

112,407 

(52,182)

787,219 

615.19 

106.07 

8.97 

115.05 

(19.93)

95.12 

(44.16)

666.15 

 775,272 

 105,938 

 16,367 

 122,305 

(30,445) 

 91,860 

(36,992) 

 830,139 

655.76

89.61

13.84

103.45

(25.75)

77.70

(31.29)

702.17

Photo credit: Harry Evans

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Long-term performance record

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Net assets (£m)1

412.6

390.9

451.9

569.1

574.2

557.3

662.3

748.3

669.4

775.3

727.0

Revenue return (pence)

13.26

15.52

15.14

Capital return (pence)

58.22

(19.07)

50.24

16.27

97.18

16.95

18.10

15.96

21.66

21.26

30.68

21.56 

3.87

(17.47)

89.30

67.10

(71.85)

79.27

(19.06)

Total (pence)

71.48

(3.55)

65.38

113.45

20.82

0.63

105.26

88.76

(50.59)

109.95

2.50

Revenue return (pence)

Investment trust

Independent professional 

services

7.07

6.19

8.27

7.25

8.47

6.67

9.31

10.08

6.96

6.87

11.01

7.09

10.88

7.68

11.61

9.93*

13.23

7.87

22.18

8.54

Group charges2

—

—

—

—

—

—

(2.60)

0.12

0.16

(0.04)

13.26

15.52

15.14

16.27

16.95

18.10

18.56

21.54

21.10

30.72

13.26

15.52

15.14

16.27

16.95

18.10

15.96

21.66

21.26

30.68

12.12

9.35

0.09

21.56

21.56

Dividends (pence)

12.70

13.50

14.25

15.00

15.70

16.20

16.70

17.30

18.90

26.00

27.50

Share price (pence)1

356.6

333.5

425.0

529.0

530.0

498.0

530.0

629.0

540.0

650.0

690.0 

(Discount)/premium (%)1

NAV at fair value (pence)1

(10.5)

398.5

(13.4)

385.1

0.1

(2.4)

(2.3)

(5.1)

(11.4)

(6.0)

424.7

541.8

542.3

524.5

598.5

669.5

(12.1)

614.1

(7.4)

3.6 

702.2

666.2 

Market capitalisation (£m)1

418.6

393.8

501.9

625.0

627.1

589.3

627.2

744.5

639.3

769.8

817.3 

1   At 31 December calculated in accordance with AIC methodology, based on performance data held by Law Debenture including fair value of IPS business and long-term borrowings.

2   For details see note 7 to the accounts.

*This includes 2.72 pence per share of exceptional items including the sale of an unlisted investment, excluding which, normalised earnings per share were 7.21 pence per share.

Note: The 10 year record has been restated (2010-2014) to reflect the fair value of the IPS business and the long-term borrowings.

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Risk management

Principal risks and internal controls 
– overview

2021. This will further enhance the governance and oversight 

of the management of the principal risks (detailed below). An 

update on this refresh will be made in next year’s annual report.  

The Group’s risk management and internal control framework 

is embedded in our operations and subject to continuous 

enhancements. Board-level oversight is provided by our Audit and 

Presentation of Group risks 

Risk Committee. Our Executive Risk Committee has responsibility 

The key risks for Law Debenture are referred to as principal risks; 

for the oversight of the management of operational risk within 

they broadly relate to market, credit, liquidity and operational 

the Group. The framework enables the Board to identify, evaluate 

risks and are split into three categories:

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and manage principal risks to support our delivery of long-term 

priorities. The Board recognises that there are certain risks which 

are inherent in our business structure, such as market risk with 

respect to its investment portfolio and the controls to mitigate 

against such risks are paramount to the delivery of our objectives. 

On an annual basis, the Audit and Risk Committee consider the 

risks to the Group and the adequacy of the controls in place to 

appropriately manage those risks. Consideration is also given to 

emerging risks to ensure that the risk management framework 

is updated to protect the business. Where there is insufficient 

information on the potential risk, ongoing monitoring is put 

in place. 

During 2020, the General Counsel oversaw the roll out of a policy 

review for key Group-wide risks and procedures. This included an 

updated approach to the management of incident reporting up 

to the Executive Risk Committee level and to the Audit and Risk 

Committee, if necessary. This was supported by an enhanced all 

1.  Group Risks.

2.  Investment Portfolio Risks.

3.  IPS Risks. 

The principal risks for the Group are presented below together 

with their corresponding controls and mitigating actions. In 

line with FRC guidance issued in October 2020, Law Debenture 

have identified where Covid-19 has materially impacted or has 

the potential to materially impact existing risks and has acted 

accordingly. This is outlined in the Covid-19 section on page 61. 

Governance 

staff risk and compliance training programme to build on the 

The Group’s risk management and internal control framework is 

existing learning and development programmes. In November 

managed through its governance structure shown in the diagram 

2020, the Chairman of the Audit and Risk Committee and the 

below. The IPS business risks are managed through business 

Executive Risk Committee both agreed a plan to refresh the 

unit risk committees and management meetings. The outputs 

Group’s risk management and internal audit framework during 

of these are fed through to the Executive Risk Committee. 

Executive Risk Committee

SOP

Pensions
(including 
Pegasus)

Corporate  
Trust

Corporate 
services

Safecall

Central 
Functions

– Business Unit Risk Committees (where appropriate)

– Business Unit Management Meetings

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The key focus of the Executive Risk Committee is:

• 

• 

• 

• 

 The review of high or out of appetite risks. 

 Internal controls and mitigating actions.

 Emerging risks.

 Escalations from Business Unit Risk Committees or Business Unit Management Meetings. 

Executive Risk Committee

Section

IPS Business Risks

Group Risks

Investment Portfolio Risks

–  High risk and out of appetite 

IPS risks

–  High risk and out of appetite 

business risks

–  Outstanding/ongoing mitigating 

Agenda

actions/controls

–  Testing schedule/results

– Emerging risks

–  Incidents/breaches

–  Escalations from business unit 
risk committees (e.g. Pensions)

Attendees

– Business Heads

–  Chief Financial Officer

–  Chief Operating Officer

–  Chief Technology Officer

– General Counsel

–  Heads of Overseas Offices

–  Head of Internal Audit

– MLRO

–  High risk and out of appetite 

–  High risk and out of appetite 

group risks

portfolio risks

–  Outstanding/ongoing mitigating 

–  Outstanding/ongoing mitigating 

actions/controls

actions/controls

–  Testing schedule/results

–  Testing schedule/results

– Emerging risks

–  Incidents/breaches

–  Third party suppliers

– Emerging risks

–  Incidents/breaches

–  Chief Financial Officer

–  Chief Operating Officer

–  Chief Financial Officer

–  Chief Technology Officer

–  Chief Operating Officer

– General Counsel

– General Counsel

–  Heads of Overseas Offices

–  Head of Internal Audit

–  Head of Internal Audit

– MLRO

Terms of Reference

The Executive Risk Committee escalates risk events to the Audit 

The governance framework is continually under review to ensure 

and Risk Committee, as appropriate. The General Counsel also 

that it is fit for purpose with annual reviews of the terms of 

speaks directly to the Chair of the Audit and Risk Committee on 

reference and oversight across the Group by the Chairs of the 

any matters arising as required.

Audit and Risk Committee and the Executive Risk Committee.

LDC plc Board

Audit and Risk Committee

Executive Risk Committee

Business Unit Risk Committees/Business Unit Management Meetings

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Risk management continued

Group risk summary and internal controls 

PRINCIPAL GROUP RISKS

MITIGATING ACTIVITIES

1.  Financial Reporting

The risk of inaccurate publication 

To mitigate these risks, the management and production of all financial reporting is 

of financial statements, annual 

overseen by appropriately skilled and trained colleagues within the Group’s Finance team, 

reports, NAV, factsheets and other 

with review from the CFO. 

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The valuation is calculated based on the reconciled data using a specialist third party for 

the pricing and the NAV is reported to the London Stock Exchange and Morningstar daily. 

Investment Data is reconciled to third party data held by the Custodian/Depositary and 

Janus Henderson as the investment manager. 

To mitigate these risks, the Board has various measures in place:

• 

 The investment limits and restrictions it has placed on the investment portfolio only 

permit investments in primarily equities and fixed interest securities quoted on major 

financial markets. Excess cash is held in money market funds with immediate access. 

There are also daily dealing limits in place for Janus Henderson and liquidity within the 

investment portfolio (and the Group as a whole) is closely monitored by the Finance 

team.

• 

• 

• 

 A refreshed liquidity policy has been reviewed by the CFO and a liquidity stress test is 

included in the Group Board papers on a quarterly basis. This furthers the Finance team’s 

and CFO’s monitoring of the Group’s liquidity position. 

 The Group is not permitted to retain more than 15% of its income from shares and 

securities each year. This is actively monitored by the Finance team and is also a key 

consideration as part of the discussions on the final annual dividend and interim 

dividends. 

 The Company has a stated objective to provide shareholders with a steadily increasing 

flow of income and this is considered when making any dividend decision. Distribution 

is reviewed by the Board quarterly.

market data that can adversely 

impact financial results, investor 

decisions, reputation or which 

may lead to regulatory fines 

or sanctions. 

2.  Liquidity and Dividend

The risk that the Group cannot meet 
its cash and collateral obligations 

at a reasonable cost. This is for both 

expected and unexpected cash 

flows, without adversely affecting 

daily operations or financial 

conditions. Liquidity risk can arise 

from cash flow mismatches, market 

constraints from the inability to 

convert assets to cash, the inability 

to raise cash in the markets or 

contingent liquidity events. It 

could also arise from the operating 

business of the IPS if, for example, its 

debtor position were to materially 

deteriorate or where, in extremis, the 

Group is required to use its capital to 

mitigate a material post issue event 

within IPS where we could be paid 

years after the event. 

Liquidity issues could result in the 

Group being required to sell stock 

that Janus Henderson has invested 
in at a sub-optimal time/price, not 

be able to maintain or increase the 

dividend (a publicly stated aim) or 

require additional borrowing.

3.  Foreign Currency

The risk arising from movements 

Cash positions are monitored daily by the Finance team. Where appropriate, funds are 

in currency rates applicable to the 

converted to our reporting currency.

investment portfolio’s investment 

in equities and the net assets of 

the Group’s overseas subsidiaries 

denominated in currencies other 

than sterling.

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Risk management continued

PRINCIPAL GROUP RISKS

MITIGATING ACTIVITIES

4.  Interest Rates

The risk arising from movements in 

To mitigate interest rate risks, the Board reviews the mix of fixed and floating rate 

interest rates on borrowing, deposits 

exposures and ensures that gearing levels are appropriate to the current and anticipated 

and short-term investments.

market environment. Cash positions are monitored daily by the finance team. Where 

possible, funds are moved into liquid funds with higher returns.

5.  Legal and Regulatory

The risk that the Group’s business 

To mitigate these risks, the following controls are in place:

will be negatively affected if we 

do not comply with the various 

laws and regulations the Group is 

required to, or if we are not able to 

anticipate and keep pace with rapid 

changes in laws or regulations, or 

if laws or regulations decrease the 
need for our services or increase 

our costs. 

• 

• 

• 

• 

6.  Third Party Suppliers

 A schedule of all Group legal, regulatory, compliance and reporting obligations 

to ensure all reporting and other requirements across the Group are tracked and 

complied with. 

 A GDPR review is also underway following the growth of the IPS business and 

changes to ways of working. 

 A review of regulatory permissions across the Group is ongoing. 

  Horizon scanning for any changes in legislation and regulations is also 

being progressed. 

Law Debenture relies on third 

To mitigate these risks, all third-party suppliers are subject to robust due diligence, 

parties to perform key functions of 

review and sign off from the Executive Risk Committee. 

its business operations enabling its 

provision of services to clients. The 

Board recognises that such third 

parties may act in ways that could 

harm our business either through 

failure to deliver services or negative 

public opinion. 

7.   Financial Crime and Fraud

Across all jurisdictions the Group's 

To mitigate these risks, the following controls are in place: 

activities are subject to various 

financial crime laws and regulations, 

including sanctions and export 

control, anti-bribery, anti-corruption, 

anti-money-laundering and counter-

terrorist financing. Changes to 

these laws could have a material 

• 

• 

  Enhanced incident reporting procedures for the Group with timelines for notifications 

and clear reporting lines. 

 Appropriate whistleblowing procedures and a clearly defined reporting structure 

with colleagues having the option to raise any concerns with their line manager, the 

General Counsel and HR Manager or if those avenues are not appropriate, to the 

Chairman of the Audit and Risk Committee, who is the employee representative of 

adverse impact on our operations or 

the Board. 

financial results.

• 

 There are robust policies in place covering fraud prevention, anti-bribery and 

corruption which are supported by employee training.

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Risk management continued

Investment portfolio risk summary and internal controls

INVESTMENT PORTFOLIO RISKS MITIGATING ACTIVITIES

1.  Investment Performance 
and Market Risk

The risk of the investment portfolio 

Even though this is an accepted risk given the nature of the investment portfolio, the 

failing to deliver and/or failing 

Board is responsible for ensuring that there are adequate controls to help manage the 

to consider and react to market 

inherent risk. As such, the Board has put in place various controls, details of which can 

conditions to deliver the publicly 

be found on page 33 of the strategic report on Our Strategy – implementation.

stated strategic objectives to: 

Furthermore, the NAV is published daily and subject to review by the CFO, which 

• 

• 

• 

 Achieve long-term capital growth.

enables ongoing monitoring of the investment portfolio’s performance.

 Deliver a steadily increasing income.

The Board further notes that the IPS business also provides an additional layer of 

 Achieve a rate of return greater than 

the FTSE Actuaries All-Share Index.

diversification for the portfolio, meaning that the investment portfolio and the Group as 

a whole are less exposed to any potential dividend cuts from the equity holdings.

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Investment performance and market 

risk is the largest risk which the 

investment portfolio is exposed to, 

however, this is an accepted risk 

and one which the Board actively 

takes as it believes long-term equity 

investment is an attractive proposition. 

2.  Gearing

This risk could arise where the 

To mitigate this risk, all borrowings require the prior approval of the Board and gearing 

Company has borrowed money for 

levels are kept under close review by the Board. The Board applies a ceiling on effective 

investment purposes. If the value 

gearing of 50%. While effective gearing will be employed in a typical range of 10% net 

of portfolio investments falls, any 

cash to 20% gearing, the Board retains the ability to reduce equity exposure so that net 

borrowings will magnify the extent 

cash is above 10% if deemed appropriate. Gearing is reviewed and reported on to the 

of this loss. 

AIC monthly by the Finance team. 

3.  Credit Risk (Securities 
Lending)

Securities lending within the 

To mitigate this risk, the Board has limited the amount of stock lending within the 

investment portfolio could lead to 

investment portfolio to up to 30% of NAV only. In addition, the Board is indemnified 

the risk of loss if any of our borrowers’ 

by HSBC as the sub-custodian under the securities lending arrangements. HSBC are 

default on their obligations to 
the business. 

obliged to indemnify the arrangements such that the security collateral value shall 
always be greater than the value of securities on loan and a minimum margin is applied 

onto the security collateral: 102.5% for government bonds and 105% for equities.

4.  Legal and Regulatory

This could arise from a failure to 

All legal, regulatory, compliance and reporting obligations across the Group, including 

comply with legal and regulatory 

that of the investment portfolio, are tracked and complied with. Horizon scanning 

requirements and filings resulting in 

for any changes in legislation and regulations is also being progressed. An annual 

fines, suspension of listing or a loss 

“Key Information Document” (KID) is compiled and published by the business as are 

of investment trust status. Changes 

European PRIIP and MIFID templates (EPT/EMT). There is also oversight and monitoring 

to legislation could have a negative 

from the Depositary. 

impact on Law Debenture’s ability to 

meet its objectives. e.g. Government 

intervention on publicly listed firms’ 

dividend policy. 

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Risk management continued

INVESTMENT PORTFOLIO RISKS MITIGATING ACTIVITIES

5.  Technology, Systems and 
Internal Controls

The risk of loss resulting from 

To mitigate these risks, Janus Henderson are subject to an annual ISAE3402 audit and AAF 

inadequate or failed technology, 

review to ensure there are no material deficiencies. The Executive Risk Committee also 

information and manual processes and 

receive a monthly operational report with respect to Janus Henderson’s risks and controls. 

systems of Janus Henderson, including 

business continuity/disaster recovery 

incidents and wider control issues such 

as fraud or conflicts of interest.

IPS business risk summary and internal controls

IPS BUSINESS RISKS

MITIGATING ACTIVITIES

1.  Financial

This is the risk that the IPS business 

To mitigate these risks, monthly management information is provided to the CEO and 

is not able to scale up and deliver 

Business Heads to monitor and assess business performance. Through 2020 there 

on its growth plans to generate 

has been significant investment in people and technology to support the long-term 

anticipated revenue growth, 

growth of the business and these needs continue to be regularly assessed. 

profitability, cost savings and react 

to any changes in market conditions. 

2.  People

This is key as the IPS business is based 

To mitigate our key people risks, a new COO and Human Resources Manager 

on successfully attracting and retaining 

have been recruited and are developing plans for continued and better employee 

talented employees representing 

engagement and wellbeing. With this, the Board recognises that there is an 

diverse backgrounds, experiences and 

opportunity to further develop and enhance its strategic plans to support employees 

skill sets. The loss of key colleagues, no 

in a collaborative culture.

succession planning or failure to ensure 

effective transfer of knowledge and 

smooth transition could damage or 

result in the loss of client relationships 

and could result in such colleagues 

competing against the business. 

3.  Technology and Systems

Maintaining the brand and reputation, as well as a diverse and inclusive work environment 

that enables all our employees to thrive, is important to our ability to recruit and retain 

employees. 

The risk of cyberattacks and security 

To mitigate such risks, the office move is allowing for enhanced technology resources 

vulnerabilities is ever present, and 

and capability through investment and increased use of cloud services allowing 

failures here could lead to reduced 

sustainable, scalable technology growth in 2021 and beyond. Incident reporting 

revenue, increased costs, liability 

procedures are in place. 

claims, or harm to our reputation or 

competitive position.

4.  Legal and Regulatory

The IPS business will be negatively 

The General Counsel helps safeguard the IPS business and ensures that it complies 

affected if it is not able to anticipate 

with changes in law or regulations. 

and keep pace with rapid changes 

in laws or regulations, or if laws or 

regulations decrease the need for the 

services provided or increase costs. 

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Risk management continued

IPS BUSINESS RISKS

MITIGATING ACTIVITIES

5.  Credit

This is the risk of loss to our receivables 

Credit risk is actively monitored by the Finance team; the mitigations in place ensure 

should any of IPS’ clients or other 

that debtors across the business are monitored and moreover, the credit status of 

counterparties default on their 

clients is considered as part of the client onboarding process. 

payment obligations either through 

no payment or late payment for 

services we have delivered or the risk of 

exposure or centration to one client or 

business sector.

6.  Strategic

This is the risk that the current business 

To mitigate this risk, there has been significant investment in people and technology 

model becomes obsolete due to a lack 

to support the IPS business strategy and this will continue to be monitored along with 

of technical or commercial innovation, 

the introduction of the Group’s 3-year strategic plan which forms part of the Group’s 

market disruption, product obsolesce 
or regulatory or legislative change. 

longer term viability statement. There are also regular IPS board meetings where 
the strategy of the business is discussed with the Business Heads and the Executive 

Leadership team.

Looking forward: our risk agenda 2021

The focus for 2021 and beyond will be to further enhance the internal controls and mitigating actions in place to reduce risk and to test 

the procedures added in 2020 to further strengthen their effectiveness. A number of initiatives have been planned for 2021; the below 

lists some examples.

Risk Management and Internal Audit plans

As noted above, a plan to refresh the risk management and internal audit framework has been agreed by the Chairman of the 

Audit and Risk Committee and the Executive Risk Committee and will begin in earnest in 2021. This will support the management 

of the principal risks (and other business specific risks) highlighted above and will enhance the governance and oversight of 

their management. 

AML/KYC

A review of the AML/KYC framework is due to be undertaken in 2021. This will focus specifically on the management of the principal 

risks (and other business specific risks) noted earlier and to enhance the governance and oversight of their management. This also 

includes the review of the Sixth Money Laundering Directive which came into force in December 2020. As such an important area for 

the Group, the Board is keen that this is something that is continually under review and enhanced where possible. As a result of the 
leadership changes in 2020, we will look to appoint a new Group MLRO in 2021.

Third Party Supplier Due Diligence

An enhanced third-party risk/due diligence policy will be put in place with the aim of documenting third party risk and supplier due 

diligence requirements. This will include third party fraud prevention, anti-bribery and corruption and will enhance the due diligence 

process and sign-off the Executive Risk Committee already undertakes. 

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Viability statement

Viability statement

Our business operations

The UK Corporate Governance Code (the Code) requires the 

Board to issue a ‘viability statement’ declaring whether the 

Directors believe the Company can operate and meet its 

liabilities, taking into account its current position and principal 

risks. The overriding aim of the Code is to ensure that the 

Board focuses on the longer term and is actively involved in 

the oversight of the risk management framework and internal 

control environment. 

The Board is required to assess the Company’s viability over 

a period greater than twelve months. Our stated financial 

objective is to deliver long-term capital growth in real terms 

and to steadily increase income to our shareholders. As 

such, the Board considers that the Company is a long-term 

investment vehicle and, for the purposes of this statement, has 

decided that three years is an appropriate period over which to 

consider its viability and we have aligned our business planning 

process and remuneration at a senior level accordingly.

In assessing the viability of the Company over the review 

period, the Board has considered a number of key factors, 

including:

• 

• 

• 

• 

• 

 The Company retains ownership of all assets held by the 

Custodian under the terms of formal agreements with the 

Custodian and Depositary.

 The Group’s cash is all held with banks approved by the Board. 

The Group’s cash balance, including money market funds, at 

31 December 2020 totalled £41.8m (2019: £71.2m).

 There is long-term borrowing in place comprising of two 

debentures; 6.125% debenture maturing in 2034 and a 3.77% 

debenture maturing in 2045. These are subject to formal 

agreements, including financial covenants which the Company 

complied with in full during the year.

 During January 2021, the Company put in place a £50m 

unsecured overdraft facility with HSBC.

 The Board reviews the Trust performance including revenue 

forecasts, along with other key metrics such as gearing at each 

Board meeting and receives regular financial reporting.

In addition to this, the Board carried out a robust assessment of 

our principal and emerging risks and uncertainties which could 

threaten the Company’s business model, as detailed on pages 

32 to 34 of the annual report, along with the controls in place to 

Our business model and strategy

mitigate these risks.

• 

 The Board seeks to ensure that the Company delivers 

long-term performance. The closed ended nature of 

the investment trust means that the Company does not 

face liquidity issues when shareholders wish to sell their 

shares, avoiding any untimely requirements to sell down 

the portfolio.

• 

 As an investment trust, we benefit from the unique structure 

of a predominantly UK-based equity portfolio with a 

diversified revenue stream arising from the IPS business. As 

shown both historically and during the recent economic crisis 

brought about by Covid-19, the IPS revenue streams provide 

protection to the long-term viability of the Company.

• 

• 

 The majority of the portfolio is investments in UK listed 

securities which are traded on major stock exchanges.

 The Company has an ongoing charge of 0.55%, which is lower 

than other comparable trusts within our Sector.

During 2020 there has been significant global economic 

volatility bought about by the Covid-19 global pandemic, which 

has impacted the UK Equity Investment Trust Sector, as many 

listed companies took steps to suspend or cut their dividend 

payments. A detailed overview of the response by the Board 

and Company to Covid-19 can be found on page 63. In light of 

the current conditions, the Board has considered the Company’s 

current financial position and the potential impact of its principal 

risks and uncertainties, and has a reasonable expectation that 

the Company will be able to continue in operation and meet its 

liabilities as they fall due for a period of three years from the date 

of this annual report.

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Section 172(1) statement

Section 172(1) statement

Shareholders 

The Board is responsible for the overall 

Engagement with our institutional and 

strategy and overseeing the management 

retail shareholders is an ongoing process. 

of the Group, setting investment strategy 

The Board actively communicates with its 

and ensuring that the Company is acting 

shareholders as detailed in the Directors’ 

in accordance with its legal and regulatory 

report on page 54. In addition, meetings 

The Covid-19 pandemic

The Covid-19 pandemic has had 

a significant impact on all of our 

stakeholders since it emerged towards 

the end of the previous financial year. 

obligations. Throughout the global 

are held with shareholders throughout 

This impact and how we have responded 

pandemic, the Board has been flexible 

the year, which are attended by Executive  

to protect our business and manage the 

and continued to meet as normal, hosting 

Directors along with representatives from 

expectations of our five key categories 

meetings virtually. During the course of 

the investment manager. During 2020, 

of stakeholders is set out in full on pages 

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2020, the Board met seventeen times.

in-person meetings with investors were 

In discharging its responsibilities, the 

Board takes into account the Group’s 

purpose, value and culture and acts 

in good faith to promote the success 

of the Company and to maintain high 

standards of business conduct. The Board 

is responsible for overseeing stakeholder 

engagement and ensuring that we fulfil 

our obligations to all key stakeholders 

impacted by the business. We believe 

that this is pivotal to our ability to drive 

value creation over the longer-term. Those 

impacted by the Company’s activities 

largely replaced with virtual meetings due 

to the spread of Covid-19 and resultant 

intermittent lock-downs across the UK. 

Key topics of discussion during the year 

included prospects and valuation of 
the IPS business, performance against 

benchmark, prospects for the UK economy 

and the investment style and stock 

selection. We listened to our shareholders 

and introduced the publication of a daily 

NAV, along with a full portfolio listing on 

the website every month and moved to a 

quarterly dividend. 

can be grouped into the following five 

In February 2021, the Board obtained 

main categories: shareholders, clients, 

shareholders’ approval to amend the 

employees, principal service providers, the 

Company’s Articles of Association to 

community and the environment. 

permit virtual general meetings, including 

annual general meetings. The Board does 

not at this time intend to hold virtual only 

meetings in the future or on an ongoing 

basis. The Board hopes that this will 

provide comfort to our shareholders that, 

where circumstances arise which make 

it difficult to attend in person, they will 

still be able to attend, vote and speak 

at meetings. 

When making decisions the Board 

considers the interests of shareholders 

as a whole and the need to act fairly as 

between members of the Company.

61 and 62.

KEY:

  Shareholders

  Clients

  Employees

  Service providers

 Community and  

the environment 

Clients 

Ensuring that we provide an excellent 

service to our clients is crucial to the 

delivery of the Board’s strategy for the IPS 

business. This year, we have continued to 

focus on acting as a trusted advisor to our 

clients across each of our offerings and 

have sought to introduce innovative ways 

to better meet the needs of our clients, 

through the channels we offer our services. 

In light of the Covid-19 pandemic, we 

have sought new digital ways to engage 

with our clients, such as virtual client 

events and increased our presence on 
social media.

The Board also receives presentations from 

each IPS Business Head on a rolling basis 

throughout the year, including details of 

client relationship management initiatives 

and proposed new service offerings to 

expand the client base. With the rise 

of remote working, the Board was also 

particularly concerned to have oversight of 

the Group’s approach to managing cyber 

security and engaged directly with the 

Chief Technology Officer to understand 

the controls in place.

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Section 172(1) statement continued

Stakeholders

Shareholders

Clients

Employees

Ke y Priorities

Deliver against our stated objective to provide long-term capital growth in real terms 

and a steadily increasing income.

Seek to provide an excellent service to all our clients.

To provide an inclusive and diverse place to work which promotes engagement in 

the delivery of our long-term strategy.

Service providers

To provide a clear framework and open communication channel between us and 

our key service providers to facilitate the best possible investment outcomes for 

our shareholders. 

Ensure that prompt and accurate payments are made for goods and services across 

all service providers.

Community and the environment

To act responsibly as an institutional shareholder and to minimise the impact of the 

Company’s operations on the community and the environment.

Community and 
environment 

We disclose our carbon emissions 

consumption as part of the Directors’ 

report on page 54. Those emissions relate 

solely to the maintenance of our various 

offices around the world. The Group 

supports certain charities from time to 

time, particularly where employees have 

personally organised events, or take part in 

sponsored activities, that benefit charities 

related to them or their families. During 

the course of 2020, the Group has given 

employees the opportunity to donate the 

monetary value of any unused holiday 

to a charity of their choice. The Group is 

unaware of any human rights issues that 

might arise from its activities, mindful 

though of the need to act responsibly as 

an institutional shareholder (as described 

on page 35). 

Employees 

Service providers 

In 2019, the Board appointed Mark 

The Company has regard for all service 

Bridgeman as its designated Non-

providers. The investment manager has 

Executive Director to gather the views 

been identified as the principal service 

of Law Debenture’s workforce. He 

provider with which the Board engages 

commissioned an employee engagement 

on an on-going basis. The investment 

survey across the entire employee base, 

manager provides an update on 

the results of which have been considered 

management and performance of the 

by the Board and appropriate action 

portfolio at scheduled Board meetings. 

During the pandemic, the increased use 

of online communication and out of office 

working for the investment manager 

and other key service providers have, to 

date, also proved to be robust. Aware of 

the cashflow challenges that many of our 

suppliers may have been facing, the Group 

sought to ensure we met our obligations 
on a timely basis.

plans have been put in place to address 

concerns, where required. Employees are 

also invited to attend and ask questions at 

an all staff “townhall” presentation from 

the Executives and investment manager 

following the result of the half year and 

annual results. Towards the end of the 

year, the Company moved head office 

to provide employees with a modern, 

comfortable working environment 

that complies with all relevant safety 

regulations. Employee wellbeing is 

ensured through delivery of a range of 

benefits designed to promote good health 

including health insurance and access to 

medical reviews. Independent confidential 

helpline facilities are provided to enable 

employees to deal with issues of concern 

to them, whether work or domestic. As 

a result of these measures, and senior 

management’s open style, staff turnover is 

generally low. 

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Section 172(1) statement

Key strategic decisions impacting stakeholders in 2020

During the year, as the Board made decisions to deliver against our strategy, whilst considering the different interests of our stakeholder 

groups and the impact of key decisions upon them. The following provides an overview of some of the key decisions taken and how 

integral our stakeholders are in the Board’s decision-making process.

1)  Providing Certainty over the Final Dividend 

At a time when many companies were cancelling or postponing payment of their dividends, the Board ensured that the Company 

paid the final dividend for 2019 as approved by the shareholders. Aware that many of our shareholders are dependent on income 

arising from their investments, the Board delivered on our commitment to move to a quarterly dividend and also provided an early 

indication that the recommendation would be to at least maintain the dividend at the level of 2019, thus providing some certainty 

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for our investors during turbulent times. 

2)  Upholding our Investment Strategy 

The pandemic placed a strain on global equities valuations and many companies’ balance sheets. The Board took the decision to 

utilise the strength of the Company’s balance sheet, to fund dividends out of reserves if necessary, and allowed our investment 
managers to remain committed to pursue longer term value rather than immediate income receipts. Throughout the year, the 

Board has been instrumental in supporting the investment managers’ position, as a key service provider, to be a net investor in a 

depressed market, taking the decision to allow the investment managers to increase leverage, with a view to maximising the return 

for our shareholders.

During 2019, the portfolio was realigned to the AIC UK Equities sector and during the course of 2020, the Board took the decision to 

remove the previous cap on UK investments, giving our investment managers increased flexibility in their selection of holdings.

3)  Investing in the Executive Leadership Team 

With the IPS business showing sustained growth over the last three years, the Board recognised that it was time to invest in 

expanding the Executive Leadership team, to provide greater support to our employees as they seek to provide an excellent service 

to our clients. Having had an Executive Leadership team compromising of the CEO and the CFO, the Board took the decision to 

appoint a COO and a General Counsel to ensure that there was sufficient bandwidth within the team to continue to drive growth 

within the IPS business, which is beneficial to providing a secure source of income for our shareholders.

4)  Continued Investment in Delivering Long-Term IPS Revenue Growth 

Throughout the course of 2020, the Board has supported the Executive Leadership team in continuing investment to ensure that 

the growth in IPS revenue was sustainable. There has been ongoing investment into our digital offering with the launch of an 

ecommerce platform for our Safecall whistleblowing business, amongst other things. The Group has also continued to invest in our 

people, where supported by revenue growth or a strong business case, incremental hires have been made and we have invested in a 

training programme for all our staff.

5)  Diversification and Strengthening of Revenue Streams 

At the end of 2020, we announced the strategic acquisition of the Konexo UK company secretarial business. Having scrutinized the 

proposed acquisition, the Board believes that this deal significantly strengthens both the corporate services revenue stream, adds to 

diversification of revenues across the Group and delivers growth in earnings per share for our shareholders.

6)  Implementing a New Risk Management Framework 

The long-term success of every business is dependent on the appropriate management of risk. During the course of the year, the 

Board oversaw the implementation of a new risk management framework, of which further details can be found on pages 39 to 45 

of this report, and hired a new Head of Internal Audit to modernise the assurance programme across the Group. This provides a 

clear framework of risk management for our employees and service providers to work within and strengthens our ability to provide 

sustainable growth for our shareholders.

KEY

  Shareholders

  Clients

  Employees

  Service providers

 Community and the environment

Law Debenture Corporate Services Limited 
Company Secretary

25 February 2021

49

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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The Board

Robert Hingley 
Chairman of the Board, Independent  

Denis Jackson 
Chief Executive Officer

Trish Houston 
Chief Operating Officer

Non-Executive Director 

  N   R

Appointed to the Board on 1 October 2017 

and appointed Chairman in April 2018.

A corporate financier with over 30 years’ 

experience, Robert was a partner at 

Ondra LLP until October 2017. From 2010 

until 2015, he was a managing director 

and later senior advisor, at Lazard. He 

was previously director-general of The 

Takeover Panel from 2007 on secondment 

from Lexicon Partners, where he was 

vice chairman. Prior to joining Lexicon 

Partners in 2005, he was co-head of the 

Global Financial Institutions Group and 

head of German investment banking at 

Citigroup Global Capital Markets, which 

acquired the investment banking business 

of Schroders in 2000. He joined Schroders 

in 1985 after having qualified as a solicitor 

with Clifford Chance in 1984.

Robert is currently the chairman of 
Phoenix Spree Deutschland Limited 

and of Euroclear UK and Ireland Limited 

and chairman of Governors at North 

London Collegiate School. He is also a 

Appointed to the Board on 1 January  

Appointed to the Board on 2 September 

2018.

2020.

Denis joined Law Debenture in July 2017 

Trish brings almost twenty years of 

as Chief Commercial Officer. He was 

experience in leadership roles in the 

previously at Capita plc as director of 

financial services industry. Most recently, 

new business enterprise, having been 

she was a member of the senior 

a director at Throgmorton UK Limited 

management team at JDX Consulting 

(which Capita acquired). Prior to that, 

Limited, where she had executive 

he was regional general manager for 

responsibility for HR, IT and facilities and 

Europe and the United States at Tibra 

oversaw the merger of three businesses. 

Trading Europe Limited, a FCA regulated 

Previously, Trish was a partner at 

proprietary trading company, which he 

Ruffer LLP where she held several roles 

joined from Citigroup (formerly Salomon 

including global head of HR and global 

Brothers). He spent almost 20 years there 

head of Risk. She was also a member 

in a variety of roles including in Treasury 

of the investment management team 

(both in New York and London), as head 

in the UK, Australia and Switzerland at 

of the finance desk in Hong Kong, head 

PricewaterhouseCoopers LLP.

of fixed income prime brokerage in New 

York and ultimately, head of EMEA prime 

brokerage sales.

Key skills and experience contributed to 

the Company include operational growth, 

risk management, strategy and human 

Key skills and experience contributed to 

resource management.

the Company include strategy, commerce, 

corporate finance and governance and 

operational and transactional leadership 

non-executive director of Marathon Asset 

in regional organisations.

Management, a member of the Takeover 

Panel and a trustee of Park Theatre.

Key skills and experience contributed to 

the Company include strategy, corporate 

finance, corporate governance and 

mergers and acquisitions.

Key 

R   Remuneration Committee 

  N   Nomination Committee 

  A   Audit and Risk Committee 

  Committee Chairman

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The Board continued

Robert Laing   
Senior Independent Director 

Mark Bridgeman 
Independent Non-Executive 

Tim Bond   
Independent Non-Executive 

Claire Finn 
Independent Non-Executive 

R   A   N

Director 

  A   R   N

Director 

  A   R   N

Director 

  A   R   N

Appointed to the Board on 

Appointed to the Board on 

Appointed to the Board on 

Appointed to the Board on 

2 April 2012.

15 March 2013.

14 April 2015.

2 September 2019.

Robert qualified as a solicitor 

Mark’s background is in fund 

Tim is currently a partner of 

Claire’s most recent executive 

in England in 1977 and in 

management. He spent 19 

Odey Asset Management 

experience was at Blackrock, 

Scotland in 1985 and worked 

years with Schroders plc as an 

LLP having joined in 2010 as 

where she spent almost 13 years, 

for Slaughter and May from 

analyst and then fund manager, 

its head of macroeconomic 

becoming managing director 

1975 to 1985, when he joined 

rising to become head of global 

strategy and currently manages 

and head of UK DC, Unit Linked 

Maclay Murray & Spens LLP. 

sector research. Previous roles 

Odey’s Odyssey Fund. Before 

and Platforms, responsible for 

He is currently a non-executive 

at Schroders included head 

joining Odey, Tim spent 12 

strategy, innovation and growth. 

director of The Independent 

of Pan European research, 

years at Barclays Capital as 

Previous roles at Blackrock 

Investment Trust plc and 

head of global sector research 

managing director and head 

included director/managing 

a non-executive advisor to 

and emerging markets fund 

of global asset allocation. Tim 

director, head of strategic 

Rossie House Investment 

manager. He was also non-

was editor and principal author 

alliances, director of sales and 

Management LLP.

executive director of JP Morgan 

of Barclays Capital’s Equity Gilt 

relationship management, 

Key skills and experience 

contributed to the Company 

include corporate trust, law and 

corporate governance.

Brazil Investment Trust plc until 

Study and chief advisor to the 

and vice president of product 

November 2020. During his 

bank’s RADAR Fund. Prior to 

development. She previously 

career, he enjoyed successful 

Barclays, Tim worked at Moore 

held roles in product 

long-term secondments in 

Capital and spent 10 years as a 

management at Henderson 

Australia and the United 

strategist and trader for Tokai 

Global Investors (2001 – 2005) 

States. Mark left Schroders 

Bank Europe, a proprietary 

and relationship management 

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in 2009 to manage a rural 

trading boutique. 

Key skills and experience 

contributed to the Company 

include fund management and 

investment, strategy, corporate 

finance, ESG matters and 

distribution to investors.

estate and farming business 

in Northumberland and is also 

on the board of two charities. 

Mark is currently a director of 

Country Land and Business 

Association Limited, Howick 

Trustees Limited and Otter 

Arable Limited.

Key skills and experience 

contributed to the Company 

include fund management 

and investment, strategy and 

corporate finance.

at Bank of Tokyo-Mitsubishi, 

London (1999 – 2001). Claire 

is currently a non-executive 

director of Artemis Fund 

Managers Limited, Sparrows 

Capital Limited and St. Joseph’s 

Catholic Primary School.

Key skills and experience 

contributed to the Company 

include fund product 

development, distribution 

to retail and institutional 

investors, strategic innovation 

and growth in the UK asset 

management, pensions and 

insurance industries and 

corporate governance.

51

 
 
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Executive Leadership team

Denis Jackson  Chief Executive Officer

Appointed to the Board on 1 January 2018.

Denis Jackson’s key strengths are in commerce, corporate finance and strategy with significant 

experience in operational and transactional leadership in regional organisations. He continues 

to lead the effective implementation of strategy across the Group and has been instrumental in 

increasing the profits of the IPS business, enhancing shareholder value and increasing income. 

He also successfully led the Group’s operations during the Covid-19 pandemic and in the 

acquisition of Konexo UK’s company secretarial business.

Trish Houston  Chief Operating Officer

Appointed to the Board on 2 September 2020.

Trish Houston brings almost twenty years of experience of leadership roles in financial services. 

Her key strengths are in operational growth, risk management, strategy and human resource 

management. Trish has already been core to the improvement of the business’ operations 

having spearheaded the implementation of the new HR System for the Group, taken lead on the 

relocation of Law Debenture’s London Head Office to 100 Bishopsgate and been responsible for 

the operational aspects of the recent acquisition of Konexo UK’s company secretarial business.

Hester Scotton  Chief Financial Officer

Hester Scotton qualified at Ernst & Young LLP and has over ten years of experience in a variety of 

finance and internal audit roles at organisations such as Marks & Spencer PLC, Bupa and Legal 

and General. Since joining Law Debenture, Hester has been instrumental in the modernisation 

of the finance function and provided significant support in the acquisition of the company 

secretarial business from Konexo UK.

Kelly Stobbs  General Counsel

Kelly Stobbs brings more than ten years’ legal experience in private practice as an M&A lawyer 

at Herbert Smith Freehills LLP, in-house as a corporate and finance senior executive at HSBC at a 

Group level and latterly as a legal and tax director at Deloitte LLP. As part of her responsibilities 

as General Counsel, Kelly heads up risk and compliance and the Group company secretarial 

function. Kelly led on the legal aspects of the recent acquisition of Konexo UK’s company 

secretarial business and has implemented a risk, controls and governance refresh across 

the Group. 

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The Directors present their annual report and the audited financial statements for the year ended 31 December 2020. The Company operates 

as an investment trust in accordance with sections 1158-1159 of the Corporation Tax Act 2010 as amended (s1158-1159) and has been approved 

as such by HM Revenue & Customs. In the opinion of the Directors, the Company has conducted its affairs so as to enable it to continue to 

be an approved investment trust under s1158-1159. The Company, which is not a close company, is registered as an investment company as 

defined in section 833 of the Companies Act 2006 and operates as such. The Directors consider that the Group operates as a going concern.

The corporate governance report forms a part of the Directors’ report.

Essential contracts

any new conflicts are to be declared is also considered at each 

Board meeting. Each Director has declared all matters that might 

In the view of the Board, the only contract that is essential to the 

give rise to a potential conflict of interest and these have been 

business of the Group is the investment management agreement 

considered and (where necessary) approved by the Board. 

with Janus Henderson, details of which are set out in the strategic 

report.

Financial instruments

The Company’s financial instruments, financial risk management 

objectives and policies arising from its financial instruments and 

its exposure to risk are disclosed in note 20 to the accounts.

Regulatory compliance

The Company is subject to continuing obligations applicable to 

premium listed companies, overseen by the FCA.

Information required to be disclosed in accordance with Listing 

Rule 9.8.4 is included as referenced below:

Revenue, dividends and reserves

The Group revenue return attributable to shareholders for the 

year ended 31 December 2020 was 21.63p per share. The Directors 

Rule

9.8.4 (1)

9.8.4 (7)

Detail

Where

Interest capitalised

Note 6, page 104

Allotment of equity securities Note 18, page 101

recommend a final dividend of 8.00p per share, which, together 

9.8.4 (2-6) (8-14) Not applicable

N/A

with the interim dividend of 6.50p paid in each of July and 

October 2020 and January 2021, will produce a total of 27.5p per 

share (2019: 26.0p). The final dividend will be paid on 15 April 2021 

to holders on the register on the record date as at 12 March 2021. 

After deduction of the interim and final dividends of £32,572,000 

(2019: £30,788,000), consolidated revenue reserves decreased by 

Under the Alternative Investment Fund Managers Directive (AIFMD) 

the Company is required to appoint an “Alternative Investment Fund 

Manager” (AIFM), which must be appropriately regulated by the 

FCA. The Company has elected to be its own AIFM.

£12,358,000 (2019: increase of £4,854,000).

The AIFM is required to provide portfolio management, risk 

Directors

The Directors at the date of this report are listed on pages 50 and 

51. All Directors held office throughout the year other than Trish 

Houston, who was appointed on 2 September 2020 and Katie 

Thorpe, who resigned from the Board on 11 September 2020.

All Directors are required to stand for re-election every year (or 

election at the next AGM following appointment). The list of 

candidates, which the Board supports, is set out in the notice of 

annual general meeting. The particular skills and experience that 

each Director contributes to the long-term sustainable success of 

the Company and the Group may be found on pages 50 and 51. 

As mentioned in the Chairman’s statement, Robert Laing will not 

be standing for re-election as a Director of the Company at the 

upcoming AGM.

Directors’ conflicts of interests

management, administration, accounting and company secretarial 

services to the Company. All of these functions, barring portfolio 

management which continues to be delegated to Janus Henderson, 

are undertaken by the Company. The Company has appointed 

NatWest Trustee and Depositary Services Limited, as depositary 

under Article 36 of the AIFMD. A fee is payable for this service, being 

0.0225% per annum of the calculated monthly NAV. As part of its 

duties, the depositary is responsible for custody of the Company’s 

portfolio assets, and has appointed HSBC Bank plc (which has been 

the Company’s custodian for many years) as sub-custodian.

AIFMs are obliged to publish certain information for investors and 

prospective investors and that information may be found either in this 

annual report or on the Company’s website at www.lawdebenture.

com/investment-trust/corporate-governance/the-aifmd. 

The AIFMD requires us to report on ‘leverage’. This is slightly different 

from gearing, leverage being any method of borrowing that 

increases the Company’s exposure, including the borrowing of cash 

and the use of derivatives. It is expressed as a ratio between the 

Company’s exposure and its NAV and must be calculated on a ‘gross’ 

The Directors have a statutory duty to avoid conflicts of interest. 

and a ‘commitment’ method. Under the gross method, exposure 

The Board has in place appropriate procedures to deal with 

represents the sum of the Company’s positions after the deduction 

conflicts and potential conflicts, including an annual review, and 

of sterling cash balances, without taking into account any hedging 

can confirm those procedures are operating effectively. Whether 

and netting arrangements. Under the commitment method, 

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Directors’ report continued

exposure is calculated without the deduction of sterling cash 

issued share capital. Share information as required by section 992 

balances and after certain hedging and netting positions are offset 

of the Companies Act 2006 appears at pages 33 and 114. 

against each other. At 31 December 2020, the maximum amount of 

leverage under the gross and commitment methods was 1.50 and 

actual amounts were 1.06 and 1.15 respectively.

Shareholder relations

ESG considerations

The Company encourages communication between management 

and shareholders on matters of mutual interest. All shareholders, 

with the exception of employees, on the register are sent a copy 

The Group gives ongoing consideration to ESG factors in both the 

of the annual report and the Company also provides this service 

management of the investment portfolio and the IPS business. 

to shareholders in nominee companies where the nominee 

This is reflected in the Chairman’s statement on pages 4 and 5, the 

has made appropriate arrangements. Shareholders wishing 

CEO’s review pages 10 to 16 and the investment managers’ review 

to receive reports and other communications electronically 

pages 18 to 22.

In addition to this, we also consider our greenhouse gas emissions. 

The Group’s carbon emissions arise from its consumption of energy 

in maintaining its offices. Using conversion factors published by 
the UK Department for Business, Energy and Industrial Strategy, 

emissions for the year to 31 December 2020 were 179.65 tonnes of 

CO2e (2019: 228.63 tonnes of CO2e). This equates to 0.0059 tonnes 

of CO2e per £000 of IPS revenue (2019: 0.0062 tonnes of CO2e).

None of the entities within the Group (subsidiaries or parent 

company) meet the streamlined energy and carbon reporting 

(SECR) regulations at an individual level.

Repurchase of shares

At the 2020 AGM the Directors were given power to buy back 

17,753,225 ordinary shares or if less the number of shares equal 

to 14.99% of the Company’s issued share capital at that date. 

During the year, the Company did not repurchase any of its 

shares for cancellation. This authority will expire at the 2021 AGM. 

The Company intends to seek shareholder approval to renew its 

powers to repurchase shares for cancellation up to 14.99% of the 

Company’s issued share capital if circumstances are appropriate, 

at the 2021 AGM.

Donations

The Company made no political or charitable donations during 

the year (2019: £nil) to organisations.

may do so by writing to the Company. In addition to periodic 

regulatory reports published via the London Stock Exchange, the 

Company publishes a monthly factsheet on its website about the 

investment portfolio performance, the quality of which has been 

recently enhanced.

Investment managers – interests held

Laura Foll held 6,750 shares in the Company as at 31 December 

2020 (2019: 1,750). James Henderson did not have a beneficial 

interest as at 31 December 2020 (2019: nil), although persons 

connected to him had an interest of 134,000 shares (2019: 

100,000 shares). In addition, a charity with which James 

Henderson has non-beneficial connections owns 117,000 shares 

(2019: 100,000 shares).

The Company holds no shares in the Janus Henderson Group 

or their products. It has been notified that funds managed by 

members of the Janus Henderson Group held 262,519 shares in 

the Company as at 31 December 2020 (2019: 154,026 shares).

Employee participation/issue of shares

Employees are informed of the financial aspects of the Group’s 

performance through periodic management meetings. Mindful 

of the Company’s paperless initiative, copies of the annual 

report are made available to employees on request and are 
available on the Company’s website. The Company operates a 

SAYE scheme in which all UK full-time employees are eligible to 

participate after completing a minimum service requirement.

Share capital and significant shareholdings 

Options outstanding under the SAYE scheme as at 31 December  

2020 were:

The Company’s share capital is made up of ordinary shares with a 

nominal value of 5p each. The voting rights of the shares on a poll are 

one vote for every share held. There are no restrictions on the transfer 

Date of grant

of the Company’s ordinary shares or voting rights and no shares 

which carry specific rights with regard to the control of the Company. 

There are no other classes of share capital and none of the Company’s 

issued shares are held in treasury. As at 31 December 2020, there were 

19 August 2015

23 August 2016

15 August 2017

118,454,562 ordinary shares in issue with 118,454,562 voting rights. Note 

15 August 2018

18 includes details of share capital changes in the year.

As at 25 February 2021, there were no shareholders that had 

notified the Company of a beneficial interest in 3% or more of the 

14 August 2019

26 August 2020

Number  
of option 
holders

2

7

12

22

16

23

Shares 
under 
option

2,926

9,981

18,153

Exercise 
price

512.50p

495.75p

594.75p

44,905

606.00p

27,761

592.00p

56,759

539.00p

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Directors’ report continued

Directors’ responsibilities

responsible for ensuring that the annual report and accounts, 

taken as a whole are fair, balanced and understandable and 

The Directors are responsible for preparing the annual report 

provides the information necessary for shareholders to assess the 

and the financial statements in accordance with international 

Company’s performance, business model and strategy. 

accounting standards in conformity with the requirements of the 

Companies Act 2006 and other applicable laws and regulations. 

Company law requires the Directors to prepare financial 

statements for each financial year. Under that law the Directors 

are required to prepare the financial statements in accordance 

with international accounting standards in conformity with the 

requirements of the Companies Act 2006. 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 of the profit or loss for the Group for 

that period. The Directors are also required to prepare financial 

statements in accordance with international financial reporting 

standards adopted pursuant to Regulation (EC) No 1606/2002 as 

it applies in the European Union. 

In preparing these financial statements, the Directors are 

required to:

• 

• 

• 

 select suitable accounting policies and then apply 

them consistently;

 make judgements and accounting estimates that are 

reasonable and prudent;

 state whether they have been prepared in accordance 

with international accounting standards in conformity 

with the requirements of the Companies Act 2006, 

subject to any material departures disclosed and 

explained in the financial statements;

• 

 state whether they have been prepared in accordance 

with international financial reporting standards 

adopted pursuant to Regulation (EC) No 1606/2002 

as it applies in the European Union, subject to any 

Website publication

The Directors are responsible for ensuring the annual report 

and the financial statements are made available on a website. 

Financial statements are published on the Group’s website in 

accordance with legislation in the United Kingdom governing 

the preparation and dissemination of financial statements, which 

may vary from legislation in other jurisdictions. The maintenance 

and integrity of the Group’s website is the responsibility of the 

Directors. The Directors’ responsibility also extends to the ongoing 

integrity of the financial statements contained therein.

Directors’ responsibility statement  
pursuant to DTR4 

The Directors confirm to the best of their knowledge that:

• 

 the financial statements have been prepared in accordance 

with international financial reporting standards adopted 

pursuant to Regulation (EC) No 1606/2002 as it applies in the 

European Union and give a true and fair view of the assets, 

liabilities, financial position and profit and loss of the Group; 

and

• 

 the annual report includes a fair review of the development 

and performance of the business and the financial position of 

the Group, together with a description of the principal risks and 

uncertainties that they face.

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Auditors

material departures disclosed and explained in the 

In the case of each Director in office at the date the Directors’ 

financial statements;

report is approved:

• 

 prepare the financial statements on the going concern 

basis unless it is inappropriate to presume that the 

Group will continue in business; and

• 

 prepare a Directors’ report, a strategic report and 

• 

• 

 so far as the Director is aware, there is no relevant audit 

information of which the Group and Company’s auditors are 

unaware; and

 they have taken all the steps that they ought to have taken 

Directors’ remuneration report which comply with the 

as a Director in order to make themselves aware of any 

requirements of the Companies Act 2006.

relevant audit information and to establish that the Group and 

The Directors are responsible for keeping adequate accounting 

Company’s auditors are aware of that information. 

records that are sufficient to show and explain the Group’s 

A resolution to re-appoint BDO LLP as auditors to the Company 

transactions and disclose with reasonable accuracy at any time 

will be proposed at the upcoming annual general meeting. 

the financial position of the Group and enable them to ensure 

that the financial statements comply with the Companies Act 

2006 and, as regards the financial statements, article 4 of the 

IAS Regulation. 

By order of the Board

They are also responsible for safeguarding the assets of the 

Group and hence for taking reasonable steps for the prevention 

Law Debenture Corporate Services Limited 
Company Secretary

and detection of fraud and other irregularities. The Directors are 

25 February 2021

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Corporate governance report 

Corporate governance

Procedures are in place to enable independent professional 

advice to be taken by individual Directors at the Company’s 

The Directors are required to report on how the Company has 

expense. Appropriate insurance cover is in place in respect of legal 

applied the main and supporting principles in the UK Corporate 

action against the Directors.

Governance Code (the Code), and to confirm that it has complied 

with the Code’s provisions or, where this has not been the case, 

to provide an explanation. This report relates to the Code as 

published in July 2018, a copy of which may be obtained by visiting 

www.frc.org.uk. The FRC has recognised that the Board structure 

of investment companies such as Law Debenture, might affect the 

relevance of some of the provisions of the Code. The Company has 

therefore considered the provisions of the Code that are applicable 

to it as a FTSE 250 listed investment company. This corporate 

governance statement forms part of the Directors’ report and should 

be read in conjunction with the strategic report on pages 4 to 49.

The Board has concluded that, as demonstrated by the disclosures 

made throughout the Directors’ report, the Company has complied 

with all of the requirements applicable to it under the Code.

The Board – role, modus operandi  
and appraisal

The names and biographies of the Directors at the date of this 

report are on pages 50 and 51 of the annual report. Trish Houston 

was appointed as an Executive Director on 2 September 2020 and 

Katie Thorpe stepped down as CFO on 11 September 2020.

The Board is responsible for the overall strategy and management 

of the Group, setting investment strategy and ensuring that the 

The Board meets regularly throughout the year. The attendance 

records of the Directors (both at meetings of the Board and, where 

they are a member, meetings of Board Committees) are set out in 

the table below. There was also a strategy meeting in September 

2020, attended by all of the Directors, the Company’s corporate 

broker and certain senior executives.

Board Remuneration Audit and Risk Nomination

Number of 

meetings in 

the year

Meetings  

attended by:

D. Jackson

T. Houston*

R. Hingley

R. Laing

M. Bridgeman

T. Bond

C. Finn

17

17

8

16

16

16

14

16

6

—

—

6

6

5

5

6

8

—

—

—

8

8

8

8

5

—

—

5

5

5

4

5

* Trish Houston was appointed on 2 September 2020 and was present at all Board 

meetings on or after that date.

Company is operating in compliance with statutory and legal 

Whilst not members of the Committees, Denis Jackson and 

obligations. There is a formal schedule of matters specifically 

Trish Houston attend meetings at the invitation of the relevant 

reserved for Board decision, published on the Company’s website 

Committee. Similarly Robert Hingley’s attendance at Audit and 

(https://www.lawdebenture.com/investment-trust/shareholder-

Risk Committee meetings is by invitation only.

information/corporate-governance). Matters connected with 

strategy and management, structure and capital, financial 

reporting and control, the investment trust portfolio, contracts, 

shareholder communication, Board membership and other 

appointments, remuneration and corporate governance are 

reserved for the Board. 

During the second half of the year, the Directors participated in 

an external Board evaluation process, conducted by independent, 

external consultant, Value Alpha. Value Alpha provides no other 

services to the Company. Each Director was interviewed on 

a one-to-one, confidential basis, as were a number of senior 
stakeholders from the business. A cycle of quarterly Board and 

In discharging its responsibilities, the Board takes account of the 

Committee meetings was observed. The evaluation focused on 

Group’s purpose, value and culture, aiming to promote enhanced 

Board composition, including Directors’ skills, experience and 

value for shareholders in both capital and income terms. The 

behaviours, Board processes and decision-making mechanisms. 

Board sets a cultural tone that encourages openness, diversity and 

The findings of the evaluation were presented to and discussed 

attention to the needs and views of shareholders and those who 

with the Board in late November 2020.

transact with us through our IPS business.

The evaluation concluded that the Board is performing strongly 

The Chairman takes personal responsibility for leadership of 

and represents a healthy platform for the next stage of the 

the Board and ensures that Directors receive accurate, timely 

Board’s and Company’s evolution. Behaviours are appropriate, 

and clear information. He reviews channels for the provision of 

commitment is high and Board meetings are effective.

information with the company secretary at least annually.

The following actionable recommendations were made:

The Board operates as a collective decision-making forum. 

Individual Directors are required to scrutinise reports produced 

by the Executive Leadership team and are encouraged to debate 

issues in an open and constructive manner. If one or more Directors 

cannot support a consensus decision, a vote will be taken and the 

• 

• 

 increase investment by the Company in Director development;

 robust succession planning should be put in place for both 

the Executive and Non-Executive Directors, with the aim 

of ensuring an appropriate mix of skills in the medium and 

views of a dissenting Director recorded in the minutes.

longer-term;

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• 

• 

• 

 consider potential ways to enhance Board engagement with 

dates of appointment and have remained independent, having no 

investors;

previous connection with the Company or any of its subsidiaries.

 Board reports and management information should be 

Denis Jackson and Trish Houston, as Executive Directors, are not 

streamlined to reflect the changing nature of the business; and

independent.

 work should be undertaken to clarify and embed the vision, 

Robert Laing will remain the SID until the date of his retirement 

values, culture and behaviours required to shape the business 

and is available to shareholders who have concerns that cannot 

as it grows.

be addressed through the Chairman, CEO or COO. 

Actions against each of these recommendations is currently 

underway. The Board will continue to conduct an externally 

facilitated performance evaluation every three years and internal 

evaluations in the intervening years.

Based on the outcome of the evaluation and on the basis that they 

continued to make valuable contributions and exercise judgement 

and express opinions in an independent manner, the Nomination 

Committee has recommended the re-election and election of 
Directors, as set out in the Notice of AGM on pages 132 and 133.

Directors’ remuneration

Details of the Directors’ remuneration appear in the remuneration 

report on pages 67 to 82.

Board Committees

The Board has established Nomination, Audit and Risk and 

Remuneration Committees, to each of which it has delegated 

All Directors are submitted for annual re-election, subject to 

certain responsibilities. Each Committee has terms of reference, 

continued satisfactory performance, which is assessed as previously 

which are reviewed annually and published on the Company’s 

described. As mentioned in the Chairman’s statement, Robert 

website (www.lawdebenture.com/investment-trust/corporate-

Laing will not be standing for re-election at the upcoming AGM.

governance). Membership of the Committees is reviewed annually. 

There is no maximum number of terms that a Director may serve, 

other than the Chairman whose tenure is explained on page 58. 

The Company has established a diversity policy, described in the 

Nomination Committee’s report. 

The Board – independence

Taking account of the position of the Company as an investment 

trust, the Board is deliberately kept small and it believes this is in 

the best interests of shareholders. The Board is satisfied that its 

composition and size is sufficient to ensure that the requirements 

of the business can be met.

The membership of the Board and its Committees are fully 

compliant with Code stipulations.

At least half of the Board, excluding the Chairman, must be 

independent Non-Executive Directors (NEDs). The Board can 

The Board does not operate a management engagement 

Committee; the duties of such a Committee are undertaken 

confirm that as at the date of this report, excluding the Chairman, 

directly by the Board. 

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four of the six other Directors are independent NEDs. In assessing 

Directors’ independence, the Board takes into account their 

tenure on the Board, whether or not a Director is independent of 

management and any material business or other relationship that 

could affect or interfere with the exercise of objective judgement 

by the Director, or his/her ability to act in the best interests of the 
Group. As well as being satisfied that each Director dedicates 

sufficient time to Law Debenture, the Board is satisfied that none 

of the Directors are ‘overboarded’ (having five or more listed 

company roles). The contribution made by each Director to the 

Company’s and Group’s long-term success, is described on pages 

50 and 51 of the annual report.

The Chairman, Robert Hingley, was independent at appointment 

and continued to be independent throughout the period, in the 

view of the Board, having no current or previous connections with 

the Company or any of its subsidiaries. 

The Board is satisfied that Robert Hingley’s other commitments 

do not interfere with the discharge of his responsibilities to 

Law Debenture, and that he makes sufficient time available to 

discharge his duties as Chairman.

A summary of each Committee is set out below.

Nomination Committee

Members 
R. Hingley (Chairman) 

T. Bond 

M. Bridgeman 

C. Finn 

R. Laing 

Role
To keep under review the structure, size and composition of the 

Board and its Committees, to make recommendations to the 

Board about adjustments that are deemed necessary and to 

ensure effective succession planning in accordance with legal and 

corporate governance requirements.

Key duties
• 

 identification and nomination of suitable candidates to fill 

Similarly, the Board is satisfied that Robert Laing, Mark Bridgeman, 

Tim Bond and Claire Finn were independent at their respective 

vacancies, with particular regard for the need to develop a 

diverse pipeline of Board members and senior executives, for 

Board approval;

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Corporate governance report continued

• 

• 

• 

 succession planning (in particular of the Chairman and CEO);

 making recommendations for the election and re-election 

of Directors; and

 ensuring that the Board and its Committees are constituted 

to comply so far as practicable with the Code.

The Nomination Committee ensures that the Board has in 

place arrangements for orderly and transparent appointments 

to the Board. There are job descriptions in place for NEDs’ 

roles, and the Board has written terms and conditions for such 

appointments, which will be made available for inspection 

upon request to the Company Secretary, until the conclusion 

of the 2021 AGM. Particular care is taken to ensure that NEDs 

have sufficient time to commit to the duties expected of 

them and as necessary, diversity issues are considered. No 

new NED is appointed without first being interviewed by each 
existing NED and comfort is obtained in relation to their other 

commitments to ensure they have sufficient time to devote to 

the role.

All new Directors undergo an induction process, involving 

presentations by the CEO, COO, CFO, General Counsel, each 

of the Business Heads and meetings with the investment 

manager.

For the appointment of Trish Houston, the Committee 

identified potential candidates through a rigorous selection 

process against an agreed set of criteria.

The Committee is also responsible for considering the policy 

on the tenure of the Chairman of the Board. Robert Hingley 

was appointed to the Board in October 2017 and, in line with 

the policy on tenure and the recommendations of the Code, he 

will stand down after nine years although this period may be 

extended for a limited time to facilitate an effective handover. 

Accountability and audit, fair balanced 
and understandable reporting and 
going concern

The statement of Directors’ responsibilities in relation to the 

financial statements appears on page 55. The independent 

auditors’ report appears on pages 84 to 90. The Directors confirm 

that the Group and Company are a going concern as evidenced by 

the financial statements, which demonstrate a healthy position, 

taking into account all known and future anticipated liabilities, 

and the Group’s ability to meet those liabilities. The performance 

metrics of the Group remain strong. The trust has outperformed 

its benchmark by 87.3% over the last ten years and the IPS 

business has shown positive growth following the introduction 

of a new management team. There are no material uncertainties 

that call into question the Company’s ability to continue to be a 

going concern for at least 12 months from the date of approval 
of the financial statements. The Directors therefore consider it 

appropriate to adopt a going concern basis in preparing the 

financial statements.

The Audit and Risk Committee has concluded and the Board 

concurs, that the financial statements present a fair, balanced 

and understandable assessment of the financial position and 

prospects of the Company and the Group. The financial statements 

are reviewed by the Audit and Risk Committee, approved by the 

Board and signed by the Chairman and CEO. In the opinion of 

the Board, the annual report, taken as a whole is fair, balanced 

and understandable and provides the necessary information for 

shareholders to assess the Company’s and Group’s position and 

performance, business model and strategy.

Internal controls 

The framework of internal controls ensures that the Company 

The Board diversity policy states that, while the Board remains 

has sound risk management systems to enable it to operate 

small, it will endeavour to meet the requirements of the 

within the desired risk appetite. The following paragraphs provide 

Davies review in 2021. At the date of this report the Company 

a description of the main features of the internal control and 

is compliant with the recommendations under the Hampton-
Alexander review. 

The Committee’s approach to performance evaluation and the 

gender balance of those in senior management is set out at 

pages 56 and 57, respectively.

Audit and Risk and Remuneration 
Committees

Following best practice guidelines published by the Financial 

Reporting Council (FRC), the Audit and Risk and Remuneration 

Committee reports are published as separate sections of the 

annual report and can be found at pages 63 to 65 and 67 to 82, 

respectively.

risk management systems in relation to the financial reporting 
process, which fulfil the obligations of the FRC Guidance on Risk 

Management, Internal Control and Related Financial and Business 

Reporting and the FCA’s Disclosure Guidance and Transparency 

Rules. This section should be read in conjunction with the 

strategic report, which sets out how the Directors manage or 

mitigate the principal risks relating to the Company and Group’s 

business model. 

The Board monitors the effectiveness of internal controls on 

a continuous basis to ensure that internal control and risk 

mitigation is incorporated into the day to day management 

of the organisation, both directly through main Board general 

reviews and by the more specific work carried out by the Audit 

and Risk Committee. The annual internal audit programme and 

system of compliance checks have both been developed using 

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a risk-based methodology and an evaluation of the existing 

• 

 systematic reporting to the Board of matters relating 

process controls. Other mechanisms in place to monitor risk 

to litigation, insurance, pensions, taxation, accounting, 

include: 

• 

 Board review of the Group’s matrix of key risks and controls 

counterparty risk and cash management as well as legal, 

compliance and company secretarial issues; 

managed by the General Counsel, reporting to an Executive 

• 

 review of internal audit reports by the appropriate 

Risk Committee;

professional services company, Board and the Audit and Risk 

• 

 an internal audit function, which involves business 

Committee; 

departments and business wide processes (including overseas 

• 

 review of the internal controls of those services, such as 

offices) being subject to audit on a regular basis; 

investment management, which have been delegated to 

 testing by the General Counsel of the FCA regulated business 

systems and controls; 

third parties. This review was conducted during the initial 

contractual negotiations and on a regular basis, including 

annual discussions with the senior management and 

 testing by the General Counsel of the Company’s compliance 

compliance staff of Janus Henderson; 

with its AIFMD obligations; 

• 

 monitoring by the Board of the investment management 

 review of reports by the depositary and the sub-custodian; 

process, including the establishment and maintenance of 

 periodic reports to the Board by the General Counsel about 

legal and regulatory changes, and the steps that the Board 

must take to comply; and 

investment guidelines, receiving a report from the investment 

manager on a quarterly basis, the review of all transactions 

with the investment manager and regular reconciliations of 

the records of the Group with those of the depositary and 

 review of the reports produced by the external auditors on 

sub-custodian; and 

• 

• 

• 

• 

• 

their annual audit work.

The Board considers that the above measures constitute 

• 

 receipt of frequent and detailed reports about the 

performance of the IPS business, including the overseas 

continuing application of the FRC risk guidance and form an 

subsidiaries. 

important management tool in the monitoring and control of 

the Group’s operational risks. 

An important element of the overall controls remains a 

continuous review of the quality and effectiveness of internal 

financial controls of the Group. During the year, the Board 

requires that the Group maintains proper accounting records, 

so that it can rely on the financial information it receives to 

make appropriate business decisions and also that the Group’s 

The systems of internal financial control are designed to provide 

reasonable assurance against material misstatement or loss. 

By means of the procedures set out above, the Directors have 

established a robust process for identifying, evaluating and 

monitoring the effectiveness of the internal control systems for 

the period. This process has been in place throughout 2020 and 

will be reviewed by the Board on a regular basis. 

assets are safeguarded. This includes having data that allows the 

Arrangements are in place by which staff of the Group may, in 

Board to consider country and currency exposure and potential 

confidence, raise concerns under the Public Interest Disclosure 

impairment of assets (both financial and non-financial). 

Act 1998 about possible improprieties in matters of financial 

In November 2020 the Chairman of the Audit and Risk 

Committee and the Executive Risk Committee agreed a plan 
to refresh the Group’s risk management and internal audit 

framework. This will enhance the governance and oversight 

of the management of the Company’s principal risks. A risk 

and controls consultant was added during the year. A risk and 

compliance learning programme was rolled out to all staff on 

key topics and policies, including whistleblowing, anti-bribery 

and corruption and financial crime. A new management and 

incident reporting framework was also introduced.

Key elements of the systems of internal control continue to be: 

reporting or other matters. Whistleblowing capability has been 

enhanced as part of the changes made to the whistleblowing 

policy, with several senior colleagues undergoing specialist 

investigative training to manage reports as they come in. Any 

concerns which are raised will be subject to proportionate 

investigation, with appropriate follow up action as per the policy. 

There is a clearly defined reporting structure with colleagues 

having the option to raise any concerns with their line manager, 

the General Counsel and HR Manager or if those avenues are not 

appropriate, to the Chairman of the Audit and Risk Committee, 

who is the employee representative of the Board.

• 

• 

 regular qualitative self-assessment of the effectiveness of the 

individual controls maintained in the overall internal financial 

control framework; 

Information about share capital

The information that the Company is required to disclose about its 

share capital can be found in the Directors’ report (significant holders) 

 preparation by management of a comprehensive and detailed 

and AGM notice (total voting rights).

budget, involving annual Board approval and comparison at 

Board level of actual results with budgets and forecasts at 

every meeting; 

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Corporate governance report

Annual general meeting (AGM)

Details of the 2021 AGM are set out at pages 132 and 133.

The Board recognises the value of the AGM as an opportunity to 

communicate with shareholders and encourage their participation. 

Separate resolutions are put to the AGM on each substantially 

separate issue. The number of votes lodged for and against 

each resolution and the number of votes withheld is published 

immediately after the AGM to the London Stock Exchange and on 

the Company’s website. In line with governance recommendations, 

if 20% or more of the votes cast are against any Board resolution, the 

Company would announce what action it intended to take to consult 

shareholders’ views and provide a summary of the outcome. The 

Board confirms that none of the resolutions put to shareholders at the 

AGM in 2020 received votes against above 20% of the votes cast. The 

notice of the AGM and related papers are sent to shareholders at least 

20 business days before the meeting. Where requested by nominee 

holders, annual reports and related documentation are circulated to 

beneficial owners and the Company is happy for beneficial owners 

to attend the AGM and (where appropriate arrangements have been 

made with the nominee) to vote their shares in person. 

On 11 February 2021, at an Extraordinary General Meeting, 

amendments to the Company’s Articles of Association allowing 

shareholders to attend, speak and vote electronically at the 2021 

AGM and subsequent AGMs and general meetings, were approved. 

Accordingly, this year’s AGM will be held electronically to provide 

shareholders with the opportunity to participate by virtual means, 

given the ongoing Covid-19 related restrictions at the time of the 

approval of the Notice of AGM.

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Covid-19 Response

Our response to Covid-19: governance in action

During the global pandemic, there have been three main bodies responsible for managing and monitoring the impact of Covid-19 on 

the business, that have worked together to protect the interests of our key stakeholders.

Response teams

The Board
The Board has overseen the business’ Covid-19 response and it has 

worked with the Executive Leadership team to consider multiple 

scenarios associated with the pandemic, reviewed and considered 

potential response options and set expectations for the Group’s 

approach with consideration for each of the key stakeholders. The 

Board has asked the Executive Leadership team to keep them 

updated on the performance of both the investment portfolio 

and the IPS business, along with reviewing the implementation 

During the initial phase of ‘lockdown’, the Board met on a 

fortnightly basis to monitor the key performance indicators such 

as the performance of the portfolio and to provide guidance to 

the Executive Leadership team and the investment managers on 

the response to Covid-19. This enabled the investment managers 

to continue to pursue their strategy and take advantage of market 

conditions, being net investors in the depressed market. During 

this time our gearing peaked at 19%. The Executive Leadership 

team also sought to ensure that all suppliers received timely 

payments to minimise impact on their cashflows.

of the government’s guidelines to manage the pandemic. During 
the extended UK ‘lockdown’ in the Spring, after the World Health 

Our people

Organization declared the virus a pandemic, the Board had 

additional meetings by phone or online at least fortnightly to 

monitor the Group’s ongoing response. 

Executive Leadership team 
As the Executive Leadership team was responsible for the 

day-to-day operation of the business, they have overseen the 

business’ Covid-19 response under the guidance of, and as 

directed by, the Board. From reviewing the impact on revenue to 

ensuring the smooth transition to remote working, the Executive 

The safety and well-being of our people is of the utmost 

importance to the Board and the Executive Leadership team. 

We have sought to engage our staff to ensure that their needs 

were met. We ensured that there were regular communications 

both through ‘all staff’ calls, team meetings and email 

communications. We have made our offices available to those 

who have been unable to work from home, which has been 

adjusted to comply with the Government’s health and safety 

guidelines relating to Covid-19.

Leadership team continues to take operational decisions in line 

To assess whether we were meeting the needs of our staff, 

with the Board’s strategic approach, ensuring that the Board can 

a staff survey was commissioned, for which the results were 

remain focused on the long-term strategic issues and decisions 

overwhelmingly positive. The successful transition to remote 

associated with the pandemic. During the height of the pandemic 

working and the nature of the IPS business has meant that there 

as the Group transitioned into new ways of working, the Executive 

has been no requirement for the Group to furlough workers 

Leadership team worked closely with the IPS Business Heads.

or to make any demands on Government schemes to support 

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Executive Risk Committee
The Executive Risk Committee has representation from finance, 

operations, IT and legal, risk and compliance and has been 

responsible for providing oversight of the actions required to 
minimise the impact of the pandemic on business operations. It 

has worked with the Executive Leadership team to highlight any 

key risks emerging and ensured that appropriate measures have 

been implemented to safeguard the well-being of our people. 

During the height of the pandemic, the Executive Risk Committee 

met weekly.

Operations

On 23 March 2020, the Group transitioned to full remote 

working. Having monitored the situation closely the Group’s 

Chief Technology Officer, with support from the Executive Risk 

Committee, took steps to ensure that the business would be ready 

to make such a transition. This, coupled with the investment in 

modernising our IT infrastructure over the preceding eighteen 

months, meant that there was a limited but manageable impact 

on business operations.

business operations. 

Balance sheet resilience

The Board and the Executive Leadership team have actively 

monitored the cash position across the Group throughout the 

year, mindful of our commitment to pay quarterly dividends to 

shareholders. As of year-end, the Group held cash of £41.8m. In 

addition to this, the Company has secured an overdraft facility of 

£50m to protect against any significant fall of cash inflows. This 

has been declared as a post balance sheet event.

Revenue

In the early stages of the Covid-19 crisis, the potential impact of 

the crisis led to the reforecast of income for 2020, which has been 

monitored throughout the year. As reflected in our CEO’s review 

on pages 10 to 16, the IPS business has proved resilient, with 

revenues growing 8.5% during 2020. 

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Covid-19 Response continued

As with many equity based portfolios, the overall portfolio 

March 2020, the Company remained well within the requirements 

dividend income declined. Despite the backdrop of companies 

of the covenants and this remains the case, with no future looking 

cutting, postponing and cancelling dividends, the Board sought 

concerns identified through the forecast undertaken.

to provide certainty to our shareholders by not only paying the 

declared 2019 dividend but also confirming our intention to at 

least maintain the 2020 dividend at the 2019 level, utilising some 

of our reserves if required.

Structured finance covenant checks

The Company is required to monitor the debenture covenants on 

Actions taken

A snapshot of how the Board sought to comply with its duty 

under section 172 of the Companies Act 2006 during the year 

while navigating the macro environmental impact of Covid-19 and 

the expected long-term effects of those decisions is set out below 

a monthly basis. During the height of the turbulence within the 

in a case study.

equity markets, this was monitored daily by the CFO and reported 

up to the Board. Despite the sharp drop in asset prices during 

Other ways in which the Board adhered to its duties under section 

172 of the Companies Act 2006 are provided on page 47.

Covid-19 case study

The effects of Covid-19 on the operations of the Group are unprecedented, having resulted in the Board and the Executive 

Leadership team expediting new ways of operating and servicing clients. Remaining cognisant of its duty under section 172 of the 

Companies Act 2006, the following is a summary of actions taken since the start of the pandemic and the long-term solutions that 

have been implemented, ensuring the safety of our staff, business continuity, service excellence and ultimately, income growth. 

First response  
to Covid-19 working

Remote working

Safety and flexible working

• 

  Daily monitoring of the 

• 

  Daily and weekly 

• 

  100 Wood Street office adjusted and 

virus and UK Government’s 

communications provided 

consistently deep cleaned to comply with 

response.

by the Executive Leadership 

government guidelines on maintaining a 

• 

  Daily all staff e-mail 

communications were 

circulated with updates on the 

virus, Government guidance 

and the business’ response 

with regular invitations 

for employee queries 

and concerns.

• 

  Testing of the resilience of 

the IT infrastructure and 

team. Once stability was 

achieved, updates were 

provided periodically, 

including remarks from Non-

Executive directors during 

virtual staff presentations.

• 

  Regular reminders sent to 

staff on available channels 

to voice mental health and 

welfare concerns.

preparation for business-wide 

• 

  Covid-19 staff survey issued 

remote working. 

• 

  Frequent management 

meetings around Covid-19 and 

regular reports to the Board 

to gauge employees’ views 

on management’s response 

to the pandemic and any 

other concerns.

on the impact to the portfolio, 

• 

  Results of the staff survey 

staff and the IPS business.

were positive and were shared 

with the Board and with staff. 

Actions were taken to address 

any concerns raised.

Covid-secure environment for those returning 

to the office.

  The Company offered to cover the costs of 

Covid-19 testing kits for employees.

  Guidelines circulated to staff on precautions 

to be adopted where opting to work in 

the office.

  Office re-opened to staff who voluntarily 

chose to work in the office.

  Flexible working policy devised and released 

on a trial basis for possible long-term 

implementation.

• 

• 

• 

• 

• 

 100 Bishopsgate office fitted to accommodate 

social distancing and other required safety 

measures to permanently ensure the safety of 

all staff, clients, advisors, suppliers and visitors.

• 

 Implementation of paperless initiative 

across the Group where possible, reducing 

our carbon footprint and surfaces to aid in 

combating the spread of Covid-19.

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• 

• 

 Reviewing and reporting to the Board on significant financial 

reporting issues (if any) and judgements which those 

statements contain.

 Providing review and challenge where necessary over key areas 

of judgement, including the assumptions or qualifications in 

support of the going concern statement and the Company’s 

ongoing viability and risks thereto. 

Internal controls and risk management 
• 

 Reviewing the adequacy and effectiveness of the risk 

management and internal controls framework.

• 

 Advising the Board on the Company’s overall risk appetite, 

tolerance and strategy, and the principal and emerging risks 

the Company is willing to take in order to achieve its long-term 

strategy and objectives. 

• 

 Reviewing the inherent and emerging risks in the business and 

the system of internal controls necessary to monitor such risks. 

Where requested by the Board, provide them with assurance of 

the robustness of the management of principal risks. 

• 

 Reviewing regular reports from the General Counsel and 

Executive Risk Committee (which is responsible for day-to-day 

management of the operational risk within the Group), and 

other applicable persons on risk and internal control matters 

and the adequacy and effectiveness of the control functions. 

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Annual statement by the Chairman  
of the Audit and Risk Committee

I am pleased to present the Company’s Audit and Risk Committee 

report for the year ending 31 December 2020. 

The Committee was comprised at the year-end of Robert Laing, 

Tim Bond, Claire Finn and me. Robert Hingley, whilst not a 

member of the Committee, is invited to attend. 

During the year the Committee approved the new terms of 

reference to reflect more clearly that the Committee also 

considers risk-related matters as part of its role. 

Role and duties

The main function of the Audit and Risk Committee is to assist 

the Board in the management of the Company’s financial 

reporting structure, internal controls and risk management, 

external and internal audit and compliance functions. Our key 

duties are as follows: 

Financial reporting 
• 

 Monitoring the integrity of the financial statements including 

the annual and half-yearly reports, preliminary announcements 

and any other formal statements or announcements relating to 

the Company’s financial performance.

External audit 
• 

 Making recommendations to the Board on the appointment or 

reappointment of the external auditors.

• 

• 

 Monitoring the quality, independence and objectivity of 

the external auditors, their performance and agreeing 

their remuneration.

 Developing and implementing policy on the engagement (or 

not) of the external auditor for non-audit services. 

Internal audit 
• 

 Monitoring the effectiveness of the Head of Internal Audit’s 
work and overseeing the implementation of any corrective 

actions.

• 

 Approving the internal audit programme in the context of the 

Company’s overall risk management system and ensuring it is 

aligned to the key risks of the business. I have agreed a refresh 

of the risk and internal audit plan for next year to enhance risk 

management and internal controls across the Company and 

the Group.

• 

• 

 Ensuring internal audit has sufficient access to perform its 

function effectively and in accordance with relevant standards.

 Reviewing reports from the Head of Internal Audit and 

considering any major findings from their work and monitoring 

management’s responsiveness to Internal Audit’s findings 

and recommendations. 

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Compliance 
• 

 Reviewing regular reports on compliance matters and keeping 

• 

 Review of reports about reconciliations, procedures in place to 

prevent fraud and anti-bribery and corruption and anti-money 

under review the adequacy and effectiveness of the Company’s 

laundering. 

and the wider Group’s compliance reporting and obligations.

• 

 Reviewing regular reports from the Money Laundering 

Reporting Officer and the adequacy and effectiveness of the 

Company’s and the wider Group’s anti-money laundering 

systems and controls.

• 

 Reviewing the Company’s and wider Group’s procedures, 

systems and controls for ethical behaviour and the prevention 

of fraud, bribery and modern slavery and to receive reports on 

non-compliance (if any) and overseeing the implementation of 

any corrective actions.

Shortly after the year end, the Committee met with the external 

auditors to discuss the 2020 financial statements and the 

outcome of that discussion is set out below. 

Risk management, internal control  
and internal audit

The approach to risk management adopted by the Group is 

set out in the Principal Risks and Internal Controls section 

on page 39. The Board as a whole is responsible for the 

• 

 Reviewing the arrangements in place for Group staff, 

effectiveness of internal control mechanisms, but it is informed 

contractors and external parties in confidence to raise 

by more specific work carried out by the Audit and Risk 

concerns about possible improprieties in matters of financial 

Committee, which includes the initiation and oversight of 

reporting or other matters insofar as they may affect the 

any investigations that may be necessary to address control 

Group (whistleblowing). The Committee ensures that 

weaknesses or breaches, as identified. 

these arrangements allow proportionate and independent 

investigation of such matters and appropriate follow-up action.

As part of my duties as Committee Chairman, I met with the audit 

partner and also with the Chief Financial Officer, General Counsel 

and Company Secretary to discuss matters of significance. 

In particular, the Committee reviews the adequacy and 

effectiveness of the Group’s risk management systems and 

processes. The General Counsel reports through the Executive 

Risk Committee, but in line with good practice in this area, the 

Committee’s Terms of Reference give her the right to report 

directly to me on any specific matter of concern. The General 

The Committee considers that I have recent and relevant financial 

Counsel also provides quarterly reporting on risk matters to 

experience due to my extensive experience as a fund manager 

the Committee.

and from my executive management experience. Similarly, Tim 

Bond satisfies the requirement as an active fund manager. The 

Committee as a whole has competence relevant to the sector in 

which the Company operates. 

Principal activities of the Committee 

The internal auditor, who reports to me as Chairman of the Audit 

and Risk Committee, presents their annual audit programme to 

the Committee for approval each year and attends Committee 

meetings, presenting all of their reports including management’s 

actions in response to the findings and recommendations. The 

internal auditor has the right, should they wish, to meet separately 

with the Audit and Risk Committee to raise any matters of 

During the year, the Committee’s business included: 

concern that may arise (although they did not need to do so 

• 

 Consideration of the annual report and financial statements 

and of the half yearly report and statements including 
consideration of the final and interim dividends. 

• 

 Consideration of the principal risks and controls and 

general oversight of the Group’s internal control systems 

and procedures including in the context of reports by the 

Depositary, the Company’s obligations as an AIFM and 

the heads of business and functions with respect to the 

IPS business. 

• 

 Meetings with the external auditor to discuss the 2019 

financial statements and, in the fourth quarter, to plan 

the 2020 audit. These meetings included discussions on 

fees, auditor independence, key risks and developments in 

accounting standards.

• 

• 

 Review and approval of the internal audit programme.

 Consideration of all internal audit reports. 

during the year under report). 

The Committee is satisfied that the quality, experience and 
expertise of the internal auditor is appropriate for the business. 

Wilfred White retired in September 2020 and was replaced by 

Jocelyn Williamson.

Engagement with the FRC

During the second half of the year, we received a letter from the 

Financial Reporting Council Corporate Reporting Review team 

as part of its ongoing monitoring of UK corporate reporting. This 

letter informed us that it had carried out a review of our 2019 

Annual Report and Financial Statements, and that at this stage, 

the review had not raised any further questions or queries which 

required a substantive response. A small number of disclosure 

points were also noted as part of the review which require minor 

amendment and as a result, we have enhanced the relevant 

disclosures in our 2020 Annual Report and Financial Statements.

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Audit and Risk Committee report continued

The Financial Reporting Council (FRC) requested that it be 

No new significant issues arose during the course of the audit. As 

made clear the inherent limitations of the review; in particular 

reported in previous years, an area of consideration is that relating 

it noted in its letter that its review provides no assurance that 

to bad debt provisions.

the 2019 Annual Report and Financial Statements are correct in 

all material respects and that the FRC’s role is not to verify the 

information provided but to consider compliance with reporting 

requirements. The FRC also noted its review did not benefit from 

Management makes an estimate of a number of bad debt 

provisions for non-collection of fees and costs as part of the risk 

management and control framework.

detailed knowledge of the Group’s business or an understanding 

Other issues that arose included: the risk that portfolio 

of the underlying transactions entered into.

External auditors – assessing effectiveness

One of the most important functions of the Committee is to 

monitor the independence and objectivity of the auditors, their 

performance and effectiveness. The Committee achieves this 

by an annual formal meeting with the audit partner to plan 

that year’s audit. Part of that process requires the auditor to 
give the Committee written assessment of how the audit team 

identifies and manages the threats to its independence, along 

investments may not be beneficially owned or correctly valued; 

and that revenue is appropriately recognised. The Committee has 

received assurance on these matters from management. 

The Committee is satisfied that the judgements made by 

management are reasonable and that appropriate disclosures 

have been included in the accounts. Taken in its entirety, the 

Committee was able to conclude that the financial statements 

themselves and the annual report as a whole are fair, balanced 

and understandable and provide the necessary information for 

shareholders to assess the Company and Group’s position and 

performance, business model and strategy. That conclusion was 

with the description of the safeguards that it has in place to avoid 

reported to the Board.

Mark Bridgeman 
Chairman, Audit and Risk Committee

25 February 2021

such threats. This vital part of the audit process also enables 

the Committee to examine in detail the scope of the audit, 

ensuring that the auditor’s objectives meet the Committee’s own 

expectations, along with key audit and accounting matters to be 

considered that year.

At the conclusion of each audit, the Committee receives a 

presentation from the audit partner on the principal findings. 

This provides the opportunity for robust challenge, particularly 

in areas where management judgement has been required. The 

Committee will also give the auditors an opportunity, without the 

Executive Leadership team present, to comment on the quality 

and standard of the executive’s performance generally and during 

the audit. Similarly, the Committee will seek the views of the 

Executive Leadership team on the effectiveness and performance 

of the audit team. There were no matters of concern raised during 

the period under review.

Non-audit services

Non-audit services provided by the auditor are reviewed by the 

Committee to ensure that independence is maintained. Non-

audit fees are shown at note 3 to the accounts. The Committee’s 

policy is that non-audit work should be limited to those matters 

where the external auditor is most appropriately placed to carry 

out the work, unless there is a conflict of interest. Consequently, 

fees for non-audit services have historically been low and in the 

year under review were £9,000 (2019: £13,600).

Significant financial issues relating  
to the 2020 accounts

The Code requires us to describe any significant issues considered 

in relation to the financial statements and how those issues 

were addressed.

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Annual remuneration report

Part 1  Remuneration Committee Chairman’s annual statement

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As a result, 2020 was another encouraging year for our IPS 

business with revenue growth of 8.5%, an increase in profit before 

tax of 6.6% and an increase in earnings per share of 9.5%. This 

builds on the momentum of last year and is a positive reflection of 

the efforts of all our staff and the success of our new management 

team. Please refer to the Chairman’s statement on pages 4 and 

5 for further overview of the financial and operational highlights 

for 2020.

Towards the end of the year, we were pleased to announce 

the acquisition of the company secretarial services business of 

Konexo UK, a division of Eversheds Sutherland (International) LLP. 

We completed this acquisition in January and the successful 

integration of this business should generate approximately £2m 

of additional profit for the IPS business in 2021. 

Management changes

In May 2020, our CFO, Katie Thorpe, announced her intention 

to leave Law Debenture in October 2020. Following this 

announcement, the Board oversaw the restructuring of the 

Executive Leadership team and, on 2 September 2020, Trish 

Houston joined Law Debenture as COO, and was appointed as an 

Executive Director at the same time.

As part of the restructuring, the Executive Leadership team was 

expanded to include Hester Scotton, who was promoted to CFO 

in October 2020, and Kelly Stobbs, who was appointed as General 

Counsel on 2 June 2020.

Performance outcomes for 2020

Annual bonus outcomes for 2020
As indicated in last year’s report, the maximum annual bonus 

opportunity for directors was set at 100% of salary for 2020 and 

the performance measures were based 50% on financial targets 

with the remainder based on non-financial measures aligned to 
the strategic priorities of both the IPS business and the Company 

as a whole. The financial target was based on the percentage 

growth in IPS Profit before Tax (PBT) ranging on a straight line 

basis from 3% at threshold to 8% as a stretch target. This target 

has been set to reflect the impact that Covid-19 has had on 

market conditions. Management delivered well against this target 

achieving growth in IPS PBT of 6.6%. 

Dear Shareholder 

On behalf of the Board, I am pleased to present the Directors’ 

Remuneration Report for the year ending 31 December 2020. 

This year we have continued to work on enhancing the report to 
improve transparency and clarity for all stakeholders and maintain 

alignment with governance best practice.

Financial and operational highlights

2020 has been a challenging year for both our staff and our 

clients, with many having first-hand experience of the impact 

of Covid-19. As an organisation, we have been in the fortunate 

As mentioned previously the Company did not draw upon any of 

position that we have not had to draw upon any of the 

the Government Support Schemes or place any staff on furlough 

Government Support Schemes, nor have we had to place any of 

during the year and furthermore, has generated a share price total 

our staff on furlough. The Board is very grateful for all the hard 

return of 12.9% and a growth in NAV of 3.6% over the same period. 

work that the Executive Leadership team have put in to minimise 

In view of the positive outcome for the IPS business in what has 

the effects of the pandemic and to ensure that, despite the 

been a difficult year and the progress that has been made in 

constraints imposed by working from home and social distancing, 

achieving various strategic objectives, including the recruitment 

all our staff were able to continue to focus on delivering on our 

of new senior management, continuing the process of overhauling 

objectives of producing long-term capital growth and steadily 

the IT systems completely, the move to the new head office, as 

increasing income for our shareholders. 

well as their support in numerous meetings with shareholders, 

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Annual remuneration report continued

we have decided to award a bonus of 85% to the CEO and 85%, 

pro-rated, to the COO. The Committee determined that the 

Wider workforce considerations and fairness
The Committee has carefully considered remuneration 

annual bonus outcomes for 2020, based on the application of the 

arrangements across the Group. The Committee receives 

performance conditions, were in line with the overall performance 

information on wider workforce remuneration of our staff, ensuring 

of the business and have not applied their discretion in assessing 

they have a good understanding of the structure and application of 

the Executive Directors’ remuneration.

the reward policies throughout the Group. 

Implementation of the policy in 2021

Salary and benefits
The Committee has reviewed the performance of the Executive 

Directors during 2020. The Remuneration Committee will normally 

limit Executive Director salary increases to the level of increase for 

the wider workforce. With inflation, measured by CPI, in the UK at 

0.8%, pay increases across the organisation will only be awarded 

to those employees whose roles and responsibility have materially 

changed, during the course of 2020, or on an exceptional merit 
basis. To align with this, the Committee is proposing not to award 

a pay increase for the CEO and the COO. Their salaries will remain 

at £325,000 and £230,000 respectively. The Executive Directors’ 

pension contributions will continue to be aligned with the 

workforce at 12% of salary or cash equivalent.

Bonus
The maximum bonus opportunity will remain unchanged at 100% 

of salary for 2021, with 50% of performance measures based on IPS 

financial targets and with the remainder based on non-financial 

measures aligned to the current strategic priorities of both the IPS 

business and the Company as a whole. Further details are provided 

on page 75 of this report. The specific targets will be published 

together with the bonus outcome in the Annual Report on 

Remuneration for 2021. The deferral requirement for the Executive 

Directors is that half of any bonus earned above £100,000 will be 

deferred in shares for three years.

In line with the provisions of the 2018 UK Corporate Governance 

Code, various methods of communication (including presentations, 

email correspondence and availability for digital meetings) have 

been utilised by the Board and Executive Leadership team to raise 

employee awareness of the role and engagement with the Board 

more broadly. Work continues to look at the use and frequency of 

employee engagement surveys to ensure that our people have a 

forum to share their views. As part of this, we undertook a number 

of surveys to measure our response to Covid-19 with management 

receiving positive feedback from staff.

Conclusions

I will be stepping down as Non-Executive Director for Law 

Debenture, having served nine years on the Board. I will be handing 

over the role of Chair of the Remuneration Committe to Claire Finn 

from 7 April 2021. I hope that you have found my letter useful and the 

accompanying report informative and clear. Shareholders voted to 

approve the new Remuneration Policy at the AGM in April 2020 and 

we are not proposing any additional changes to the Remuneration 

Policy. We hope shareholders will be able to give their support to 

the resolution approving the Company’s remuneration report at the 

AGM in April 2021. I am grateful for the engagement and support 

provided by our shareholders and I will be available at the AGM to 

answer any questions in relation to this Remuneration Report. 

The Executive Directors will each receive LTIP awards of 100% 

of salary in 2021 which will vest based on 3-year IPS EPS targets 

Robert Laing  
Chairman, Remuneration Committee 

ranging from 4% p.a. growth at threshold (at which 25% of the 

25 February 2021

award vests) to 10% p.a. at stretch. The calculation of the base EPS 

targets for the LTIP will be adjusted to reflect the increase in profit 

expected from acquisition of the company secretarial business 

of Konexo UK referred to above. Given the internal business plan, 

analyst forecasts, the historically flat performance of the IPS 

business, and economic uncertainty, the Board believes that to 

sustain the proposed stretch level of earnings growth for three 

years would be exceptional. Any shares vesting must be held for 

a further two years. Further details are provided on page 72 of 

this report.

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REMUNERATION COMMITTEE MEMBERSHIP AND ACTIVITIES DURING 2020

Members

The members of the Committee who served during the year were:

R. Laing (Chairman)

R. Hingley

T. Bond

M. Bridgeman

C. Finn

Details of Committee meetings and attendance can be found on page 56.

Key activities of the Committee during the year included:

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

 determining 2020 annual bonus outcomes and payments;

 preparing the 2020 Directors’ Remuneration Report;

 determining salary adjustments for the Executive Directors and senior managers;

 setting performance objectives, annual bonus measures and targets for 2021;

 reviewing the operation of the annual bonus;

 benchmarking pay for the Executive Directors and senior managers;

 determining executive pay for 2020, including performance conditions for the LTIP awards in 2021;

 reviewing the workforce engagement mechanism;

 review of Remuneration Committee Terms of Reference; and

 reviewing Gender Pay Gap reporting.

Support provided to the Committee

PricewaterhouseCoopers LLP (PwC) was appointed by the Remuneration Committee on 14 February 2019 as independent 

adviser following a formal selection process. PwC is a founding member of the Remuneration Consultants Group and 

voluntarily operates under its Code of Conduct in its dealings with the Committee. PwC’s fees charged for the provision of 

independent advice to the Committee during the year were £48,000. Other than in relation to advice on remuneration, PwC 

provides support to the Company in relation to valuation of the IPS business and tax advice. The Committee is satisfied that 

PwC does not have connections with the Group that may impair their objectivity and independence.

During the year, the Committee also took advice from the CEO, whose attendance at Committee meetings was by invitation 

from the Chair, to advise on specific questions raised by the Committee and on matters relating to the performance and 

remuneration of the senior management team. No Director was present for any discussions that related directly to their 

own remuneration. 

Key responsibilities of the Committee

The Committee’s terms of reference are published on the Company’s website (www.lawdebenture.com/investment-trust/

corporate-governance). The key responsibilities of the Remuneration Committee are to: 

• 

• 

• 

• 

• 

• 

• 

• 

 determine the Remuneration Policy for Executive Directors and senior managers (including the Company Secretary) in 

compliance with legal and governance requirements and in the context of pay and conditions across the workforce, engaging 

with shareholders thereon; 

 determine the individual remuneration packages for Executive Directors and senior managers;

 approve the remuneration package of the Chairman;

 consider the design of, determine targets for and review outcomes for the annual bonus plan;

 determine the design of, quantum and performance conditions for long-term incentive plans;

 review workforce remuneration and related policies across the Company as a whole;

 review pension arrangements, service contracts and termination payments for Executive Directors; and

 approve the Directors’ Remuneration Report, ensuring compliance with legal and governance requirements.

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Part 2: Annual remuneration report 

Remuneration Policy table including 2020 outcomes and 2021 implementation*

SALARY AND BENEFITS

Purpose

To provide an appropriate level of salary and competitive benefits package to attract and retain 

individuals of the required calibre to successfully deliver the business strategy.

Operation and Opportunity

Salary 

Benefits

 individual skills, experience and performance;

all employee share plans, sickness pay, private 

Executive Directors are entitled to receive 

those benefits available to all Law Debenture 

employees generally, such as participation in 

medical insurance, life assurance cover, disability 

income plan, season ticket and parental leave. 

Benefits are not pensionable.

Other benefits may be introduced from time 

to time to ensure the benefits package is 
competitive and reflects the circumstances of 

the individual Director, for example relocation 

allowances. 

The Remuneration Committee may award non-

pensionable cash payments in lieu of one or more 

of these benefits.

Salary levels will relate to:

 the nature of the role;

• 

• 

• 

• 

• 

 performance of the business and the external 

economic conditions; 

 appropriate market data; and

 pay and conditions elsewhere in the Company.

There is no maximum salary under the policy. 

The Committee will consider salary increases 

for the senior management team and these 

will normally be in line with those of the wider 

workforce. Increases may be made above this 

level in certain circumstances, including but not 

limited to:

• 

• 

• 

 an increase in scale, scope or responsibility of 

the role;

 to ensure salaries remain market competitive; 

and

 where individuals have been recruited or 

promoted with salaries below the targeted 

policy level initially and have become more 

established in their role.

Performance Framework

None

Outcomes for 2020

Denis Jackson’s annual salary was £325k. He 

Trish Houston’s annual salary was £230k, pro-

also opted to participate in the Company health 

rated since her appointment on 2 September 

care plan. 

2020.

Implementation in 2021

Denis Jackson’s salary and benefits are 

Trish Houston’s salary and benefits are 

unchanged in 2021.

unchanged in 2021.

PENSION

Purpose

To provide funding for retirement at market competitive levels.

Operation and Opportunity

Executive Directors may receive pension contributions to a personal pension scheme and/or cash 

allowances in lieu of contributions.

Executive Directors (including current incumbents and new Directors) receive a contribution of 12% of 

salary in line with the contribution for the wider workforce.

Performance Framework

None

Outcomes for 2020

Denis Jackson received the cash allowance in lieu 

Trish Houston received the cash allowance in lieu 

of contributions equivalent of 12% of salary.

of contributions equivalent of 12% of salary.

Implementation in 2021

Denis Jackson’s pension contributions are 

Trish Houston’s pension contributions are 

unchanged in 2021.

unchanged in 2021.

* Katie Thorpe resigned as an Executive Director on 11 September 2020 and her remuneration in relation to 2020 is disclosed on page 77 of this report.

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ANNUAL BONUS

Purpose

To incentivise and reward the achievement of annual business objectives to enable successful 

implementation of the Group strategy, and to align the interests of Executive Directors with 

shareholders and support retention.

Operation and Opportunity

Performance measures, targets and weightings 

Maximum individual annual bonus opportunity is 

are set at the start of the year. 

100% of base salary. 

At the end of the year, the Committee determines 

The total aggregate annual bonus payment 

the extent to which the targets have been 

for Executive Directors is capped at 25% of the 

achieved and the resulting proportion of the 

general bonus pool for employees. 

maximum individual opportunity payable to 

Executive Directors. 

20% of the maximum will be payable for 

threshold performance and 50% of the 

Half of any bonus earned above £100,000 will 

maximum will be payable for on-target 

be deferred in shares for three years. Dividend 

performance, with full payment for stretch 

equivalents may accrue on deferred bonus 

performance. Payment increases on a straight-

awards and be paid on those shares which vest. 
The Plan contains malus and clawback provisions 

(see below for details).

line basis between threshold, target and stretch.

Performance Framework

Performance measures, targets and weightings are determined each year to reflect key business 

priorities and are measured over a period of one financial year. 

A minimum of 50% of the bonus is based on financial measures. The remainder is based on non-

financial measures aligned to the strategic priorities of the business and may also contain individual 

performance objectives.

Outcomes for 2020

Denis Jackson is recommended to receive a 85% 

Trish Houston is recommended to receive a 

bonus. The basis for the award is explained on 

85% bonus, pro-rated. The basis for the award is 

page 75.

explained on page 75.

Implementation in 2021

The maximum individual annual bonus 

The maximum individual annual bonus 

opportunity continues to be 100% of base salary.

opportunity continues to be 100% of base salary.

LTIP

Purpose

To drive sustained long-term performance that supports the creation of shareholder value, and to 

encourage and facilitate substantial long-term share ownership.

Operation and Opportunity

An award of conditional shares or nil cost-options 

Dividend equivalents may accrue on shares held 

may be granted annually. 

Awards vest after three years, subject to 

performance and continued employment. 
Following vesting, an additional two-year holding 

under the Plan and be paid on those shares 

which vest. These will be delivered in shares in 

line with the Investment Association Guidelines. 

Maximum award of 100% of salary. 25% of the 

period will apply (net of tax), such that shares are 

award will vest for threshold performance, with 

not released until five years from grant.

full vesting for stretch performance. 

Award levels and performance conditions are 

Vesting increases on a straightline basis between 

reviewed in advance of each grant to ensure they 

threshold and stretch.

remain appropriate. 

Performance Framework

At least half of the award will be based on financial measures, normally profit-based measures linked 

to the IPS business. The Committee has discretion to adjust the formulaic vesting outcome to reflect 

underlying Company performance.

Any adjustments or discretion applied by the Committee will be fully explained in the following year’s 

Remuneration Report.

Outcomes for 2020

Denis Jackson was awarded an LTIP of up to 100%, 

Trish Houston was not eligible for an LTIP award 

subject to meeting the performance conditions.

in 2020.

Implementation in 2021

Denis Jackson will be awarded an LTIP of up 

Trish Houston will be awarded an LTIP of up 

to 100%, subject to meeting the performance 

to 100%, subject to meeting the performance 

conditions.

conditions.

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Remuneration Policy table including 2020 outcomes and 2021 implementation continued 

SHAREHOLDING REQUIREMENTS

Purpose

To provide alignment between the interests of the Executive Directors and our other shareholders.

Operation and Opportunity

The Executive Directors are required to build and maintain a minimum shareholding of two times 

base salary. Executive Directors are required to retain 50% of the post-tax number of vested shares 

from the Company incentive plans until the minimum shareholding requirement is met and 

maintained. 

On cessation of employment, Executive Directors are required to retain their minimum shareholding 

requirement immediately prior to departure for two years. Where their actual shareholding at 

departure is below the minimum shareholding requirement, the Executive Director’s actual 

shareholding is required to be retained on the same terms and for the same periods.

In addition, the Company is using an Employee Benefit Trust or nominee accounts in which to hold 

shares to enable the post cessation requirements to be operated. 

Performance Framework

None.

Outcomes for 2020

Denis Jackson currently holds 43,855 shares 

Trish Houston currently holds 1,564 shares on her 

through his own account, deferred bonus, SAYE 

own account.

and the SIP.

Implementation in 2021

No changes to the policy.

No changes to the policy.

Remuneration principles 

In preparation for the review of our Directors’ remuneration 

Executive remuneration. From this, we have drawn a unifying set 

policy, the Committee reviewed the reward frameworks for 

of remuneration principles that apply equally to Executives, and to 

the wider workforce, alongside our more specific debates on 

employees at all levels of our workforce hierarchy. 

REMUNERATION PRINCIPLES 

Alignment

Our remuneration programmes will align with Law Debenture’s strategic priorities, long-term success 

and shareholders’ experience. 

Competitiveness

Total remuneration will be competitive but not extravagant for the role taking into account sector, 

complexity of responsibility and geography. When setting senior executive pay, we will consider both 

external pay relativity and wider workforce remuneration and conditions.

Pay for performance

There should be no reward for failure, but the Executives should be rewarded for the performance of 

the IPS business, which is central to Law Debenture’s business model and unique identity.

Discretion

The Committee has discretion to adjust the formulaic bonus and the LTIP outcomes to reflect 

underlying Company performance. Any adjustments or discretion applied by the Committee will be 

fully explained in the following year’s Directors’ Remuneration Report.

Consideration of shareholder views 

of Executive remuneration remains appropriate and commits to 

undertake a shareholder consultation in advance of any material 

The Remuneration Committee is committed to shareholder 

changes to the Remuneration Policy. 

dialogue and engages with shareholders as appropriate to address 

any remuneration issues that arise in relation to the Executive 

Directors. Any feedback provided is taken into account when 

Minor amendments

developing Executive remuneration arrangements, in addition 

The Committee may make minor amendments to the policy set 

to guidelines of investor bodies and shareholder views. The 

out above (for regulatory, exchange control, tax or administrative 

Committee continues to monitor trends and developments in 

purposes or to take account of a change in legislation) without 

corporate governance and market practice to ensure the structure 

obtaining shareholder approval for that amendment.

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Consideration of employment conditions 

In determining the remuneration arrangements for Executive 

Directors, the Committee considers pay and conditions of 

other employees across the IPS business and aims to ensure 

a consistent approach. To facilitate this, the Committee 

receives information on wider workforce remuneration, 

ensuring they have a good understanding of the structure 

and application of the reward policies throughout the 

Group. Mark Bridgeman has been appointed as the Non-

Executive Director with responsibility for engaging with 

the workforce. Since making that appointment, various 

methods of communication (including presentations, 

email correspondence and availability for meetings) have 

been utilised to raise employee awareness of the role and 

engagement with the Board more broadly. The Company has 

introduced a quarterly survey to assess employee satisfaction.

Differences in remuneration policy 
for Executive Directors compared with 
other employees 

The Company’s approach to annual salary reviews is consistent 

across the Group, with consideration given to the level of 

experience, responsibility, individual performance and salary 

levels in comparable companies. In terms of variable incentives, 

all employees are eligible to participate in an annual bonus 

scheme with business area-specific metrics and individual 

performance taken into account where appropriate. The 

maximum bonus opportunity of 100% of salary is consistent 

across all staff.

Senior managers may be eligible to participate in the LTIP with 

annual awards up to 100% of salary. Performance conditions 

are consistent for all participants, while award sizes vary by 

level. Specific cash incentives are also in place to motivate, 

reward and retain staff below Board level. When determining 

incentive outcomes, the Remuneration Committee may 

take account of the Executive Directors’ contribution to the 
investment trust strategy and performance, as well as the 

performance of the IPS business. For all other employees, 

performance is primarily based on the IPS business. All UK 

employees are eligible to participate in the Company’s SAYE 

and SIP schemes on the same terms.

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Illustration of total remuneration 
opportunity

£000

1,200

1,000

800

600

400

200

0

£000

1,200

1,000

800

600

400

200

0

Denis Jackson (CEO)

£371

100%

£696

23%
23%

53%

£1,021

32%

32%

36%

Minimum

On-Target

Maximum

Trish Houston (COO)

£265

100%

£495

23%
23%

54%

£725

32%

32%

37%

Minimum

On-Target

Maximum

£1,184

14%

27%

27%

31%

Maximum
with 50%
share price
appreciation

£840

14%
27%

27%

32%

Maximum
with 50%
share price
appreciation

Fixed

Annual Bonus

LTIP

Share price appreciation

ELEMENT

Total fixed pay

ASSUMPTIONS

Base salary:  
CEO £325,000,  

COO £230,000.

Pension:  
12% of salary or cash equivalent.

Benefits:  
As disclosed in single figure table 
on page 77.

Annual bonus

Minimum: No payout.

LTIP

Share price growth

On-target: 50% of maximum  

(50% of salary).

Maximum: 100% of maximum 

(100% of salary).

Minimum: No vesting.

On-target: 50% of maximum  

(50% of salary).

Maximum: 100% of maximum 

(100% of salary).

Impact of 50% share price 

appreciation on maximum 

remuneration over three years.

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Performance measures selection for the annual bonus

Performance Measures used under the annual bonus are selected annually to reflect the Group’s main short and long-term objectives and 

reflect both financial and non-financial priorities. For Executive Directors, performance measures in incentives will focus predominantly on 

the profitability of the IPS business which is central to Law Debenture’s business model and unique identity and is the area of the business 

fully within management’s control. The performance targets are set to be stretching but achievable, taking into account a range of internal 

and external reference points and having regard to the particular strategic priorities and economic environment. 

Executive Directors’ strategic objectives are linked to the delivery of Law Debenture’s strategic priorities. By their nature, some objectives 

require a more subjective assessment than others and this is done by the Committee following the input from the wider Board and other 

Board Committees as appropriate.

STRATEGIC OBJECTIVES

Description

Weighting

IPS financial 
performance

The Remuneration Committee reviews a number of key financial metrics when assessing 

50%

the Executive Directors’ delivery against financial performance targets. The metric 

used for 2020 was profit before tax. The Executive Directors’ awards are based on the 

performance against agreed thresholds, which can be found in the table below.

Market standing

Engagement with investors, potential investors, market analysts and the media is 

20%

considered to be beneficial to our shareholders as it raises awareness of the unique 

investment proposition which is offered by Law Debenture. The Remuneration 

Committee believe that the efforts made by the Executive Directors to further enhance 

the reputation of the Group should be rewarded.

Operational resilience, 
business strategy and 
leadership

The success of the IPS business is dependent on the effective leadership and 

30%

implementation of the right strategy to ensure our people can provide excellent service 

to our clients regardless of the external challenges the business may face. This includes a 

robust business continuity plan supported by the right technology, a well embeded risk 

management framework and high calibre people. The Remuneration Committee recognise 

the importance of this and reflect this in the award made to our Executive Directors.

MEASURE

For 2020 the maximum bonus opportunity for the Executive Directors was 100% of salary. Performance conditions were based 50% on 

financial metrics and 50% on strategic metrics. Details of the specific measures, weightings, targets and outcome achieved are set out below:

Measure

IPS financial performance - PBT

Market standing

Operational resilience, business strategy and leadership

Total

Weighting

Threshold
(0% of max.)

Target 
(50% of max.)

Maximum
(100% of max.)

50%

20%

30%

100%

3%

4%

8%

Further details set out below

Further details set out below

Actual

6.6%

Long Term Incentive Plan

The first award under the new LTIP was granted to the CEO in 2020 at a level of 100% of salary. An award of 100% was also made to Katie 

Thorpe, CFO, but this lapsed after her resignation from the Company. The award will vest after three years based on IPS EPS performance, and 

any vested shares (net of tax) will be subject to a further two-year holding period. The performance targets are as follows:

3-year CAGR (p.a.)

Below threshold

Threshold

Stretch

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% vesting

IPS EPS 3-year CAGR (p.a.)

0%

25%

100%

Less than 4%

4%

10%

Annual remuneration report continued

For 2021 it is proposed that, both the Executive Directors will be granted LTIPs at the level of 100% of salary, with the same performance 

conditions. The 2021 LTIP will have the base year performance adjusted to reflect the additional EPS arising from the acquisition of the 

company secretarial services business.

2020 PERFORMANCE AND PAY OUTCOMES

Financial performance

The IPS business delivered PBT growth of 6.5%.

In light of the economic impact of Covid-19, the Remuneration Committee applied PBT growth targets of 3%-8%, resulting in an 

award of 39% in relation to financial performance.

Non-financial performance

The Remuneration Committee gave careful consideration to the delivery of non-financial targets during 2020. In challenging 

conditions, the Executive Directors oversaw:

•  a successful office move to significantly enhanced premises;

•  recruitment of new, high-calibre senior staff and the reshape of the Executive Leadership team;

•  acquisition of the company secretarial services business from Eversheds Sutherland (International) LLP;

• 

 the response to the Covid-19 pandemic by ensuring we had a robust business continuity plan in place to allow us 

to continue to service the needs of our clients;

•  effectively moved immediately to home working with the introduction of national ‘lockdown’ in March 2020;

• 

improved market standing through positive media coverage, meetings with brokers and potential investors; and

•  the implementation of a new risk management framework as detailed on pages 39 to 45 of the annual report. 

As a result of this, the Executive Directors were awarded 46% in relation to non-financial targets.

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Total remuneration 2020

Denis Jackson
Chief Executive Officer

    Salary and benefits 50%
    Retirement benefits 6%
    Annual bonus 44%
    Performance Shares 0%*

Trish Houston
Chief Operating Officer

    Salary and benefits 51%
    Retirement benefits 6%
    Annual bonus 43%
    Performance Shares 0%*

* No Long-Term incentives or scheme interests vested in 2020 for either the CEO or COO.

Share ownership

Shareholding is a key means by which the interests of Executive Directors are aligned with those of shareholders. As at 

31 December 2020 neither Director had holdings in Law Debenture which exceeded our shareholding policy requirement of two 

times salary.

Denis Jackson1
Denis Jackson
Chief Executive Officer
Chief Executive Officer

£271k

Trish Houston
Trish Houston
Chief Operating Officer
Chief Operating Officer

£10k

  Actual 

  Total Policy Requirement 

Current holdings: 43,855 shares2 
Two times salary, 94,203 shares  
Total share value3 of £650k

Current holdings: 1,564 shares  

Two times salary, 66,667 shares 
Total share value3 of £460k

1   D. Jackson has 117,400 shares vesting in 1-4 years time subject to a service condition but not a performance condition. 

2  Includes shares held in the deferred bonus scheme.

3  Calculated based on a close price of 690p as at 31 December 2020.

The value of the shareholdings disclosed have been calculated using the close price at the time of acquisition of the shares. For 

these purposes, shares held in the deferred bonus scheme, the SIP and SAYE as at 31 December 2020 have been included as there 

are no performance conditions to be met. The LTIP awards have not been factored in.

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How do we safeguard against payments for failure?

SAFEGUARDING REQUIREMENTS

Performance based pay

A significant portion of remuneration varies with performance – where performance targets are not 

achieved, lower or no payments will be made under the plans.

Discretion

The Committee will operate all incentive plans 

• 

 adjustment of awards in certain 

according to the rules and discretions contained 

circumstances, e.g. changes in capital 

therein to ensure that the implementation of 

structure, demerger, special dividend, 

the Remuneration Policy is fair, both to the 

distribution or any other corporate event 

individual Director and to the shareholders. The 

which may affect the current or future value 

discretions cover aspects such as: 

of an award;

•  selection of participants; 

• 

 adjustment of performance conditions in 

• 

• 

• 

• 

• 

• 

 timing of grant and vesting of awards;

 size of awards (subject to the Policy limits); 

 choice of measures, weightings and targets;

 determining level of payout or vesting based 

exceptional circumstances provided the new 

targets are fair and reasonable and neither 

materially more or less challenging than the 
original targets; and 

• 

 application of malus and/or clawback. 

on an assessment of performance; 

Any such use of discretion will be fully disclosed 

 settlement of awards in cash or shares; 

 treatment of awards on termination of 

employment and change of control; 

in the subsequent annual report and may, as 

appropriate, be the subject of consultation with 

the Company’s shareholders.

Malus and Clawback

Malus is the adjustment of deferred annual 

The circumstances in which malus and clawback 

bonus awards or unvested LTIP awards, because 

could apply are as follows:

of the occurrence of one or more circumstances. 

The adjustment may result in the value being 

reduced to nil.

Clawback is the recovery of cash payments 

made under the annual bonus, deferred annual 

bonus award or vested LTIP awards as a result 

of the occurrence of one or more circumstances 

listed. Clawback may apply to all or part of a 

participant’s payment or award and may be 

effected, among other means, by requiring the 

transfer of shares, payment of cash or reduction 

of awards or bonuses.

• 

• 

• 

• 

• 

 gross misconduct; 

 misstatement of the financial results;

 error in reporting or calculation; 

 serious reputational damage; or

 corporate failure. 

Malus applies to deferred annual bonus awards 

and unvested LTIP awards up to the date 

of vesting. 

Clawback applies to cash annual bonus 

payments and vested LTIP awards for up to two 

years from payment or vesting. 

Annual bonus payments and LTIP awards are 

subject to malus and clawback for up to two 

years from payment of the bonus or vesting 

of shares.

Payments for loss of office

There were no payments to former Directors for loss of office.

Payments to past Directors

There were no payments to past directors during the year.

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Single total figure of remuneration (audited)

Denis Jackson

Trish Houston1

Katie Thorpe2

Year ended

Salary
£000

Benefits
£000

Bonus
£000

LTIP
£000

Pension
£000

2020

2019

2020

2019

2020

2019

325

315

77

N/A

180

225

4

4

—

N/A

3

3

275

287

65

N/A

—

205

—

—

—

—

—

—

39

38

9

N/A

22

25

Total
£000

643

644

151

N/A

205

458

Total
Fixed
£000

368

357

86

N/A

205

253

Total 
Variable
£000

275

287

65

N/A

—

205

1  Trish Houston joined the Board as COO on 2 September 2020..

2  Katie Thorpe resigned from the Board on 11 September 2020 and left the Company in October 2020.

Executive Directors’ shareholdings (audited)

The table below shows the interests of the Executive Directors and connected persons in shares (owned outright or vested) as at 

31 December 2020. There have been no changes in Directors’ interests in the period between 31 December 2020 and 25 February 2021. 

Outstanding scheme interests

Shares owned 
outright

Unvested 
shares not 
subject to 
performance3

Unvested 
options 
not subject to 
performance4

Unvested 
options 
subject to 
performance5

Vested but 
unexercised 
share options

Total scheme 
interests

Shareholding 
guideline
(% of salary)

Current 
shareholding 
(% of salary)6

Guideline 
met

Denis Jackson

Trish Houston1

Katie Thorpe2

2,948

1,564

1,767

35,342

5,565

70,210

—

18,257

—

2,475

—

—

—

—

—

114,065

1,564

22,499

200%

200%

N/A

18.1%

4.7%

N/A

No

No

N/A

1  Trish Houston joined the Board as an Executive Director with effect from 2 September 2020.

2  Katie Thorpe resigned from the Board as an Executive Director with effect from 11 September 2020.

3  Includes deferred bonus awards granted under the Deferred Share Plan.

4  Includes options awarded under Save As You Earn Share Save Plan.

5  Includes options awarded under the LTIP.

6  Based on a share price on 31 December 2020 of 690p. Shares owned outright have been included.

Executive Directors’ interests in shares and option plans (audited)

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Interests 
held at 
1 January 
2020

Granted 
in the 
year

Date of 
grant

Market 
price at 
grant

Vested 
in the 
year

Lapsed / 
forfeited 
in the 
year

Exercised  
in the  
year

Market 
price at 
date of 
exercise

Interests 
held at 
31 December 
2020

Vesting / 
first  
exercise 
date

Exercise 
price* 

Denis Jackson

Scheme

DSP1

DSP2

DSP3

LTIP4

SAYE5

3,079

196†

02.03.18 572.00p

16,662

1,020†

11.03.19 582.00p

— 17,333†

13.03.20 587.19p

— 70,210 07.04.20 462.90p

—

5,565

26.08.20 539.00p

—

—

—

—

—

—

—

—

—

—

— 572.00p

— 582.00p

—

587.19p

— 462.90p

— 539.00p

n/a

n/a

n/a

n/a

n/a

3,275 01.03.21

17,682

11.03.22

17,333

13.03.23

70,210 07.04.23

5,565 26.08.25

114,065

Total

19,741

94,324

1  Deferred Share Plan 2018 (share grant price is based on market close on the date of the grant).

2  Deferred Share Plan 2019 (share grant price is based on market close on the date of the grant).

3  Deferred Share Plan 2020 (share grant price is based on market close on the date of the grant).

4   Long Term Incentive Plan 2020 (price at grant is calculated based on a 5 day average close price up to and including the day before the date of grant). Details of performance conditions 

and targets can be found on page 74.

5  Save As You Earn Save Plan 2020 (share grant price is based on market close on the date of the grant).

* Exercise price is based on market price at grant.
† Includes dividend reinvestment.

Trish Houston does not currently hold options or shares in any of the Company’s employee share schemes.

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Percentage change in Director remuneration

The table below shows the percentage change in Director remuneration, comprising salary, taxable benefits and annual bonus, and 

comparable data for the average of all UK employees within the Company. 

Denis Jackson (CEO)

Trish Houston (COO)1

Katie Thorpe (CFO)2

Robert Hingley (NED)

Robert Laing (NED)

Mark Bridgeman (NED)

Tim Bond (NED)

Claire Finn (NED)

All other Employees (excluding directors)3

1  Trish Houston was appointed to the Board on 2 September 2020 

Salary
2020

Taxable benefits 
2020

Annual bonus 
2020

3%

N/A

6%

3%

3%

3%

3%

3%

3%

3%

N/A

6%

0%

0%

0%

0%

0%

3%

-4%

N/A

N/A

0%

0%

0%

0%

0%

11%

2  Katie Thorpe resigned from the Board on 11 September 2020 and left Law Debenture in October 2020

3  For the purposes of this table, all other employees excluding Directors have been taken to mean employees of LDC Trust Management Limited.

Relative importance of spend on pay 

The chart below shows the Company’s actual expenditure on shareholder distributions (including dividends and share buybacks) and total 

employee pay expenditure for the financial years ended 31 December 2018, 31 December 2019 and 31 December 2020.

Total employee pay expenditure1

Total distributed to shareholders2

2018  
£000

13,964

22,339

2019 
£000

14,709

30,778

2020 
£000

16,156

32,572

% change

9.8%

5.8%

1  Total remuneration includes bonuses, employers’ NI and pension costs and is the figure reported at note 3 of the accounts less remuneration of Non-Executive Directors.

2  Amounts distributed to shareholders are the totals of the final and interim dividends in respect of that year. There were no other distributions.

The dividend payment structure was changed during 2020 to include three interim and one final dividend to be paid to shareholders as 

explained in the Chairman’s statement on pages 4 and 5. The average number of employees has increased from 133 in 2019 to 165 in 2020, 

which has led to an increase in employee pay expenditure. The increase also includes a discretionary increase in individuals’ remuneration. 

Distribution to shareholders has been subject to an increase for the current year as explained in the Chairman’s statement on pages 4 

and 5. 

Historical remuneration and TSR chart

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Incumbent

C. Banszky C. Banszky C. Banszky C. Banszky C. Banszky

CEO single figure of total 

remuneration (£000)

602.7

636.9

636.9

690.7

677.5

Annual bonus and deferred bonus 

awarded (against maximum %)

75.0% 70.0%

72.1% 62.0% 100.0%

M. Adams1 T. Fullwood2

C. Banszky M. Adams

180.5

757.8

142.2

344.1

65.1% 100.0%

0.0%

0.0%

D. Jackson3 D. Jackson3 D. Jackson3

611.2

643.4

643.0

100.0% 90.9%

85.0%

1  C. Banszky stepped down as CEO on 31 August and was succeeded by M. Adams on the same date following his appointment to the Board on 4 August.

2  T. Fullwood was appointed interim Chief Executive Officer from 22 October for a fixed term until retirement at 1 January 2018.

3  D. Jackson was appointed as CEO on 1 January 2018. 

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Total Shareholder Return (TSR) chart and historical remuneration 

The graph below compares the value of £1,000 invested in Law Debenture’s shares, including reinvested dividends, with the FTSE All-Share 

Total Return Index over the last ten years. This index was selected because it is the index adopted as Law Debenture’s benchmark. 

£3,000

£2,800

£2,600

£2,400

£2,200

£2,000

£1,800

£1,600

£1,400

£1,200

£1,000

£800

£600

Notes

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Law Debenture share price total return, assuming 
the investment of £1,000 on 31 December 2010 and the 
reinvestment of all dividends (excluding dealing expenses)

FTSE All-Share Index Total Return assuming notional 
investment of £1,000 into the index on 31 December 2010 and 
the reinvestment of all income (excluding dealing expenses)

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1   The graph shows the total shareholder return of a nominal holding of £1,000 of Law Debenture’s shares measured against the total shareholder return of a nominal holding of £1,000 

invested in the FTSE All-Share Index over a 10 year period.

2  Dividends have been reinvested.

3   FTSE All-Share Index is chosen as the comparator in this table because that is the index against which, historically, the Company has reported the performance of the investment 

trust portfolio.

External appointments

It is the Board’s policy to allow the Executive Directors to take up one non-executive position on the board of another company, subject 

to the prior approval of the Board. Any fee earned in relation to outside appointments is retained by the Executive Director. During 2020, 

there were no external appointments held by the Executive Directors.

Recruitment policy

When determining the remuneration arrangements of a new appointment to the Board, the Committee will seek to apply the following 

principles:

• 

• 

 although we operate in a competitive market for talent, we are mindful to pay no more than is necessary to attract and retain high-

quality talent; and

 the Committee will appoint new Executive Directors with a package that is in line with the remuneration policy in place at the time. In 

particular, the maximum level of variable remuneration will be in line with the limits set out in the policy table on pages 72 and 73.

Service contracts

Executive Directors’ service contracts may be terminated by not less than six months’ notice given in writing by either party to the 

contract, with no contractual provisions for compensation payable on early termination of contract. The Directors are subject to annual 

re-election at the AGM. Executive Directors’ service contracts are available for inspection at the Company’s registered office, subject to 

Covid-19 restrictions.

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Termination Policy

Executive Directors will be entitled to receive salary and benefits during the notice period, which may be paid ‘in lieu’ of all or part of any 

period of notice. Payments may be made as either a lump sum or in equal monthly instalments until the end of the notice period at the 

discretion of the Company and Executive Directors will be expected to mitigate their loss. 

The Committee will seek to ensure that there are no unjustified payments for failure. There are no entitlements to payments of any sort 

in the event that for cause an Executive Director’s employment is summarily terminated. In the event that an Executive Director is given 

notice of termination of employment within twelve months of any change in control of the Company, he/she will be given not less than 

twelve month’s written notice and the same arrangements for receiving salary and benefits during this period will apply as described 

above.

The Committee may authorise payments for statutory entitlements in the event of termination, reasonable settlement of potential legal 

claims, and payment of reasonable reimbursement of professional fees in connection with such agreements.

PLAN

GOOD LEAVERS1

ALL OTHER LEAVERS

CHANGE OF CONTROL

• 

• 

• 

• 

Annual bonus

• 

 Typically paid at the same time 

as continuing employees, to the 

extent that the performance 

conditions are achieved with 

pro-rating for the proportion of 

the financial year served, unless 

the Committee determines 

otherwise.

• 

 Deferred bonus awards will 

continue until the normal vesting 

date or may vest earlier at the 

discretion of the Committee.

LTIP

• 

 Unvested LTIP awards will 

typically vest on the normal 

vesting date, to the extent that 

the performance conditions are 

achieved with pro-rating for the 

proportion of the financial year 

served, unless the Committee 

determines otherwise.

• 

 Vested awards will remain 

subject to any holding period.

 No bonus payable.

• 

 Normally paid immediately on 

 Unvested deferred bonus 

awards lapse.

the effective date of change 

of control, subject to the 

achievement of the performance 

conditions and pro-rated for 

the proportion of the year 

served to the date of change of 

control, unless the Committee 

determines otherwise.

• 

 Deferred bonus awards vest 

immediately in full on the 

effective date of change of 

control.

 Unvested awards lapse.

• 

 Unvested LTIP awards will 

 Vested awards will remain 

subject to any holding period.

typically vest immediately in 

full on the effective date of 

change of control, subject to the 

achievement of the performance 

conditions and pro-rated for 

the proportion of the year 

served to the date of change of 

control, unless the Committee 

determines otherwise.

• 

 The holding period applicable to 

any awards will end at the time of 

change in control.

• 

 Alternatively, awards may be 

exchanged for new equivalent 

awards in the acquiring company. 

1    The Committee has discretion to determine that an Executive Director is a good leaver. It is the Committee’s intention to only use this discretion in circumstances where there is an appropriate 

business case which will be explained in full to shareholders. A good leaver is typically defined as an employee who ceases to hold employment by reason of: death, injury, ill-health or disability; 

retirement with the agreement of the Group; redundancy; the participant’s employing Company being transferred to an entity which is not a Group member; transfer of undertaking; or any 

other reason at the Committee’s discretion. 

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Policy for Chairman and Non-Executive Directors

The Non-Executive Directors, including the Chairman, do not have service contracts and are appointed for an indefinite term. Non-Executive 

Directors will not be entitled to compensation on termination of their directorship, no matter what the reason for termination. The Directors 

are subject to annual re-election at the AGM. Non-Executive Directors’ letters of appointment are available to view at the Company’s 

registered office.

Non-Executive Directors do not receive benefits from the Company and they are not eligible to join the Company’s pension scheme 

or participate in any bonus or share incentive plans. Where specific cash or share arrangements are delivered to the Chairman or Non-

Executive Directors, these will not include share options or any other performance related elements. Any reasonable expenses that they 

incur in the furtherance of their duties are reimbursed by the Company (including any tax liability thereon). 

PURPOSE AND LINK TO STRATEGY

OPERATION

FEE LEVELS

To attract and retain Non-Executive 

The Chairman is paid a single annual all-

Fee increases are typically expected to be 

Directors of the required calibre by 

inclusive fee for all Board responsibilities.

in line with wider employee rises. 

offering market competitive fees.

Non-Executive Directors receive a basic annual 
Board fee. Additional fees may be payable 

In exceptional circumstances (including, 
but not limited to, material misalignment 

for additional Board responsibilities such as 

with the market or a change in the 

Chairmanship or Membership of a Committee, 

complexity, responsibility or time 

or the role of Senior Independent Director.

commitment required to fulfil the role) the 

The Chairman’s fee is determined by the 

Committee, and fees to Non-Executive Directors 

are determined by the Board. Fees are reviewed 

Board may make appropriate adjustments 

to fee levels to ensure they remain market 

competitive and fair to the Director.

periodically, considering time commitment, 

The maximum annual aggregate fee for 

scope and responsibilities, and appropriate 

all Non-Executive Directors will be within 

market data.

the limit set out in the Company’s Articles 

Expenses incurred in the performance of 

non-executive duties for the Company may be 

reimbursed or paid for directly by the Company, 

including any tax due thereon. 

of Association.

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Non-Executive Directors’ shareholdings (audited)

The table below shows the interests of the Non-Executive Directors and connected persons in shares (owned outright or vested) as at 

31 December 2020. There have been no changes in Directors’ interests in the period between 31 December 2020 and 25 February 2021. 

Robert Hingley

Robert Laing

Mark Bridgeman1

Tim Bond

Claire Finn

1  Interests of connected persons in addition to Mark Bridgeman's beneficial holding – 25,620.

Shares owned outright

4,870

12,300

4,513

—

—

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Single total figure of remuneration for Non-Executive Directors (audited)

The table below sets out the single figure for the total remuneration received by each Non-Executive Director for the year ended 

31 December 2020 and the prior period:

Non-Executive Directors

Robert Hingley

Robert Laing

Mark Bridgeman

Tim Bond

Claire Finn

Salary/fees

Total

£87,550

£85,000

50,985

£54,153

56,650

£51,940

£45,320

£44,000

£46,237

£13,750

£87,550

£85,000

50,985

£54,153

56,650

£51,940

£45,320

£44,000

£46,237

£13,750

2020

2019

2020

2019

2020

2019

2020

2019

2020

2019*

*Claire Finn’s remuneration for 2020 includes an extra payment which relates to 2019.

Non-Executive Director fees

For 2021, the fees for the Chairman and Non-Executive Directors have been maintained in line with the wider workforce: 

Fee

Chairman fee

Non-Executive Director base fee

Additional fee for Chairman of Audit Committee

Additional fee for Chairman of Remuneration Committee 

Additional fee for oversight of workforce engagement

Fees effective  
1 January 2021

Fees effective  
1 January 2020

% change

£87,550

£45,320

£5,665

£5,665

£5,665

£87,550

£45,320

£5,665

£5,665

£5,665

0.0

0.0

0.0

0.0

0.0

Statement of shareholder voting at the Company’s AGM

The table below sets out the results of the most recent shareholder votes on the Policy Report and the Annual Report on Remuneration at 

the AGM on 7 April 2020.

Policy Report

2019 Annual Report on Remuneration

Percentage of votes cast

Number of votes cast

For

97.65%

97.64%

Against

2.35%

2.36%

For

30,240,887

30,389,436

Against

728,373

733,673

Withheld1

250,424

96,865

1  A vote withheld is not a vote in law and is not counted in the calculation of the proportion of votes cast for and against a resolution.

For and on behalf of the Remuneration Committee.

Robert Laing

Chairman of the Remuneration Committee
25 February 2021

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• 

• 

F I N A N C I A L   S T A T E M E N T S

Independent auditor’s report 

to the Members of The Law Debenture Corporation P.l.c.

Opinion on the financial statements

In our opinion:

• 

 the financial statements give a true and fair view of the 

state of the Group’s and of the Parent Company’s affairs as 

at 31 December 2020 and of the Group’s profit for the year 

then ended;

Independence
Following the recommendation of the audit committee, we 

were appointed at the Annual General Meeting on 7 April 2020 

to audit the financial statements in the UK for the ended 31 

December 2020. The period of total uninterrupted engagement 

including retenders and reappointments is 13 years, covering 

the years ending 31 December 2008 to 31 December 2020. We 

remain independent of the Company in accordance with the 

 the Group financial statements have been properly prepared 

ethical requirements that are relevant to our audit of the financial 

in accordance with international accounting standards in 

statements in the UK, including the FRC’s Ethical Standard as 

conformity with the requirements of the Companies Act 2006;

applied to listed public interest entities, and we have fulfilled 

 the Group financial statements have been properly prepared 

in accordance with international financial reporting standards 

adopted pursuant to Regulation (EC) No 1606/2002 as it applies 

in the European Union;

• 

 the Parent Company financial statements have been properly 

prepared in accordance with international accounting 

our other ethical responsibilities in accordance with these 

requirements. The non-audit services prohibited by that standard 

were not provided to the Group or the Parent Company.

We have provided services other than audit to the Group as set out 

below. This includes a description of any relationships between the 

company, its subsidiaries and Directors and the firm.

standards in conformity with the requirements of the 

• 

 BDO provided the Group with a limited assurance opinion on 

Companies Act 2006 and as applied in accordance with the 

the CASS report that was issued to the FCA. The work involved 

provisions of the Companies Act 2006; and

as part of the CASS procedures is closely related to the work 

• 

 the financial statements have been prepared in accordance 

with the requirements of the Companies Act 2006 and, 

performed in the audit and the threats to auditor independence 

are insignificant. 

as regards the Group financial statements, Article 4 of the 

• 

 BDO also provided agreed upon procedures relating to 

IAS Regulation.

We have audited the financial statements of The Law Debenture 

Corporation p.l.c. (the ‘Parent Company’ or ‘Company’) and 

its subsidiaries (the ‘Group’) for the year ended 31 December 

2020 which comprise the group income statement, the group 

statement of comprehensive income, the group and company 

reporting on the Company’s statement of capital and reserves. 

The work involved is closely related to the work performed in 

the audit and the threats to auditor independence are clearly 

insignificant. This work is a requirement of the Guaranteed 

Secured Bond in accordance with Clause 27 of the Trust Deed 

dated 12 October 1999. 

statement of financial position, the group and company 

We do not consider there to be any other threats that may be 

statement of changes in equity, the group and company 

considered to bear on our objectivity and independence. Our 

statements of cash flows and notes to the financial statements, 

overall assessment is that the safeguards described here are 

including a summary of significant accounting policies. The 

appropriate and effective.

financial reporting framework that has been applied in their 

preparation is the law and international accounting standards in 

conformity with the requirements of the Companies Act 2006 

and, as regards the Parent Company financial statements, as 
applied in accordance with the provisions of the Companies 

Act 2006.

Basis for opinion

We conducted our audit in accordance with International 

Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our 

responsibilities under those standards are further described in the 

Auditor’s responsibilities for the audit of the financial statements 

section of our report. We believe that the audit evidence we have 

obtained is sufficient and appropriate to provide a basis for our 

opinion. Our audit opinion is consistent with the additional report 

to the audit committee. 

Conclusions relating to principal risks,  
going concern and viability statement

In auditing the financial statements, we have concluded that 

the Directors’ use of the going concern basis of accounting in 

the preparation of the financial statements is appropriate. Our 

evaluation of the Directors’ assessment of the Group and the 

Parent Company’s ability to continue to adopt the going concern 

basis of accounting included:

• 

• 

 Obtaining management’s assessment of the Going Concern 

Status & Long Term Viability of the Group

 Reviewing the appropriateness of the forecasted cash flow 

calculated at group level by performing a sensitivity analysis 

on the expected receipt of cash from revenue streams and 

future expenditure and the cash outflow arising from dividend 

payments to shareholders 

• 

 Challenging management’s assumptions and judgements 

made with regards to stress-tested forecast revenue figures, 

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cash to be received from revenue, the cost of fixed expenditures, 

the payment of dividends to shareholders on a quarterly basis 

An overview of the scope of our audit

and cash flows relating to the acquisition of a new company 

Our Group audit was scoped by obtaining an understanding of 

secretarial unit by comparing to the accuracy of past forecasts 

the Group and its environment, including the Group’s system of 

 Enquiring with management about the level of insurance 

coverage across the group

internal control, and assessing the risks of material misstatement 

in the financial statements. We also addressed the risk of 

management override of internal controls, including assessing 

 Calculating financial ratios to ascertain the financial health of 

whether there was evidence of bias by the Directors that may have 

the group 

represented a risk of material misstatement.

 We obtained the debenture and loan agreements to identify the 

All seven significant components (The Law Debenture Corporation 

covenants and assessed the likelihood of the covenants being 

p.l.c., The Law Debenture Trust Corporation p.l.c., The Law 

breached based on management forecasts and our sensitivity 

Debenture Pension Trust Corporation p.l.c., Law Debenture 

• 

• 

• 

analysis

• 

 Performing calculations assessing the net asset position of the 

group to understand the reliance on loans and debentures

Corporate Service Ltd, L.D.C. Trust Management Ltd, The Law 

Debenture Intermediary Corporation p.l.c. and Law Debenture 

Trustees Ltd) are based in the UK and the group audit team have 

responsibility for the audit of all significant components included 

Based on the work we have performed, we have not identified 

in the consolidated financial statements. 

any material uncertainties relating to events or conditions that, 

individually or collectively, may cast significant doubt on the 

entity’s ability to continue as a going concern for a period of at 

least twelve months from when the financial statements are 

authorised for issue. 

In relation to the Parent Company’s reporting on how it has 

applied the UK Corporate Governance Code, we have nothing 

material to add or draw attention to in relation to the Directors’ 

statement in the financial statements about whether the Directors 

considered it appropriate to adopt the going concern basis of 

accounting.

Component materiality across the group ranged from £900 

to £5.475m. For components where full scope audits were not 

undertaken, the group audit team undertook audit procedures 

on material balances with a performance materiality of 75% of 

materiality in all cases. 

Our audit approach was developed by obtaining an understanding 

of the group’s activities and the overall control environment. Based 

on this understanding we assessed those aspects of the group’s 

transactions and balances which were most likely to give rise to a 

material misstatement. 

Our responsibilities and the responsibilities of the Directors with 

respect to going concern are described in the relevant sections of 

Our involvement with component auditors
In respect of non-significant components, we instructed other BDO 

this report.

Overview

Coverage 

100.0% (2019: 100.0%) of the investment 

portfolio.

member firms to carry out desktop reviews and undertake specific 

audit procedures on balances where we identified a significant risk. 

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 period and include the most significant 

assessed risks of material misstatement (whether or not due to 

93.6% (2019: 95.1%) of the Group Revenue.

fraud) that we identified, including those which had the greatest 

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effect on: the overall audit strategy, the allocation of resources in 

the audit, and directing the efforts of the engagement team. These 

matters were addressed in the context of our audit of the financial 

statements as a whole, and in forming our opinion thereon, and we 

do not provide a separate opinion on these matters.

Key audit 

Valuation & Ownership of 

matters

Investments – investment 

portfolio

Revenue Recognition – 

Independent Professional 

Services

Revenue Recognition – 

investment portfolio

2020

2019

Ç

Ç

Ç

Ç

Ç

Ç

Materiality

£7.30m (2019: £8.22m) based on 1% of Group net 

assets (2019: 1% of Group Total Investments)

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Independent auditor’s report continued

Key Audit Matter 

Valuation and 

Ownership of 

Investments – 

The investment portfolio at the year-

We responded to this matter by testing the valuation and ownership 

end comprised of predominantly 

of 100% of the quoted investments.

How the matter was addressed in the audit

listed equity investments at fair value 

We utilised our BDO DIVA (Dividend-Investment-Valuation Analyser) 

tool to recalculate the valuation of the listed investments portfolio 

using the holdings per the third party HSBC report and independent 

bid prices.

We obtained the third party year-end custodian holdings report from 

HSBC and checked that for all listed investments the number of 

shares owned agreed to the year-end investments summary provided 

in the draft financial statements. A sample of additions and disposals 

have been corroborated to third party confirmations and we have 

recalculated the realised gains on disposals based on the brought 

forward book cost.

We reviewed the latest available independent assurance report 
addressing the relevant controls in place at the custodian to assess 

whether any of the exceptions identified had an impact on our 

audit approach. 

For the unrealised gains/losses on investments held at fair value, we 

tested the valuation of the portfolio at the year-end, together with 

testing the reconciliation of opening and closing investments. We did 

this by taking the portfolio holdings at and the opening and closing 

positions and corroborating the bid prices to independent sources, 

obtaining comfort over the unrealised movements recognised 

between these two points. 

For the unlisted investment (£4.1m at 31 December 2020) we 

considered whether, in our professional judgement, the valuation 

methodology was the most appropriate in the circumstances under 

the IPEV guidelines.

As part of our detailed testing for the unlisted investment, we:

• 

• 

• 

 re-performed the calculation of the valuation

 verified key inputs to the valuation to independent information

 challenged significant judgements made such as the NAV 

per share

Key observations:

Based on our procedures performed, we did not identify any 

exceptions with regards to valuation or ownership of investments. 

investment portfolio 

through profit or loss. 

(notes 1 and 14 to the 
financial statements)

We consider the valuation and 

ownership of investments to be one 

of the most significant audit areas 

as investments represent the most 

significant balance in the financial 

statements and underpin the 

principal activity of the entity

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Key Audit Matter 

How the matter was addressed in the audit

Revenue Recognition 

We consider that the timing of 

In respect of fee income from the provision of professional services, our 

– Independent 

invoicing of fees resulting in amounts 

audit strategy differed per revenue stream. 

Professional Services 

being accrued and deferred at the 

(notes 1 and 7 to the 
financial statements

year-end based on management’s 

estimates as a significant risk and key 

audit matter. 

For annuals fees, annual trustee fees, company secretarial fees and daily 

rates fees we agreed a sample of recorded revenue to a contractual 

agreement, invoice and receipt of cash. We also obtained a breakdown 

of accrued and deferred income and selected a sample, which we 

Revenue consists of fees receivable 

recalculated, based on the aforementioned supporting documentation 

from the provision of professional 

to check that the appropriate proportion of income had been 

services including, but not limited to, 

recognised in the year. 

annual trustee services, transaction 

fees, service of process fees, company 

secretarial fees, special fees, daily 

rates, single payments, new fee 

structure and European Medium 

Term Note revenue.

For the annual fees revenue stream 

we consider that the risk lies with 

billing and invoicing throughout the 

For the testing of the transaction and special fees, we agreed the fee to 

sales invoice and receipt of cash. For these revenue streams, we tested 

whether the sampled client was on the annual fees schedule meaning 

that they had an equal opportunity to be chosen in our samples as part 

of our annual fee, annual trustee fees and company secretarial fees 

contract testing.

For service of process fees we agreed a sample of recorded revenue to 

appointment letter, invoice and receipt of cash. 

year for all clients in this revenue 

Single payments, New Fee Structure and European Medium Term 

stream. 

Note revenue generated was tested through a sample of transactions 

being agreed to client agreements or recent correspondence where a 

countersigned agreement was not available, sales invoices and bank 

receipts; in addition to a revenue recalculation being performed.

We obtained evidence to confirm that performance obligations have 

been satisfied across all streams.

We reviewed invoices either side of the year-end to verify that the 

revenue has been accounted for in the correct period.

We have also reviewed a sample of credit notes raised post year-end to 

ascertain whether any related to revenue recorded in the financial year. 

Key observations:

Based on procedures performed, we did not identify any exceptions 

with regards to the income and revenue recognition policy in 

relation to the provision of professional services.

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Revenue Recognition 

– investment portfolio 

We consider that the existence of 
dividend income recorded by the 

For the income recognised in the investment portfolio, we utilised our 

BDO DIVA (Dividend-Investment-Valuation Analyser) tool to recalculate 

(notes 1 and 7 to the 

investment portfolio is a significant 

the dividend income received.

financial statements

risk and a Key Audit Matter. 

We sourced further independent data to corroborate an expectation 

For the investment portfolio the 

of income due based on the investments held and dividend 

revenue comprises dividends and 

announcements made. 

interest receivable on the portfolio 

of investments held. Dividend 

income is one of the key drivers of 

dividend returns to investors and is 

often a key factor in demonstrating 

the performance of the portfolio. 

Judgement is also required in the 

allocation of income to revenue 

or capital.

We performed a dividend yield to test, using a threshold of 5%, to 

identify whether any capital dividends had incorrectly been recorded 

as revenue income. 

Key observations:
Based on our procedures performed, we did not identify any 

exceptions with regards to the income in relation to the provision 

of the investment portfolio.

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Independent auditor’s report continued

Our application of materiality

We apply the concept of materiality both in planning 

extent of testing needed. Importantly, misstatements below 

and performing our audit, and in evaluating the effect of 

these levels will not necessarily be evaluated as immaterial as 

misstatements. We consider materiality to be the magnitude by 

we also take account of the nature of identified misstatements, 

which misstatements, including omissions, could influence the 

and the particular circumstances of their occurrence, when 

economic decisions of reasonable users that are taken on the 

evaluating their effect on the financial statements as a whole. 

basis of the financial statements. 

Based on our professional judgement, we determined 

In order to reduce to an appropriately low level the probability 

materiality for the financial statements as a whole and 

that any misstatements exceed materiality, we use a lower 

performance materiality as follows:

materiality level, performance materiality, to determine the 

Materiality

Group financial statements

Parent Company financial statements

2020

£m

7.30

2019

£m

8.22

2020

£m

5.48

2019

£m

7.81

Basis for determining 

1% Group Net Assets

1% Group Total 

75% Group Materiality

95% Group Materiality

materiality

Rationale for the 

benchmark applied

Investments

Group Net Assets to 

Total Investments 

This to ensure the 

This to ensure the 

account for the debt 

threshold to effectively 

audit team identify 

audit team identify 

held by the group. 

test the value of 

errors in the parent 

errors in the parent 

investments and the 

entity that may present 

entity that may present 

range of reasonable 

an aggregate risk of 

an aggregate risk of 

alternative valuations. 

material misstatement 

material misstatement 

to the group financial 

to the group financial 

statements. 

statements. 

Performance materiality

5.48

6.17

4.11

5.86

Basis for determining 

75% based on the 

75% based on the 

75% based on the 

75% based on the 

performance materiality

expected total value 

expected total value 

expected total value 

expected total value 

of known and likely 

of known and likely 

of known and likely 

of known and likely 

misstatements. 

misstatements.

misstatements.

misstatements.

Change to Group Materiality Approach
The benchmark for group materiality was changed this year to 

Five of the significant components had a materiality calculated 

based on 7.0% of their adjusted profit before tax with L.D.C. Trust 

account for the debt within the group. This is appropriate as the Law 

Management Ltd based on 1% of expenditure and the parent 

Debenture group is a mixture of a large Independent Professional 

company capped at 75% of Group materiality. We used adjusted 

Services (“IPS”) business and an investment portfolio. The use of the 

profit before tax to exclude the impact of group intercompany 

investment value alone is not appropriate given the IPS business. 

recharges. 

Specific materiality
We also determined that for items impacting the revenue return, a 

Reporting threshold 
We agreed with the Audit Committee that we would report 

misstatement of less than materiality for the financial statements 

to them all individual audit differences in excess of £65,000. 

as a whole could influence the economic decisions of users. 

A specific materiality level was therefore set at £1.290m (2019: 

£1.884m), based on 5% of group income before tax (2019: 5% of 

group income before tax). We further applied a performance 

(2019: £164,000). We also agreed to report differences below this 

threshold that, in our view, warranted reporting on qualitative 

grounds by which misstatements, including omissions, could 

influence the economic decisions of reasonable users that are 

materiality level of 75% of specific materiality to ensure that the risk 

taken on the basis of the financial statements. 

of errors exceeding specific materiality was appropriately mitigated. 

Component materiality
Full scope audits of the seven significant components were 

Other information

The directors are responsible for the other information. The 

performed at a materiality level calculated based on a level 

other information comprises the information included in 

appropriate to the relative scale of the business concerned. 

the annual report other than the financial statements and 

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Independent auditor’s report continued

our auditor’s report thereon. Our opinion on the financial 

statements does not cover the other information and, except 

Other Companies Act 2006 reporting

to the extent otherwise explicitly stated in our report, we do 

Based on the responsibilities described below and our work 

not express any form of assurance conclusion thereon. Our 

performed during the course of the audit, we are required by 

responsibility is to read the other information and, in doing 

the Companies Act 2006 and ISAs (UK) to report on certain 

so, consider whether the other information is materially 

opinions and matters as described below. 

inconsistent with the financial statements or our knowledge 

obtained in the course of the audit, or otherwise appears 

to be materially misstated. If we identify such material 

inconsistencies or apparent material misstatements, we are 

required to determine whether this gives rise to a material 

misstatement in the financial statements themselves. If, based 

on the work we have performed, we conclude that there is 

a material misstatement of this other information, we are 

required to report that fact.

We have nothing to report in this regard.

Corporate governance statement

The Listing Rules require us to review the Directors’ statement 

in relation to going concern, longer-term viability and that 

part of the Corporate Governance Statement relating to the 

parent company’s compliance with the provisions of the UK 

Corporate Governance Statement specified for our review. 

Based on the work undertaken as part of our audit, we 

have concluded that each of the following elements of the 

Corporate Governance Statement is materially consistent 

with the financial statements or our knowledge obtained 

during the audit. 

Going concern 

• 

 The Directors’ statement with regard to 

and longer-

the appropriateness of adopting the going 

term viability 

concern basis of accounting and any 

material uncertainties identified set out on 

page 55; and

• 

 The Directors’ explanation as to its 

assessment of the entity’s prospects, the 

period this assessment covers and why this 

period is appropriate set out on page 53.

Other Code 

• 

 Directors’ statement on fair, balanced 

provisions 

and understandable reporting set out on 

page 58; 

• 

 Board’s confirmation that it has carried out 

a robust assessment of the emerging and 

principal risks set out on page 46; 

• 

 The section of the annual report that 

describes the review of effectiveness of risk 

management and internal control systems 

set out on page 64; and

• 

 The section describing the work of the audit 

committee set out on pages 63 and 64.

Strategic 

report and 

Directors’ 

report 

In our opinion, based on the work undertaken 

in the course of the audit:

• 

 the information given in the Strategic report 

and the Directors’ report for the financial 

year for which the financial statements are 

prepared is consistent with the financial 

statements; and

• 

 the Strategic report and the Directors’ report 

have been prepared in accordance with 

applicable legal requirements.

In the light of the knowledge and 

understanding of the Group and Parent 

Company and its environment obtained in 

the course of the audit, we have not identified 

material misstatements in the strategic report 

or the Directors’ report.

Directors’ 

In our opinion, the part of the Directors’ 

remuneration

remuneration report to be audited has been 

properly prepared in accordance with the 

Companies Act 2006.

Matters on 

which we 

We have nothing to report in respect of the 

following matters in relation to which the 

are required 

Companies Act 2006 requires us to report to 

to report by 

you if, in our opinion:

exception

• 

 adequate accounting records have not been 

kept by the Parent Company, or returns 

adequate for our audit have not been 

received from branches not visited by us; or

• 

 the Parent Company financial statements 

and the part of the Directors’ remuneration 

report to be audited are not in agreement 

with the accounting records and returns; or

• 

 certain disclosures of Directors’ 

remuneration specified by law are not made; 

or

• 

 we have not received all the information and 

explanations we require for our audit.

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Independent auditor’s report continued

Responsibilities of Directors

As explained more fully in the Directors’ responsibilities, the 

Directors are responsible for the preparation of the financial 

statements and for being satisfied that they give a true and fair 

view, and for such internal control as the Directors determine is 

necessary to enable the preparation of financial statements that 

are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the Directors are 

responsible for assessing the Group’s and the 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 the Directors either intend to liquidate 

the Group or the Parent Company or to cease operations, or have 

no realistic alternative but to do so.

and regulation, review of board meeting minutes and review of 

legal correspondence.

We focused on laws and regulations that could give rise to a 

material misstatement in the company financial statements. Our 

tests included, but were not limited to:

• 

• 

• 

• 

• 

 agreement of the financial statement disclosures to 

underlying supporting documentation;

 enquiries of management;

 Testing of journal postings made during the year to identify 

potential management override of controls

 review of minutes of board meetings throughout the period; 

and

 Obtaining an understanding of the control environment in 

monitoring compliance with laws and regulations

Auditor’s responsibilities for the audit of 
the financial statements

Our audit procedures were designed to respond to risks of 

material misstatement in the financial statements, recognising 

that the risk of not detecting a material misstatement due 

Our objectives are to obtain reasonable assurance about whether 

to fraud is higher than the risk of not detecting one resulting 

the financial statements as a whole are free from material 

from error, as fraud may involve deliberate concealment by, for 

misstatement, whether due to fraud or error, and to issue an 

example, forgery, misrepresentations or through collusion. There 

auditor’s report that includes our opinion. Reasonable assurance 

are inherent limitations in the audit procedures performed and 

is a high level of assurance, but is not a guarantee that an audit 

the further removed non-compliance with laws and regulations 

conducted in accordance with ISAs (UK) will always detect a 

is from the events and transactions reflected in the financial 

material misstatement when it exists. Misstatements can arise 

statements, the less likely we are to become aware of it.

from fraud or error and are considered material if, individually or 

in the aggregate, they could reasonably be expected to influence 

the economic decisions of users taken on the basis of these 

financial statements.

Extent to which the audit was 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. 

The extent to which our procedures are capable of detecting 

irregularities, including fraud is detailed below:

We gained an understanding of the legal and regulatory 

framework applicable to the group and the two industries 

in which the group operates, and considered the risk of acts 

by the company which were contrary to applicable laws and 

regulations, including fraud. These included but were not limited 

to compliance with Companies Act 2006, the FCA listing and 

DTR rules, the principles of the UK Corporate Governance Code, 

industry practice represented by the AIC SORP and international 

accounting standards. We also considered the company’s 

qualification as an Investment Trust under UK tax legislation. 

We considered compliance with this framework through 

discussions with the Audit Committee and performed audit 

procedures on these areas as considered necessary. Our 

procedures involved enquiries with Management, review of the 

reporting to the directors with respect to compliance with laws 

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A further description of our responsibilities is available on 

the Financial Reporting Council’s website at: www.frc.org.

uk/auditorsresponsibilities. This description forms part of our 

auditor’s report.

Use of our report

This report is made solely to the Parent Company’s members, 

as a body, in accordance with Chapter 3 of Part 16 of the 

Companies Act 2006. Our audit work has been undertaken so 

that we might state to the Parent 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 Parent Company and the Parent Company’s 

members as a body, for our audit work, for this report, or for 

the opinions we have formed.

Vanessa-Jayne Bradley (Senior Statutory Auditor)
For and on behalf of BDO LLP, Statutory Auditor

London

United Kingdom

25 February 2021

BDO LLP is a limited liability partnership registered in England 

and Wales (with registered number OC305127).

 
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Group income statement 

as at 31 December 2020

UK dividends

UK special dividends

Overseas dividends

Overseas special dividends

Interest income

Independent professional services fees

Other income

Total income 

Net (loss)/gain on investments held at fair 

value through profit or loss

Total income and capital gains/(losses)

Cost of sales

Administrative expenses

Provision for onerous contracts

Operating profit/(loss)

Finance costs

Interest payable

Profit/(loss) before taxation

Taxation

Profit/(loss) for the year

Return per ordinary share (pence)

Diluted return per ordinary share (pence)

Revenue
£000

 14,794 

 458 

 2,685 

—

 17,937 

 89 

 38,898 

 219 

 57,143 

Capital
£000

2020

Total*
£000

Revenue
£000

Capital
£000

—

—

—

—

—

—

—

—

—

 14,794 

23,458

 458 

 2,685 

—

2,364

3,294

85

 17,937 

29,201

 89 

706

 38,898 

36,815

 219 

20

 57,143 

66,742

—

—

—

—

—

—

—

—

—

2019

Total*
£000

23,458

2,364

3,294

85

29,201

706

36,815

20

66,742

—

 (16,354)

 (16,354)

—

100,023

100,023

 57,143 

 (16,354)

 40,789 

66,742

100,023

166,765

 (4,405)

—

 (4,405)

(5,026)

—

(5,026)

 (24,879)

 (2,216)

 (27,095)

(22,835)

(2,379)

(25,214)

 118 

—

 118 

113

—

113

 27,977 

 (18,570)

 9,407 

38,994

97,644

136,638

 (1,320)

 (3,958)

 (5,278)

 26,657 

 (22,528)

 (1,178)

—

 25,479 

 (22,528)

 21.56 

 21.56 

 (19.06)

 (19.06)

 4,129 

 (1,178)

 2,951 

 2.50 

 2.50 

(1,319)

37,675

(1,420)

36,255

30.68

30.67

(3,958)

93,686

—

(5,277)

131,361

(1,420)

93,686

129,941

79.27

79.27

109.95

109.94

Notes

6

2

3

4

6

7

8

7

7

7

Statement of comprehensive income 

as at 31 December 2020

GROUP

Profit for the year

Revenue
£000

Capital
£000

2020

Total
£000

Revenue
£000

Capital
£000

2019

Total
£000

 25,479 

 (22,528)

 2,951 

36,255

93,686

129,941

Items that will or may be reclassified to profit or loss:

Foreign exchange on translation of foreign operations

—

Items that will not be reclassified to profit or loss:

Pension actuarial losses

Taxation on pension

Other comprehensive loss for the year

 (6,500)

 1,235 

 (5,265)

105

—

—

105

Total comprehensive (loss)/income for the year

 20,214 

(22,423)

105

—

(214)

(214)

 (6,500)

 1,235 

(5,160)

(2,209)

(800)

152

(648)

—

—

(214)

(800)

152

(862)

35,607

93,472

129,079

92

lawdebenture.com

Statement of financial position 

as at 31 December 2020

Assets

Non-current assets

Goodwill

Property, plant and equipment

Right-of-use asset

Other intangible assets

Investments held at fair value through profit or loss

Investments in subsidiary undertakings

Retirement benefit asset

Deferred tax asset

Total non-current assets

Current assets

Trade and other receivables

Other accrued income and prepaid expenses

Cash and cash equivalents

Total current assets

Total assets

Current liabilities

Amounts owed to subsidiary undertakings

Trade and other payables

Lease liability

Corporation tax payable

Deferred tax liability

Other taxation including social security

Deferred income

Total current liabilities

Non-current liabilities and deferred income

Long-term borrowings

Deferred income

Lease liability

Retirement benefit liability

Provision for onerous contracts

Total non-current liabilities

Total net assets

Equity

Called up share capital

Share premium

Own shares

Capital redemption

Translation reserve

Capital reserves

Retained earnings

Total equity

Notes

11

12

23

13

14

14

24

8

15

16

17

23

8

8

21

23

4

18

18

2020
£000

 1,914 

 1,088 

 5,413 

  619  

GROUP

2019
£000

COMPANY

2020
£000

2019
£000

 1,930 

 64 

 1,057 

 104 

—

—

—

 16 

—

—

—

 16 

 812,297 

 822,316 

 812,083 

 822,102 

—

—

 771 

—

 61,283 

 61,283 

 2,700 

—

—

—

—

—

 822,102 

 828,171 

 873,382 

 883,401 

16,129

 6,529 

 7,213 

 6,438 

 4,084 

1,990

 542 

 2,155 

 41,762 

 71,236 

 32,098 

 46,128 

 64,420 

 84,887 

 38,172 

 48,825 

 886,522 

 913,058 

 911,554 

 932,226 

—

—

 61,698 

 53,990 

27,405

 13,010 

13,075

 1,420 

—

 238 

—

 860 

 4,367 

 730 

 710 

 83 

 540 

 5,625 

—

—

—

 793 

 16 

—

 20 

—

 534 

 16 

32,870

 20,698 

 75,582 

 55,980 

 114,201 

 114,157 

 74,569 

 74,551 

 4,011 

5,606

 2,840 

—

 2,463 

 125 

 135 

350

—

118

—

—

—

—

—

—

 126,658 

  117,088  

74,694

74,686

726,994

 775,272 

 761,278 

 801,560 

 5,923 

 9,277 

 (1,461)

 8 

 5,921 

 9,147 

 (1,332)

 8 

2,002

 1,897 

 5,923 

 9,277 

—

 8 

—

 5,921 

 9,147 

—

 8 

—

19

 674,591 

 697,119 

 733,189 

 755,717 

36,654

 62,512 

 12,881 

 30,767 

726,994

 775,272 

 761,278 

 801,560 

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Total equity pence per share

615.19

655.76

As permitted by Section 408 of the Companies Act 2006, the Company has not presented its own income statement, however its gain for 

the year was £5,658,000 (2019: gain £122,817,000). Approved and authorised for issue by the Board on 25 February 2021 and signed on its 

behalf by: 

R. Hingley, Chairman 
Registered number 30397.

|  D. Jackson, Chief Executive Officer  

93

 
F I N A N C I A L   S T A T E M E N T S

Statement of changes in equity 

as at 31 December 2020

GROUP

Called 
up share 
capital 
£000

Share  
premium
£000

Own 
shares 
£000

Capital  
redemption 
£000

Translation 
reserve 
£000

Capital  
reserves 
£000

Retained 
earnings 
£000

Total 
£000

Balance at 1 January 2020

5,921 

9,147 

 (1,332)

8 

1,897 

697,119 

62,512 

775,272 

Net gain for the period

Foreign exchange

Actuarial gain on pension 

scheme (net of tax)

Total comprehensive loss 

for the period

Issue of shares

Movement in own shares

Dividend relating to 2019

Dividend relating to 2020

Statute barred dividends

Total equity at  

31 December 2020

GROUP

Balance at 1 January 

2019

Net gain for the period

Foreign exchange

Actuarial gain on pension 

scheme (net of tax)

Total comprehensive income 

for the period

Issue of shares

Movement in own shares

Dividend relating to 2018

Dividend relating to 2019

Statute barred dividends

Total equity at  

31 December 2019

—

—

—

—

2

—

—

—

—

—

—

—

—

130

—

—

—

—

—

—

—

—

—

(129)

—

—

—

—

—

—

—

—

—

—

—

—

 (22,528)

25,479 

 2,951 

105

—

—

105

—

—

—

 (5,265)

 (5,265)

105

 (22,528)

20,214 

(2,209)

—

—

—

—

—

—

—

—

—

—

—

—

 132 

(129)

 (22,976)

 (22,976)

 (23,096)

 (23,096)

—

—

5,923 

9,277 

 (1,461)

8 

2,002

674,591 

36,654 

726,994

Called up 
share capital 
£000

Share  
premium
£000

Own 
shares 
£000

Capital  
redemption 
£000

Translation 
reserve 
£000

Capital  
reserves 
£000

Retained 
earnings 
£000

Total 
£000

5,919

8,904

(966)

—

—

—

—

2

—

—

—

—

—

—

—

—

243

—

—

—

—

—

—

—

—

—

(366)

—

—

—

5,921

9,147

(1,332)

8

—

—

—

—

—

—

—

—

—

8

2,111

—

(214)

—

603,433

49,955

669,364

93,686

36,255

129,941

—

—

—

(214)

(648)

(648)

(214)

93,686

35,607

129,079

—

—

—

—

—

—

—

—

—

—

—

—

245

(366)

(15,272)

(15,272)

(7,813)

(7,813)

35

35

1,897

697,119

62,512

775,272

Capital reserves comprises realised and unrealised gains on investments held at fair value through profit or loss (see note 19).

94

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Statement of changes in equity continued 

as at 31 December 2020

COMPANY

Balance at 1 January 2 020

Total comprehensive gain 

for the period

Issue of shares

Dividend relating to 2019

Dividend relating to 2020

Statute barred dividends

Total equity at 

31 December 2020

COMPANY

Balance at 1 January 2019

Total comprehensive gain 

for the period

Issue of shares

Dividend relating to 2018

Dividend relating to 2019

Statute barred dividends

Total equity at 

31 December 2019

Share 
capital 
£000

5,921 

Share  
premium
£000

9,147 

—

2

—

—

—

—

130

—

—

—

5,923 

9,277 

Share 
capital 
£000

5,919

Share  
premium
£000

8,904

—

2

—

—

—

—

243

—

—

—

5,921

9,147

Own 
shares 
£000

Capital  
redemption 
£000

Translation 
reserve 
£000

Capital  
reserves 
£000

Retained 
earnings 
£000

Total 
£000

— 

—

—

—

—

—

— 

8 

—

—

—

—

—

8 

— 

755,717 

30,767 

801,560 

—

—

—

—

—

 (22,528)

28,186

5,658

132

—

—

—

—

—

 (22,976)

 (22,976)

 (23,096)

 (23,096)

—

—

— 

733,189 

12,881 

761,278

Own 
shares 
£000

Capital  
redemption 
£000

Translation 
reserve 
£000

Capital  
reserves 
£000

Retained 
earnings 
£000

Total 
£000

—

—

—

—

—

—

—

8

—

—

—

—

—

8

—

—

—

—

—

—

—

662,031

24,686

701,548

93,686

29,131

122,817

—

—

—

—

—

245

(15,272)

(15,272)

(7,813)

(7,813)

35

35

755,717

30,767

801,560

Capital reserves comprises realised and unrealised gains on investments held at fair value through profit or loss (see note 19).

95

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F I N A N C I A L   S T A T E M E N T S

Statements of cash flows  

for the year ended 31 December 2020

Operating activities

Operating profit before interest payable and taxation

Losses/(gains) on investments

Non-cash dividends

Foreign exchange losses/(gains)

Depreciation of property, plant and equipment

Depreciation of right-of-use assets

Interest on lease liability

Amortisation of intangible assets

Loss on sale of fixed assets

Decrease/(increase) in receivables

(Decrease)/increase in payables

Transfer from capital reserves

Normal pension contributions in excess of cost

Cash generated from operating activities

Taxation

Operating cash flow

Investing activities

Acquisition of property, plant and equipment

Expenditure on intangible assets

Purchase of investments

Sale of investments

Acquisition of subsidiary undertakings

Cash flow from investing activities

Financing activities

Intercompany funding

Interest paid 

Dividends paid

Payment of lease liability

Proceeds of increase in share capital

Purchase of own shares

Net cash flow from financing activities

2020
£000

GROUP

2019
£000

COMPANY

2020
£000

2019
£000

9,406

 136,638 

18,570

 (97,644)

—

19

37

1,179

49

59

(15)

(9,007)

14,926

(1,341)

(960)

 — 

 20 

 55 

 1,101 

 99 

 104 

—

 (958)

 1,298 

 (1,680)

 (1,000)

10,843

18,570

(10,000)

—

—

—

—

—

—

128,207

(97,644)

—

—

—

—

—

—

—

(3,377)

11,922

(1,341)

—

 (626)

 60 

 (1,680)

—

32,922

38,033 

26,617

28,317 

(1,103)

31,819

 (663)

—

—

 37,370 

26,617

 28,317 

(1,079)

(574)

 (21)

 (23)

—

—

—

 (16)

(173,831)

 (163,106)

(173,831)

 (163,106)

166,908

 102,888 

166,908

 102,888 

—

—

—

 (50)

(8,576)

 (60,262)

(6,923)

 (60,284)

—

—

17,708

 6,150 

(5,278)

 (5,277)

(5,206)

 (5,390)

(46,071)

 (23,050)

(46,071)

 (23,050)

(1,163)

132

(129)

 (1,177)

 245 

 (366)

—

132

—

—

 245 

—

(52,509)

 (29,625)

(33,437)

 (22,045)

Net (decrease)/increase in cash and cash equivalents

(29,266)

 (52,517)

(13,743)

 (54,012)

Cash and cash equivalents at beginning of period

Foreign exchange (losses)/gains on cash and cash equivalents

Cash and cash equivalents at end of period

71,236

(208)

41,762

 124,148 

46,128

 100,321 

 (395)

(287)

 (181)

 71,236 

32,098

 46,128 

96

lawdebenture.com

Notes to the accounts 

for the year end 31 December 2020

1.  Summary of significant accounting policies

General information

The Law Debenture Corporation p.l.c. is a public company incorporated in the United Kingdom. The address of the registered office 

is given on page 130. The Group’s operations and its principal activities are as an investment trust and the provider of independent 

professional services.

Basis of preparation

The financial statements of The Law Debenture Corporation p.l.c. and the Group have been prepared in accordance with international 

accounting standards in conformity with the requirements of the Companies Act 2006 and in accordance with international financial 

reporting standards adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union.

Where presentational guidance set out in the Statement of Recommended Practice Financial Statements of Investment Trust Companies 

and Venture Capital Trusts issued November 2014 and updated in October 2019 (SORP) is consistent with the requirements of IFRS, the 

Directors have sought to prepare the financial statements on a basis compliant with the recommendations of the SORP.

The Directors have considered the guidance of the UK Financial Reporting Council and events relating to the spread of Covid-19 and have 

treated this as an in year event with due consideration given in preparing these financial statements.

Going concern

The financial statements have been prepared on a going concern basis and under the historical cost basis of accounting, modified to 

include the revaluation of investment at fair value.

The assets of the Company consist of securities that are readily realisable and, accordingly, the Directors believe that the Company has 

adequate resources to continue in operational existence for at least 12 months from the date of approval of the financial statements.

The Directors have also considered the impact of Covid-19, including cash flow forecasting, balances sheet review at entity level, a review of 

covenant compliance including the headroom above the covenants and an assessment of the liquidity of the portfolio. A detailed overview 

of these considerations can be found in the section on our response to Covid-19, page 61. They have concluded that the Group is able to 

meet its financial obligations, including the repayment of the debenture interest, as they fall due for a period of at least 12 months from 

the date of approval of the financial statements. Having assessed these factors and the principal risks, the Directors are not aware of any 

material uncertainties that cast significant doubt on the Group’s ability to continue as a going concern.

The Directors have also considered the wider operational consequences and ramifications of the Covid-19 pandemic. As explained in the 

Chief Executive Officer’s report our business infrastructure has proved resilient in protecting the safety of our employees and maintaining 

our high levels of client service as the vast majority of Group staff work from home. We continue to review our approach in line with latest 

developments and government guidance. 

Critical accounting estimates and judgements

The preparation of the financial statements requires the exercise of judgement both in application of accounting policies which are set out 

below and in the selection of assumptions used in the calculation of estimates. These estimates and judgements are reviewed on an ongoing 

basis and are continually evaluated based on historical experience and other factors. However, actual results may differ from these estimates. 

The most significantly affected component of the financial statements and associated critical judgements is as follows:

Defined benefit scheme
The calculation of the defined benefit scheme assets and obligations is sensitive to the assumptions used. The assumptions used are given 

in note 24 to the financial statements.

The sensitivity to changes in assumptions and conditions which are significant to the calculation of the asset have been considered  

and the following is an illustration of the potential impact.

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Discount rate +0.1%

Inflation assumptions +0.1%

Life expectancy at 65 +1 year

RPI/CPI gap 0.1% increase in wedge between RPI and CPI at all durations (2019: 1.0% instead of 0.8%)

Increase/(decrease)  
in defined benefit obligations

at 31 December 
2020 
£ million

at 31 December 
2019 
£ million

(1.2)

1.0 

2.9 

(0.3)

(1.1)

0.9 

2.0 

(0.6)

97

 
Notes to the accounts continued 

for the year end 31 December 2020

1.  Summary of significant accounting policies continued

Basis of consolidation

The consolidated financial statements incorporate the financial statements of The Law Debenture Corporation p.l.c. and entities controlled 

by the Company (its subsidiaries) made up to the end of the financial period. The Company controls an investment if all three of the 

following elements are present: power over the investee, exposure to variable returns from the investee, and the ability of the investor to 

use its power to affect those variable returns. Control is reassessed whenever facts and circumstances indicate that there may be a change 

in any of these elements of control.

The assets, liabilities and contingent liabilities of a subsidiary are measured at their fair values at the date of acquisition. Any excess 

consideration over the fair values of the identifiable net assets acquired is recognised as goodwill.

Intercompany transactions, balances and unrealised gains on transactions between Group companies are eliminated. The financial 

statements of subsidiaries are adjusted, where necessary, to ensure the accounting policies used are consistent with those adopted by 

the Group.

Presentation of income statement and statement of comprehensive income

In order to better reflect the activities of an investment trust company and in accordance with the SORP, supplementary information 

which analyses the income statement and statement of comprehensive income between items of a revenue and capital nature has been 

presented. Additionally, the net revenue is the measure the Directors believe appropriate in assessing the Group’s compliance with certain 
requirements set out in Sections 1158-1159 of the Corporation Tax Act 2010. 

The allocation of investment trust finance costs and investment management fees between the revenue and the capital columns in the 

income statement reflects the expected split of future returns between income and capital. The proportional split is:

•  Revenue 25% (2019: 25%)

• 

 Capital 75% (2019: 75%)

Segment reporting

Operating segments are components of an entity about which separate financial information is available that is evaluated regularly by 

the Directors in deciding how to allocate resources and in assessing performance. The Group comprises two operating segments; the 

investment portfolio and independent professional services business. This is consistent with internal reporting. 

Foreign currencies

Transactions recorded in foreign currencies are translated into sterling at the exchange rate ruling on the date of the transaction.

Assets and liabilities denominated in foreign currencies at the reporting date are translated into sterling at the exchange rate ruling at that 

date. Gains and losses on translation are included in profit or loss for the period, however exchange gains or losses on investments held at 

fair value through profit or loss are included as part of their fair value gain or loss.

The assets and liabilities of overseas subsidiaries are translated at exchange rates prevailing on the reporting date. Income and expenses of 

overseas subsidiaries are translated at the average exchange rates for the period. Exchange differences arising from the translation of net 

investment in foreign subsidiaries are recognised in the statement of comprehensive income and transferred to the Group’s translation reserve.

Property, plant and equipment and right-of-use assets

All property, plant and equipment are stated at historical cost less depreciation. Historical cost includes expenditure that is directly 

attributable to the acquisition of the item. Depreciation is calculated using the straight-line method to allocate the cost over the assets’ 

estimated useful lives. 

Right-of-use assets are measured at cost less accumulated depreciation. The carrying amount is adjusted for any re-measurement of the 

lease liability.

Leasehold improvements 

over the remaining lease period

Office furniture and equipment 

3-10 years

Right-of-use asset 

over the remaining lease period

98

lawdebenture.com

Notes to the accounts continued 

for the year end 31 December 2020

1.  Summary of significant accounting policies continued

Intangible assets

Computer software
Computer software is capitalised on the basis of the costs incurred to acquire and bring to use the specific software. These costs are 

amortised over their estimated useful lives of between three and five years.

IT project costs
IT project costs have been capitalised that relate to the development of new internal software scheduled to be launched in 2021. It will be 

depreciated on the commencement of its use, over the useful economic life of three years.

Goodwill
Goodwill arising on consolidation represents the excess of the cost of acquisition over the Group’s interest in the fair value of the identifiable 

assets and liabilities of a subsidiary at the date of acquisition. Goodwill is initially recognised as an asset at cost and is subsequently measured 

at cost less any accumulated impairment losses. Goodwill which is recognised as an asset is reviewed for impairment at least annually. Any 

impairment would be recognised in profit or loss and is not subsequently reversed.

Impairment of assets
An impairment loss is recognised for the amount by which an asset’s carrying amount exceeds its recoverable amount. Assets are reviewed on a 

regular basis and tested for impairment whenever events or changes in circumstances indicate that the carrying amount may not be recoverable.

Financial instruments

Investments 
Listed and unlisted investments, which comprise the investment trust portfolio, have been designated as investments held at fair value 

through profit or loss. Purchases and sales of listed and unlisted investments are recognised on the date on which the Group commits to 

purchase or sell the investment. Investments are initially recognised at fair value and transaction costs are expensed as incurred. Gains and 

losses arising from listed and unlisted investments, as assets at fair value through profit or loss, are included in the income statement in 

the period in which they arise. The Group has not taken the option to irrevocably designate any equity securities as fair value through other 

comprehensive income. Transaction costs are expensed immediately.

The fair value of listed investments is based on quoted market prices at the reporting date. The quoted market price used is the bid price. 

The fair value of unlisted investments is determined by the Directors with reference to the International Private Equity and Venture Capital 

Valuation (IPEV) guidelines (December 2018).

Gains and losses on investments and direct transaction costs are analysed within the income statement as capital. All other costs of the 

investment trust are treated as revenue items.

Trade receivables
Trade receivables do not carry any interest and are stated at their nominal value as reduced by appropriate allowances for estimated 

irrecoverable amounts and expected credit losses.

Trade payables 
Trade payables are not interest bearing and are stated at their nominal value.

Cash and cash equivalents 
Cash and cash equivalents include cash in hand, deposits held with banks and other short-term highly liquid investments with original 

maturities of three months or less, subject to insignificant changes in fair value.

Borrowings 
Borrowings are recognised initially at fair value, which is generally the proceeds net of transaction costs incurred. The difference between 

the proceeds net of transaction costs and the redemption value is recognised in the income statement over the term of the borrowings 

using the effective interest rate method, so as to generate a constant rate of return on the amount outstanding.

Share capital 
Ordinary shares are classified as equity. The ordinary shares of the Company which have been purchased by the Employee Share 

Ownership Trust (ESOT) to provide share based payments to employees are valued at cost and deducted from equity.

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Notes to the accounts continued 

for the year end 31 December 2020

1.  Summary of significant accounting policies continued

Financial instruments continued

Taxation 
Current tax is based on taxable profit for the year. Taxable profit differs from profit as reported in the income statement because it 

excludes items of income or expense which are either never taxable or deductible or are taxable or deductible in other periods. The 

Group’s liability for current tax is calculated using tax rates that have been enacted or substantively enacted by the year end date.

Deferred income tax is provided in full, using the liability method, on temporary differences arising between the tax bases of assets 

and liabilities and their carrying amounts in the consolidated financial statements.

Deferred tax liabilities are 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.

Deferred tax liabilities are recognised for taxable temporary differences arising on investments in subsidiaries, except where the 

Group is able to control the reversal of the temporary difference and it is probable that the temporary difference will not reverse in the 

foreseeable future.

The carrying amount of deferred tax assets is reviewed at each year end date and reduced to the extent that it is no longer probable 

that sufficient taxable profits will be available to recover the asset. 

Deferred tax is calculated at the tax rates that are expected to apply in the period when the liability is expected to be settled or the 

asset is expected to be realised based on tax rates that have been enacted or substantively enacted at the year end date.

Deferred tax assets and liabilities are offset when the Group has a legally enforceable right to do so and presented as a net number on 

the face of the balance sheet.

Investment in subsidiaries 
Investments in subsidiaries are carried at cost.

Revenue recognition

Dividend income 
Dividend income from investments is recognised when the shareholders’ rights to receive payment have been established.

Stock lending 
Stock lending revenue is accounted for on an accruals basis and shown in the revenue return based on amounts to which the 

Company is entitled. The fees relating to the third party arranging the transaction are accounted for in Cost of Sales. 

Interest income 
Interest income is accrued on a time basis using the effective interest rate applicable.

IPS income
The Group has disaggregated the IPS revenue into various categories below which depict the nature, amount, timing, and uncertainty 

of revenue and cash flows.

During the course of the year there has been no changes to the Group’s application of IFRS 15. We continue to recognise revenue in 

line with the discharge of our performance obligations and we apply this consistently across the Group.

Corporate Services
Corporate Services provide governance services and includes Corporate Services, Service of Process and Safecall. In Service of Process, 

the performance obligation is fulfilled at the point in time we are appointed as process agent for the client, who is the contract 

counter party. In Corporate Services and Safecall the performance obligation is the provision of contracted services.

The transaction price can include any combination of one-off acceptance fees, regular annual payments, and special fees for extra 

work. Transactions are billed as a single payment at point of engagement or as on-going annual fees. Revenue is recognised over the 

period of time it is taken to fulfil the contracted performance obligation.

For annual contracts such as the provision of company secretarial work, or a whistleblowing hotline, the substance of these 

performance obligations is to “stand ready” to serve the customer and is satisfied over time with revenue recognised straight-line over 

the time lapsed. If the contract is an acceptance fee, the revenue is recognised in-month as that is the obligation and performance 

is at that point in time. If the contract is for training, revenue is recognised in the month the training took place as the obligation is 

fulfilled at that training event.

100

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Notes to the accounts continued 

for the year end 31 December 2020

1.  Summary of significant accounting policies continued

Revenue recognition continued

Corporate Trust
Contract terms are dealt with either in trust deeds or appointment letters. Revenue is recognised over the period of service where 

amounts which are not recognised in the financial period are deferred. The majority of Group deferred revenue relates to Corporate 

Trust business. Amounts are mostly billed and paid on an annual or quarterly basis. The Corporate Trust business is not adversely 

affected by economic stress factors because in a downturn clients seek to restructure their debt arrangements.

The transaction price can include any combination of one-off acceptance fees, regular annual payments, and special fees for extra 

work, and are recognised over the annual term or when the performance obligation is met.

The performance obligations are services provided in the creation of the trust or the structure and the obligations set out in the trust 

deed or service agreement over the period for which the trust or structure will be in place.

Pensions
Pension trusts provide professional trustee and governance services to clients, typically on a fixed annual fee basis or a time cost basis. 

The transaction price may be determined either by time billed or as an annual fixed fee.

The performance obligation is provision of the time of the Pensions professionals and the transfer of the services is at that point of time. 

Revenue is recognised in the accounting period in which the time has been recorded with amounts mostly billed and paid on a 

quarterly basis. This means that revenue accrued at year end is invoiced in January the following year. 

The cashflow associated with Pensions are largely unimpacted by economic factors because if a client becomes distressed they still 

deliver on their pensions governance requirements. There has been very limited history of bad debt write-off in the Pensions business.

Employee benefits

Pension costs 
The Group operates a defined benefit pension plan, which was closed to future accrual on 31 December 2016. The cost of providing 

benefits under the plan is determined using the projected unit credit method, with independent actuarial calculations being 

carried out at each year end date. Actuarial gains and losses are recognised in full in the period in which they occur through other 

comprehensive income.

The asset recognised in the statement of financial position in respect of the defined benefit plan is the present value of the defined 

benefit obligation at the year end date less the fair value of the plan assets.

In addition the Group operates defined contribution plans, where the cost recognised is the contributions paid in respect of the year.

Profit share schemes 
The Group recognises provisions in respect of its profit share schemes when contractually obliged or when there is a past practice that 

has created a constructive obligation. 

Share based plans 
The Group issues equity-settled share-based payments to certain employees. whereby the shares are deferred for a three-year period. 

Equity-settled share-based payments are measured at fair value at the date of grant. The fair value determined at the grant date of 

the equity-settled share-based payments is expensed on a straight-line basis over the vesting period, based on the Group’s estimate of 

shares that will eventually vest and adjusted for the effects of non-market-based vesting conditions. 

The Group also awards share options to executives. In 2020 the Group introduced a long-term performance incentive plan (LTIP) to 

executives in addition to annual bonus following the completion of a required service period and is dependent on the achievement 

of corporate performance and individual targets. Options are normally exercisable between 3 to 5 years from the date of grant for nil 

consideration. Full details of this plan can be found in the Directors’ remuneration report.

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101

 
 
Notes to the accounts continued 

for the year end 31 December 2020

1.  Summary of significant accounting policies continued

Reserves

A description of each of the reserves follows:

Share premium 
This reserve represents the difference between the issue price of shares and the nominal value of shares at the date of issue,  

net of related issue costs.

Capital redemption 
This reserve was created on the cancellation and repayment of the Company’s share capital.

Own shares 
This represents the cost of shares purchased by the ESOT.

Capital reserves 
The following are dealt with through this reserve:

•  gains and losses on realisation of investments; and

•  changes in fair value investments which are readily convertible to cash.

Retained earnings 
Net revenue profits and losses of the Company and its subsidiaries and the fair value costs of share based payments which are revenue 

in nature are dealt with in this reserve.

Translation reserve 
This reserve is used to record exchange differences arising from the translation of the financial statements of foreign subsidiaries and in 

prior years gains or losses on hedging instruments relating to the effective portion of the hedge related to the net investment in foreign 

subsidiaries.

Leases

Operating leases under right-of-use model 
From 1 January 2019 IFRS 16 replaced IAS 17; and the right-of-use model replaces the risks and rewards of ownership model. Under this 

standard leases previously classified as operating leases are recognised on the balance sheet, and the impact to the income statement 

is a change to both the expense character (rent expenses replaced with depreciation and interest expense) and recognition pattern 

(acceleration of lease expense relative to the recognition pattern for operating leases today).

Further detail on leases is provided in note 23 of the accounts.

Dividend distribution

Dividends are recognised when they become legally payable. In the case of interim dividends to equity shareholders, this is when paid. In the 

case of final dividends, this is when approved by the shareholders.

2.  Net capital gain/(loss) on investments

Realised gains based on historical cost

Amounts recognised as unrealised in previous years

Realised gains based on carrying value at previous year end date

Unrealised (loss)/gain on investments

Transfers to revenue

102

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2020
£000

2019
£000

 62,233 

39,043

 (51,586)

 (22,242)

 10,647 

 (27,001)

 (16,354)

—

 16,801 

 83,365 

 100,166 

 (143)

 (16,354)

 100,023 

Notes to the accounts continued 

for the year end 31 December 2020

3.  Administrative expenses

Administrative expenses include:

Salaries and Directors’ fees

Social security costs

Other pension costs

Investment management fee*

Depreciation – property, plant and equipment

Depreciation – right-of-use asset

Amortisation – intangible assets

Interest on lease liability

Foreign exchange

Auditors’ remuneration

Other property costs 

IT infrastructure 

Business development

Professional fees

Other expenses

Administrative expenses

2020
£000

13,762

1,622

1,093

16,477

447

37

1,179

59

49

(35)

289

511

791

83

950

2019
£000

12,731

1,457

878

15,066

512

55

1,101

104

99

54

265

542

463

129

676

4,042

24,879

3,769

22,835

*  25% of the management fee is charged to revenue, and 75% to capital reserves, to better reflect the expected split of future returns between income and capital. Further details are given 

in note 1 on page 98.

During the year, the Group employed an average of 152 staff (2019: 133). All staff are engaged in the provision of independent professional 

services. The Company has no employees.

Details of the terms of the investment management agreement are provided on page 34 of the strategic report.

Administrative expenses charged to capital are transaction costs and foreign exchange differences on the purchase of investments held at 

fair value through profit or loss.

A more detailed analysis of the auditors’ remuneration on a worldwide basis is provided below:

Audit services

–  fees payable to the Company’s auditors for the audit of its financial statements*

– audit related regulatory

2020
£000

275

14

289

2019
£000

251

14

265

* Including the Company £48,000 (2019: £45,500).

A description of the work of the Audit and Risk Committee is set out in the Audit and Risk Committee report on pages 63 to 65 

and includes an explanation of how auditor objectivity and independence is safeguarded when non-audit services are provided by 

the auditors.

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103

 
Notes to the accounts continued 

for the year end 31 December 2020

4.  Provision for onerous contracts 

GROUP

At 1 January

(Release) made in the year

Foreign exchange

At 31 December

2020
£000

118

(118)

—

—

2019
£000

236

 (113)

(5)

118

In December 2016 the Group completed the disposal of substantially all of its US corporate trust business for a consideration of $1. The 

disposal was the completion of the first part of a strategy to exit the US corporate trust business, so as to release $50m of capital required 

by the business. At the time of disposal the contracts remaining were assessed and deemed to generate insufficient income to cover 

the costs of running and financing the remainder of the business up to the eventual date of its closure. A provision for onerous costs of 

£3,106,000 representing the expected net future costs up to the date of disposal or completion of the remaining contracts was included 

in the year ended 31 December 2016. The business was closed during 2020 and the remaining provision of £118,000 was released (2019: 

release of £113,000). No provision was required at 31 December 2020.

5.  Remuneration of Directors (key management personnel)

The remuneration of the Directors, who are the key management personnel of the Group, comprises the following:

Short-term benefits including fees in respect of Directors

Deferred share bonus scheme

Details for each individual Director are shown in the remuneration report on pages 77 and 82.

6.  Interest

Interest Income

Interest on pension scheme (net)

Interest on bank deposits

Returns on money market funds

Interest Payable

Interest on long-term debt – revenue

Interest on long-term debt – capital

2020
£

2019
£

1,285,600

1,351,170

—

—

1,285,600

1,351,170

2020
£000

—

1

88

89

1,320

3,958

5,278

2019
£000

100

1

605

706

1,319

3,958

5,277

Interest (net)

(5,189)

(4,571)

104

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Notes to the accounts continued 

for the year end 31 December 2020

7.  Segment analysis

Investment portfolio

Independent 
professional services

Group charges

Total

31 December 
2020 
£000

31 December 
2019 
£000

31 December 
2020 
£000

31 December 
2019 
£000

31 December 
2020 
£000

31 December 
2019 
£000

31 December 
2020 
£000

31 December 
2019 
£000

Revenue

Segment income

17,937

29,201

38,898

36,815

Other income

Cost of sales

213

—

17

—

6

3

(4,405)

(5,026)

Administration costs

(2,570)

(2,186)

(22,301)

(20,536)

Release of onerous contracts 

Interest payable (net) (note 6)

Return, including profit on 

—

15,580

(1,260)

—

27,032

(822)

ordinary activities before taxation

14,320

26,210

Taxation

—

—

Return, including profit 

—

12,198

29

12,227

(1,178)

—

11,256

209

11,465

(1,370)

attributable to shareholders

14,320

26,210

11,049

10,095

—

—

—

(8)

118

110

—

110

—

110

—

—

—

(113)

113

—

—

—

(50)

56,835

66,016

219

20

(4,405)

(5,026)

(24,879)

(22,835)

118

113

27,888

38,288

(1,231)

(613)

26,657

(1,178)

37,675

(1,420)

(50)

25,479

36,255

Revenue return per  

ordinary share (pence)

Assets

Liabilities

12.12

22.18

9.35

850,255

870,944

36,246

(146,992)

(126,399)

(12,536)

Total net assets

703,263

744,545

23,710

8.54

42,021

(11,226)

30,795

0.09

(0.04)

21.56

30.68

21

—

21

50

(118)

(68)

886,522

913,015

(159,528)

(137,743)

726,994

775,272

For the purposes of reporting segmental performance, the table above presents a split of the revenue column between the investment 

portfolio, the IPS business and Group charges. Group dividends are paid from the investment portfolio segment of revenue reserves.

Geographic location of revenue: 90% of revenue is based in the UK. Geographic location is based on the jurisdiction in which the 
contracting legal entity is based.

Major customers: Due to the diverse nature of the IPS revenue streams, there is no single customer or concentration of customers that 
represents more than 2% of gross revenue streams.

Capital element: The capital element of the income statement is wholly gains and losses relating to investments held at fair value through 
profit and loss (2020 loss of £16,354,000; 2019 gain of £100,023,000), administrative expenses (2020: £2,216,000; 2019: £2,379,000) and 

interest payable (2020: £3,958,000; 2019: £3,958,000) which corresponds to amounts classified as capital in nature in accordance with the 

SORP are shown in the capital column of the income statement on page 92.

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Details regarding the segments are included on page 1 – Group summary and in note 1 – Segment reporting on page 98.

The total of the capital element and the table above is loss of £8,208,000 (2019: gain of £119,896,000).

105

 
Notes to the accounts continued 

for the year end 31 December 2020

7.  Segment analysis continued

Investment portfolio

Independent professional services

31 December 
2020 
£000

31 December 
2019 
£000

31 December 
2020 
£000

31 December 
2019 
£000

31 December 
2020 
£000

Total

31 December 
2019 
£000

Other information

Capital expenditure

Depreciation/amortisation

Depreciation – right-of-use asset

—

—

—

—

—

—

1,652

96

1,179

44

159

1,101

Group charges before taxation during the year comprised the following:

Closure of the US trust business:

Release for onerous contracts (see note 4)

8.  Taxation

Taxation based on revenue for the year comprises:

UK Corporation tax at 19.0% (2019: 19.0%)

Foreign tax charge

Total current tax charge

Deferred tax charge

Charge for the year

Taxation

The charge for the year can be reconciled to the profit per the income statement as follows:

Profits before taxation

Tax on ordinary activities at standard rate 19.0% (2019: 19.0%)

Effects of:

Permanent tax adjustments

Higher rates of tax on foreign income 

Non-taxable capital (gains)

Tax credit on dividend income 

Limit on Group relief for UK interest expense

Prior year under/(over) provision in respect of current tax

Deferred tax on movement in provision for onerous contracts

Total

1,652

96

1,179

2020 
£000

118

118

2020 
£000

 404

 338 

 742

 436 

 1,178 

2020 
£000

4,129

785

(79)

128 

6,405

(5,926)

133 

(56)

(212)

1,178 

44

159

1,101

2019 
£000

113

113

2019 
£000

855

327

 1,182 

238

 1,420 

2019 
£000

131,361

24,885 

25 

150 

(18,959)

(4,848)

217 

— 

(50)

1,420 

The Group expects that a substantial portion of its future income will continue to be in the form of dividend receipts and capital gains and 

losses, which constitute non-assessable income. On this basis, the Group tax charge is expected to remain significantly different to the 

standard UK rate of 19.0%.

106

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Notes to the accounts continued 

for the year end 31 December 2020

8.  Taxation continued

Deferred Tax

The following are the major deferred tax liabilities and assets recognised by the Group and movements thereon during the current and 

prior reporting period.

GROUP  
Deferred tax assets/(liabilities)

At 31 December 2018

(Charge) to income

Credit to other comprehensive income

Foreign exchange

At 31 December 2019

(Charge) to income

Credit to other comprehensive income

Other

At 31 December 2020

Accelerated tax 
depreciation 
£000

Retirement 
benefit 
obligations 
£000

486

(48)

—

(8)

430

(246)

—

55

239

(475)

(190)

152

—

(513)

(190)

1,235

—

532

Total 
£000

11

(238)

152

(8)

(83)

(436)

1,235

55

771

In accordance with the applicable accounting policy, deferred tax is calculated at the tax rates that are expected to apply to the reversal. 

Foreign taxes reflect the current rate, whilst UK taxes are at the enacted rate of 19.0%. A deferred tax asset has not been recognised in 

respect of foreign losses of £1,281,501 (2019: £1,245,981) as their usability cannot be predicted with reasonable certainty.

9.  Dividends on ordinary shares

Dividends on ordinary shares comprise the following:

2020 Interims† 19.50p (2019: 6.60p)

2019 Final 12.90p (2018: 12.90p)

Statute barred dividends*

Total for year

† 2020 interim dividends were paid in July 2020, October 2020 and January 2021.
* Relates to dividends unclaimed over 12 years old.

2020 
£000

2019 
£000

23,096

22,976

—

7,813

15,272

(35)

46,072

23,050

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Proposed final dividend for the year ended 31 December 2020 

The proposed final dividend is subject to approval by shareholders at the annual general meeting and has not been included as a liability 

in these financial statements.

Set out below is the total dividend payable in respect of the financial year, which is the basis on which the requirements of Sections 1158-

1159 of the Corporation Tax Act 2010 are considered.

2020 Interims† 19.50p (2019: 6.60p)

2020 Final 8.0p (2019: 19.40p)

† 2020 interim dividends were paid in July 2020, October 2020 and January 2021.

2020 
£000

23,096

9,476

32,572

2019 
£000

7,813

22,975

30,788

On this basis, The Law Debenture Corporation p.l.c. satisfies the requirements of Sections 1158-1159 of the Corporation Tax Act 2010, as an 

approved investment trust company. 

107

 
Notes to the accounts continued 

for the year end 31 December 2020

10.  Net asset value/return per share

NAV per share is calculated based on 118,173,664 (2019: 118,224,400) shares, being the total number of shares in issue of 118,454,562 (2019: 

118,429,010), less 267,752 (2019: 204,610) shares, acquired by the ESOT in the open market. The net asset value of £787,219,000 (2019: 

£830,139,000) comprises the NAV per the balance sheet of £726,994,000 (2019: £775,272,000) plus the fair value adjustment to for the IPS 

business of £112,407,000, (2019: £91,860,000) less the fair value adjustment for the debt of £52,204,000, (2019: £36,993,000). 

Revenue return per share is based on profits attributable of £25,479,000 (2019: £36,255,000). 

Capital loss per share is based on capital losses for the year of £22,528,000 (2019: gains £93,686,000). 

Total return per share is based on gain for the year of £2,951,000 (2019: gain £129,941,000). 

The calculations of returns per share are based on 118,171,875 (2019: 118,181,082) shares, being the weighted average number of shares 

in issue during the year after adjusting for shares owned by the ESOT. In 2020, total revenue and capital diluted returns per share were 

calculated using 118,192,860 shares (2019: 118,190,993 shares), being the diluted weighted average number of shares in issue assuming 

exercise of options at less than fair value. There were no (2019: 47,380) antidilutive shares. 

11.  Goodwill

GROUP 

Cost

At 1 January

Foreign exchange

At 31 December

Provision for impairment

At 1 January

Foreign exchange

At 31 December

Net book value at 31 December

2020 
£000

 2,359 

 (30)

 2,329 

 428 

 (13)

 415 

 1,914

2019 
£000

2,397

(38)

2,359

445

(16)

429

1,930

The goodwill is identifiable with separate operating companies (Safecall Limited: £1,419,000; and Delaware Corporate Services Inc.: 

£495,000). At 31 December 2020 the goodwill in relation to the operating companies was reviewed. The review assessed whether the 

carrying value of goodwill was supported by the net present value of future cash flows based on management forecasts for 2021.

The review for Safecall was assessed using annual growth for five years of 5% with no terminal growth, which is based on current 

expectations and a discount rate of 9% (2019: 9%). Sensitivity analysis was also completed using annual growth of 2% and a discount rate 

of 10% and on neither basis was the goodwill considered to be impaired.

The review of Delaware Corporate Services Inc. was assessed using annual growth for five years of 5% with no terminal growth, which is 

based on current expectations and a discount rate of 9% (2019: 9%). Sensitivity analysis was also completed using annual growth of 2% 

and a discount rate of 10% and on neither basis was the goodwill considered to be impaired.

108

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Notes to the accounts continued 

for the year end 31 December 2020

12.  Property, plant and equipment

Office 
 improvements 
£000

Furniture and 
equipment
£000

2020

Total
£000

2,748 

1,079 

(2,372) 

(7) 

1,448 

2,684 

37 

Office 
improvements
£000

Furniture and 
equipment 
£000

2019

Total
£000

899

17 

—

(3)

913

888

15

—

(3)

900

1,836

2,735

4

—

(5)

21

—

(8)

1,835

2,748

1,747

2,635

40

—

(3)

55

—

(6)

1,784

2,684

1,835 

1,079 

(1,576) 

(4) 

1,334 

1,784 

20 

913 

—

(796) 

(3) 

114 

900 

17 

(813) 

(2) 

102 

(1,544) 

(2,357) 

(2) 

258 

(4)

360 

GROUP 

Cost

At 1 January

Additions at cost

Disposals at cost

Foreign exchange

At 31 December

Accumulated depreciation

At 1 January

Charge

Disposals at cost

Foreign exchange

At 31 December

NET BOOK VALUE

Net book value at 31 December

12 

1,076 

1,088 

13

51

64

The Company holds no property, plant and equipment.

13.  Other intangible assets

Computer
Software
£000

IT project
Costs
£000

2020

Intangible 
Total
£000

Computer
Software
£000

IT project
Costs
£000

2019

Intangible 
Total
£000

GROUP 

Cost

At 1 January

Additions at cost

Disposals at cost

Foreign exchange

At 31 December

Accumulated depreciation

At 1 January

Charge

Disposals at cost

Foreign exchange

At 31 December

NET BOOK VALUE

1,814 

6 

(660)

—

1,160

1,710 

59 

(661) 

—

1,108 

—

567 

—

—

567 

—

—

—

—

—

1,814 

573

(660)

—

1,727

1,710 

59 

(661) 

—

1,108

1,792

23

—

(1)

1,814

1,606

104

—

—

1,710

Net book value at 31 December

52

567

619

104

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T
A
T
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M
E
N
T
S

—

—

—

—

—

—

—

—

—

—

—

1,792

23

—

(1)

1,814

1,606

104

—

—

1,710

104

109

 
Notes to the accounts continued 

for the year end 31 December 2020

14.  Investments

Investments held at fair value through profit or loss

GROUP

Opening cost at 1 January

Gains at 1 January

Opening fair value at 1 January

Purchases at cost

Cost of acquisition

Sales – proceeds

 – realised gains on sales

Gains/(losses) in the income statement

Closing fair value at 31 December

Closing cost at 31 December

Gains

Closing fair value at 31 December

Fair value through profit or loss

COMPANY

Opening cost at 1 January

Gains at 1 January

Opening fair value at 1 January

Purchases at cost

Cost of acquisition

Sales – proceeds

 – realised gains on sales

Gains/(losses) in the income statement

Closing fair value at 31 December

Closing cost at 31 December

Gains

Closing fair value at 31 December

Listed 
£000

629,845 

188,402 

818,247 

173,831

(588)

(166,908)

62,233

(78,809)

808,006

698,413

109,593

808,006

Listed 
£000

634,943 

183,304 

818,247 

173,831

(588)

(166,908)

62,233

(78,809)

808,006

703,511

104,495

808,006

Unlisted
£000

3,547 

522 

4,069

—

—

—

—

222 

4,291

3,547 

744

4,291

Unlisted
£000

3,333 

522 

3,855 

—

—

—

—

222 

4,077 

3,333 

744 

4,077 

2020

Total
£000

633,392 

188,924 

822,316 

173,831

(588)

Listed
£000

531,245

127,264

658,509

163,106

(661)

(166,908)

(102,888)

62,233

(78,587)

812,297 

701,960

110,337

812,297 

2020

Total
£000

638,276 

183,826 

822,102 

173,831

(588)

39,043

61,138

818,247

629,845

188,402

818,247

Listed
£000

536,343

122,166

658,509

163,106

(661)

(166,908)

(102,888)

62,233

(78,587)

812,083 

706,844

105,239

812,083 

39,043

61,138

818,247

634,943

183,304

818,247

Unlisted 
£000

3,547

537

4,084

—

—

—

—

(15)

4,069

3,547

522

4,069

Unlisted 
£000

3,333

537

3,870

—

—

—

—

(15)

3,855

3,333

522

3,855

2019

Total
£000

534,792

127,801

662,593

163,106

(661)

(102,888)

39,043

61,123

822,316

633,392

188,924

822,316

2019

Total
£000

539,676

122,703

662,379

163,106

(661)

(102,888)

39,043

61,123

822,102

638,276

183,826

822,102

Listed investments are all traded on active markets and as defined by IFRS 13 are Level 1 financial instruments. As such they are valued at 

unadjusted quoted bid prices. Unlisted investments are Level 3 financial instruments. They are valued by the Directors using unobservable 

inputs including the underlying net assets of the investments. There were no transfers in or out of Level 3 during the year.

Investments in subsidiary undertakings – Company

Cost

At 1 January 

Additions in year

At 31 December

110

lawdebenture.com

2020 
£000

2019 
£000

61,283

—

61,283

61,233

50

61,283

 
 
Notes to the accounts continued 

for the year end 31 December 2020

14.  Investments continued

Investments in subsidiaries are measured at cost less impairment. The financial statements consolidate the results and financial position 

of the Group, including all subsidiary undertakings, which are listed in this note under section “subsidiaries and related undertakings”. 

The cost of subsidiary undertakings includes capital contributions and as a consequence is not comparable to the fair value of the IPS 

business. 

Fair valuation of the IPS

The fair value of the IPS business relates to all of the wholly owned subsidiaries of the Company, with the exception of Law Debenture 

Finance p.l.c. The Directors have chosen to provide a fair valuation of the IPS business, which is not included within the financial 

statements, to assist the users of the annual report. The fair valuation is used in preparing performance data for the Group. The fair value 

is determined using unobservable inputs (including the Group’s own data), which represent Level 3 inputs. The Directors’ estimate of fair 

value uses the guidelines and methodologies on valuation published by the International Private Equity and Venture Capital Association.

The fair valuation of IPS is based upon the historic earnings before interest, taxation, depreciation and amortisation (EBITDA), an 

appropriate multiple and the surplus net assets of the business at their underlying fair value. The multiple applied in valuing IPS is from 

comparable companies sourced from market data, with appropriate adjustments to reflect the difference between the comparable 

companies and IPS in respect of growth, margin, size and liquidity.

Fair valuation of IPS

EBITDA at a multiple of 9.4 (2019: 9.2)

Surplus net assets

2020 
£000

125,349

10,605

135,954

2019 
£000

105,938

16,367

122,305

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An increase or decrease of 1 in the multiple would give rise to a £13.3m change in the fair valuation of the IPS. The adjustment to NAV to 

reflect the IPS fair value is an increase of 95.12p per share (2019: 77.70p).

Subsidiaries and related undertakings

The following is a list of all of the subsidiaries within the Law Debenture Group. Each of them is 100% owned within the Group and has been 

consolidated in the Group accounts. Subsidiaries held directly by the Company are in bold. Unless indicated, all subsidiaries are incorporated 

and have their registered office in the United Kingdom at 8th Floor, 100 Bishopsgate, London EC2N 4AG. The addresses of overseas registered 

companies appear at page 131. All shares issued by Group subsidiaries are ordinary shares. The Company and the Group do not have any 

significant holdings in any qualifying undertakings other than the subsidiary undertakings listed below. 

L.D. Pension Plan Trustee Limited 

L.D.C. Trust Management Limited 

Safecall Limited 

Safecall Training Limited 

Law Debenture Investment Management Limited 

The Whistleblowing Company Limited 

Law Debenture (Independent Professional Services) Limited 

The Sole Trustee plc 

Beagle Nominees Limited 

The Law Debenture Corporation (Deutschland) Limited 

The Law Debenture Trust Corporation p.l.c. 

L.D.C. Latvia Limited 

The Law Debenture Pension Trust Corporation p.l.c. 

Law Debenture Trustee for Charities 

Pegasus Pensions plc

Law Debenture (No. 1 Scheme) Trust Corporation 

Law Debenture Corporate Services Limited 

Law Debenture (No. 2 Scheme) Trust Corporation 

Law Debenture Trustees Limited 

Law Debenture (No. 3 Scheme) Pension Trust Corporation 

The Law Debenture Intermediary Corporation p.l.c. 

The Law Debenture (No. 5) Trust Corporation 

Law Debenture Overseas No. 1 Limited 

The Law Debenture (1996) Pension Trust Corporation 

Law Debenture Finance p.l.c. 

The Law Debenture (Airborne) Pension Trust Corporation 

Law Debenture Securitisation Services Limited 

The Law Debenture (BAA) Pension Trust Corporation 

LDPTC Nominees Limited 

The Law Debenture (BIS Management) Pension Trust Corporation 

Law Debenture Governance Services Limited 

The Law Debenture (BIS Retirement) Pension Trust Corporation 

111

 
Notes to the accounts continued 

for the year end 31 December 2020

14.  Investments continued

The Law Debenture (Freemans) Trust Corporation 

The Law Debenture (GS) Pension Trust Corporation 

The Law Debenture (Intel Old Plan) Pension Trust Corporation 

The Law Debenture (SAPP) Pension Trust Corporation 

The Law Debenture (JLPF) Pension Trust Corporation 

The Law Debenture (JLPP) Pension Trust Corporation 

The Law Debenture (JGRP) Pension Trust Corporation 

The Law Debenture (JGSPS) Pension Trust Corporation 

The Law Debenture (JIC) Pension Trust Corporation 

LDC DR Trustee Limited 

LDC DR Nominees Limited 

L.D.C. (SPV No.1) Limited 

LD (Holdco) Limited 

LD (Bidco) Limited 

The Law Debenture Corporation (HK) Limited 
(incorporated/registered office in Hong Kong)

Law Debenture Trust (Asia) Limited 
(incorporated/registered office in Hong Kong)

Law Debenture China Limited 

The Law Debenture (KBPP) Pension Trust Corporation 

(incorporated/registered office in Hong Kong)

The Law Debenture (KGPP) Pension Trust Corporation

Law Debenture Services (HK) Limited 

The Law Debenture (LBS) Pension Trust Corporation 

The Law Debenture (Swiss Re GB) Trust Corporation 

Law Debenture (Ocean) Trust Corporation 

Law Debenture (Odyssey) Trust Corporation 

(incorporated/registered office in Hong Kong)

The Law Debenture Trust Corporation (Channel Islands) Limited  
(incorporated/registered office in Jersey)

The Law Debenture Trust Corporation (Cayman) Limited  
(incorporated/registered office in the Cayman Islands)

The Law Debenture (SRL) Pension Trust Corporation 

The Law Debenture (Stena Line EPS) Pension Trust Corporation 

The Law Debenture (Tootal) Trust Corporation 

Law Debenture (GWR) Pension Trust Corporation 

Law Debenture Corporate Services Inc.  

(incorporated/registered office in the USA)

Law Debenture Holdings Inc. 
(incorporated/registered office in the USA)

The Law Debenture (JGDBS) Pension Trust Corporation 

Delaware Corporate Services Inc.  

(incorporated/registered office in the USA)

Law Debenture (Ireland) Limited  

(incorporated/registered office in the Republic of Ireland)

Law Debenture Ireland (Trustees) Limited 

(incorporated/registered office in the Republic of Ireland)

Law Debenture Holdings (Ireland) Limited 
(incorporated/registered office in the Republic of Ireland)

LDI (OCS) Limited    

(incorporated/registered office in the Republic of Ireland)

Registered Shareholder Services No.1 Limited 

(incorporated/registered office in the Republic of Ireland)

Registered Shareholder Services No.2 Limited 

(incorporated/registered office in the Republic of Ireland)

Registered Shareholder Services No.3 Limited 

(incorporated/registered office in the Republic of Ireland)

BHP SVC PTY Limited 

(incorporated/registered office in Australia)

ICI Pensions Trustee Limited 

Morgan Crucible Pension Trustees Limited 

AstraZeneca Pensions Trustee Limited  

Law Debenture MC Senior Pension Trust Corporation 

ICI Specialty Chemicals Pensions Trustee Limited 

RTL Shareholder SVC Limited 

Billiton SVC Limited 

DLC SVC Limited 

LDC (NCS) Limited 

Terrier Services Limited 

L.D.C. Securitisation Director No. 1 Limited 

L.D.C. Securitisation Director No. 2 Limited 

L.D.C. Securitisation Director No. 3 Limited 

L.D.C. Securitisation Director No. 4 Limited 

L.D.C. Corporate Director No. 1 Limited 

L.D.C. Corporate Director No. 2 Limited 

L.D.C. Corporate Director No. 3 Limited 

L.D.C. Corporate Director No. 4 Limited 

L.D.C. Corporate Director No. 5 Limited 

CD Corporate Director No. 1 Limited 

CD Corporate Director No. 2 Limited 

LDC Nominee Director No. 1 Limited 

LDC Nominee Director No. 2 Limited 

LDC Nominee Secretary Limited 

112

lawdebenture.com

 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the accounts continued 

for the year end 31 December 2020

14.  Investments continued

Unlisted investments

The Group holds an immaterial amount (approximately 0.5% of the portfolio) in unlisted investments.

Investment trust

The majority of the investment portfolio is invested in listed investments. A small minority of investments are unlisted comprising a small 

fund investment and a number of other immaterial unquoted investments.

Quarterly valuations for the small fund investment are received. The Investment Valuation Committee updates the valuation of this 

immaterial investment on a six monthly basis. The minutes of the meeting are shared with the auditors on a bi-annual basis. 

Other unquoted investment holdings are reviewed on a bi-annual basis to market value and agreed by the Committee members at the 

same Investment Valuation Committee meeting.

Independent professional services

As part of the services offered by the Independent Professional Services business, the Group acts as the registered holder of an immaterial 

amount of unlisted shares in structured finance companies which are held on trust for discretionary charitable purposes. The Group has 

no beneficial interest in those shares or the results of the companies whose shares are held. 

The holdings are reviewed on a bi-annual basis at the Investment Valuation Committee meeting but are not revalued as there is no market 

rate and the Group has no beneficial or economic interest in those shares.

15.  Trade and other receivables

The carrying value represents trade and other receivables which are not impaired. The Directors consider that the carrying value 

approximates to the fair value. 

The Group applies the IFRS 9 simplified approach to measuring expected credit losses using a lifetime expected credit loss provision for 

trade receivables. To measure expected credit losses trade receivables are grouped based on similar risk characteristics and ageing.

The expected loss rates are based on the Group’s historical credit losses experienced over the two year period prior to the period 

end. The historical loss rates are then adjusted for current and forward-looking information on macroeconomic factors affecting the 

Group’s customers.

Contract assets and contract liabilities are included within “other accrued income and prepaid expenses” and “deferred income” 

respectively on the face of the statement of financial position. They arise from the Group’s IPS business which enters into contracts that 

can take more than one year to complete. 

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Brought forward

Amounts included in contract liabilities that were recognised as 

revenue during the period

Contract 
assets
2020
£000

3,454

—

Contract 
assets
2019
£000

2,664

—

Settlement of contract assets brought forward

(3,454)

(2,664)

Invoices issued in advance of performance and not recognised as 

—

—

revenue during the period

Contract 
liabilities 
2020
£000

9,480

(6,746)

—

6,674

Contract 
liabilities 
2019
£000

9,653

(6,417)

—

6,244

Amounts included in contract assets that were recognised as revenue 

3,902

3,454

—

—

during the period

At 31 December

3,902

3,454

9,408

9,480

113

 
Notes to the accounts continued 

for the year end 31 December 2020

16.  Cash and cash equivalents

These comprise cash held at bank by the Group, short-term bank deposits with an original maturity of three months or less and money 

market funds with immediate access. The carrying value of these assets approximates to their fair value. 

17.  Trade and other payables

Trade and other payables principally comprise amounts outstanding for trade purchases and ongoing costs. The average credit period 

taken for trade purchases is 30 days.

The Directors consider that the carrying value of trade and other payables approximates to their fair value, due to their age. 

18.  Called up share capital

Allotted, issued and fully paid share capital - Group and Company

Value

As at 1 January

Issued in year

As at 31 December

Shares

As at 1 January

Issued in year

As at 31 December

2020 
£000

5,921

2

5,923

2019 
£000

5,919

2

5,921

Number

Number

118,429,010

118,381,667

    25,552

47,343

118,454,562

118,429,010

During the year to 31 December 2020, 25,552 shares (2019: 47,343 shares) were allotted under the SAYE scheme for a total consideration of 

£131,163 (2019: £244,937) which includes a premium of £129,885 (2019: £242,570).

During the year, 56,759 options were granted under the Company’s SAYE scheme. At 31 December 2020, options under the SAYE scheme 

exercisable from 2020 to 2026 at prices ranging from 495.75p to 606.00p per share were outstanding in respect of 160,485 ordinary 

shares (2019: 135,578 ordinary shares). During 2020, 6,300 options lapsed or were cancelled (2019: 25,061) and 25,552 (2019: 47,343) 

were exercised.

Further details of options outstanding are given in the Directors’ report on page 41.

Own shares held - Group

Value

Own shares held - cost

2020 
£000

2019 
£000

1,461

1,332

The own shares held represent the cost of 267,752 (2019: 204,610) ordinary shares of 5p each in the Company, acquired by the ESOT in 

the open market. The shares have been acquired to meet the requirements of the Deferred Share Plan. The voting rights relating to the 

shares have been waived while the relevant shares remain in trust, in accordance with the Plan rules. The market value of the shares at 

31 December 2020 was £1,847,489 (2019: £1,329,965). 

114

lawdebenture.com

Notes to the accounts continued 

for the year end 31 December 2020

19.  Capital reserves

GROUP

At 1 January

Transfer on disposal of investments

Net gains on investments

Cost of acquisition

Foreign exchange

Transfers to revenue

At 31 December

COMPANY

At 1 January

Transfer on disposal of investments

Net gains on investments

Cost of acquisition

Foreign exchange

Transfers to revenue

At 31 December

20.  Financial instruments

Unrealised 
appreciation 
£000

Realised  
reserves
£000

2020

Total
£000

Unrealised 
appreciation
£000

Realised 
reserves 
£000

2019

Total
£000

 181,411 

 515,708 

 697,119 

 121,273 

 482,160 

 603,433 

 (51,586)

 (27,001)

(588)

(287)

—

 101,949 

 51,586 

 10,647 

—

—

(5,299)

572,642

Unrealised 
appreciation 
£000

Realised  
reserves
£000

 (51,586)

 (27,001)

(588)

(287)

—

 51,586 

 10,647 

—

—

—  

 (22,242)

 (16,354)

 83,365 

 22,242 

 16,801 

—  

—  

 (5,495)

 181,411 

 515,708 

Unrealised 
appreciation
£000

Realised 
reserves 
£000

—  

 100,166 

 (661)

 (181)

 (5,638)

 697,119 

2019

Total
£000

—  

 (22,242)

 (16,354)

 83,365 

 22,242 

 16,801 

—  

—  

—  

 100,166 

 (661)

 (181)

 (5,495)

 (5,637)

(588)

(287)

(5,299)

674,591

2020

Total
£000

(588)

(287)

 (661)

 (181)

 (143)

 (661)

 (181)

 (142)

 174,692 

 581,025 

 755,717 

 114,554 

 547,477 

 662,031 

 (5,299)

(5,299)

 95,230 

 637,959 

 733,189 

 174,693 

 581,025 

 755,718 

The Group’s investment objective is to achieve long-term capital growth through investing in a diverse portfolio of investments. In pursuit 

of this objective, the Group has the power to deploy the following financial instruments:

•  Quoted equities, unlisted equities and fixed interest securities
•  Cash and short-term investments and deposits
•  Debentures, term loans and bank overdrafts to allow the Group to raise finance
•  Derivative transactions to manage any of the risks arising from the use of the above instruments
•  Derivative transactions to hedge the net investment in overseas subsidiaries

It remains the Group’s policy that no trading in derivatives is undertaken. Information in respect of the investment portfolio is included on 

pages 18 to 31. 

Capital management

The Company is not allowed to retain more than 15% of its income from shares and securities each year and has a policy to increase 

dividends. However revenue profits are calculated after all expenses. Distributions will not be made if they inhibit the investment 

strategy. This policy on dividends is expected to continue going forwards. The investment strategy of the Company is disclosed on page 

32 and includes a ceiling on effective gearing of 50%, with a typical range of 10% net cash to 20% gearing. At 31 December 2020 gearing 

was 9% (2019: 5% restated). Gearing is calculated in line with net gearing guidelines from the AIC.

Capital is represented by the Group’s net assets.

115

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Notes to the accounts continued 

for the year end 31 December 2020

20.  Financial instruments continued

The Group and Company held the following categories of financial assets and liabilities at 31 December 2020:

GROUP

Assets  
Financial assets held at fair value through profit or loss:

Equity investments

Financial assets held at amortised cost

Trade and other receivables

Cash and cash equivalents

Total financial assets

Liabilities

Financial liabilities measured at amortised cost

Trade and other payables

Long-term borrowings

Lease liability

Total financial liabilities

COMPANY

Assets  
Financial assets held at fair value through profit or loss: 

Equity investments

Financial assets held at amortised cost

Trade and other receivables

Cash and cash equivalents

Total financial assets

Liabilities 

Financial liabilities measured at amortised cost

Amounts owed to subsidiary undertakings

Trade and other payables

Long-term borrowings

Total financial liabilities

116

lawdebenture.com

2020
£000

2019
£000

812,297

822,316

16,129

41,762

57,891

7,213

71,236

78,449

870,188

900,765

27,405

114,201

5,606

147,212

13,010

114,157

1,080

128,247

2020
£000

2019
£000

812,083

822,102

4,084

32,098

36,182

542

46,128

46,670

848,265

868,772

61,698

13,075

74,569

149,342

53,990

1,420

74,551

129,961

Notes to the accounts continued 

for the year end 31 December 2020

20.  Financial instruments continued

The principal risks facing the Group in respect of its financial instruments remain unchanged from 2019 and are:

Market risk

Price risk, arising from uncertainty in the future value of financial instruments. The Board maintains strategy guidelines whereby risk is 

spread over a range of investments, the number of holdings normally being between 70 and 150. In addition, the stock selections and 

transactions are actively monitored throughout the year by the investment manager, who reports to the Board on a regular basis to 

review past performance and develop future strategy. The investment portfolio is exposed to market price fluctuation: if the valuation at 

31 December 2020 fell or rose by 10%, the impact on the Group’s total profit or loss for the year would have been £81.2m (2019: £82.2m). 

Corresponding 10% changes in the valuation of the investment portfolio on the Company’s total profit or loss for the year would have 

been £81.2m (2019: £82.2m).

Foreign currency risk, arising from movements in currency rates applicable to the Group’s investment in equities and fixed interest 

securities and the net assets of the Group’s overseas subsidiaries denominated in currencies other than sterling. The Group’s financial 

assets denominated in currencies other than sterling were:

GROUP

US Dollar

Canadian Dollar

Euro

Danish Krone

Swedish Krona

Swiss Franc

Hong Kong Dollar

Japanese Yen

Investments 
£m

Net monetary 
assets 
£m

Total currency  
exposure
£m

Investments 
£m

Net monetary 
assets 
£m

Total currency  
exposure
£m

2020

2019

40.1

5.5

65.2

2.3

—

9.5

—

9.3

131.9

 11.7 

—

 0.4 

—

—

—

 1.0 

—

 13.1 

51.8

5.5

65.6

2.3

—

9.5

 1.0 

9.3

145.0

70.7

7.2

49.6

2.9

1.0

11.0

—

8.7

151.1

5.0

— 

0.7

—

—

—

0.4

—

6.1

75.7

7.2

50.3

2.9

1.0

11.0

0.4

8.7

157.2

The Group US dollar net monetary assets is that held by the US operations of £1.4m (2019: £3.1m) together with £10.3m (2019: £1.2m) held by 

non-US operations.

COMPANY

US Dollar

Canadian Dollar

Euro

Danish Krone

Swedish Krona

Swiss Franc

Japanese Yen

Investments 
£m

Net monetary 
assets 
£m

Total currency  
exposure
£m

Investments 
£m

Net monetary 
(liabilities) 
£m

Total currency  
exposure
£m

2020

2019

40.1

5.5

65.2

2.3

—

9.5

9.3

131.9

 9.9 

—

—

—

—

—

—

50.0

5.5

65.2

2.3

—

9.5

9.3

 9.9 

141.8

70.7

7.2

49.6

2.9

1.0

11.0

8.7

151.1

0.1

— 

—

—

—

—

—

0.1

70.8

7.2

49.6

2.9

1.0

11.0

8.7

151.2

117

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Notes to the accounts continued 

for the year end 31 December 2020

20.  Financial instruments continued

The holding in Scottish Oriental Smaller Companies Trust is denominated in sterling but has underlying assets in foreign currencies 

equivalent to £7.1m (2019: £7.2m which included £23.0m in Baillie Gifford Pacific and Stewart Investors Asia Pacific OEICs which were sold 

in 2019). Investments made in the UK and overseas have underlying assets and income streams in foreign currencies which cannot easily 

be determined and have not been included in the sensitivity analysis. If the value of all other currencies at 31 December 2020 rose or fell 

by 10% against sterling, the impact on the Group’s total profit or loss for the year would have been £15.5m and £12.5m respectively (2019: 

£17.6m and £14.2m). Corresponding 10% changes in currency values on the Company’s total profit or loss for the year would have been the 

same. The calculations are based on the investment portfolio at the respective year end dates and are not representative of the year as a 

whole.

Interest rate risk, arising from movements in interest rates on borrowing, deposits and short-term investments. The Board reviews the mix 
of fixed and floating rate exposures and ensures that gearing levels are appropriate to the current and anticipated market environment. 

The Group’s interest rate profile was:

Floating rate assets

Sterling

HK Dollars 

US Dollars 

£m

28.2

£m

 1.0 

£m

 11.7 

Floating rate assets

Sterling
£m

65.1

HK Dollars 
£m

US Dollars 
£m

0.4

5.0

GROUP

Euro 

£m

 0.4 

GROUP

Euro 
£m

0.7

2020

COMPANY

Sterling 

US Dollars 

£m

22.0

£m

 9.9 

2019

Sterling 
£m

46.0

COMPANY

US Dollars 
£m

0.1

The Group holds cash and cash equivalents on short-term bank deposits and money market funds. Interest rates tend to vary with bank 

base rates. The investment portfolio is not directly exposed to interest rate risk.

Fixed rate liabilities

2020 
Sterling 
£m

114.2

GROUP

2019 
Sterling 
£m

114.2

2020 
Sterling 
£m

74.5

COMPANY

2019
Sterling 
£m

74.6

Weighted average fixed rate for the year

4.589%

4.589%

3.770%

3.770%

If interest rates during the year were 1.0% higher the impact on the Group’s total profit or loss for the year would have been £458,000 

credit (2019: £791,000 credit). It is assumed that interest rates are unlikely to fall below the current level.

The Company holds cash and cash equivalents on short-term bank deposits and money market funds, it also has short-term borrowings. 

Amounts owed to subsidiary undertakings include £40m at a fixed rate. Interest rates on cash and cash equivalents and amounts due 

to subsidiary undertakings at floating rates tend to vary with bank base rates. A 1.0% increase in interest rates would have affected 

the Company’s profit or loss for the year by £317,000 credit (2019: £593,000 credit). The calculations are based on the balances at the 

respective year end dates and are not representative of the year as a whole.

Liquidity risk

Is the risk arising from any difficulty in realising assets or raising funds to meet commitments associated with any of the above financial 

instruments. To minimise this risk, the Board’s strategy largely limits investments to equities and fixed interest securities quoted in major 

financial markets. In addition, cash balances are maintained commensurate with likely future settlements. The maturity of the Group’s 

existing borrowings is set out in note 21. The interest on borrowings is paid bi-annually on March and September for the 2045 secured 

senior notes and April and October for the 2034 secured bonds.

118

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Notes to the accounts continued 

for the year end 31 December 2020

20.  Financial instruments continued

Credit risk

Is the risk arising from the failure of another party to perform according to the terms of their contract. The Group minimises credit 

risk through policies which restrict deposits to highly rated financial institutions and restrict the maximum exposure to any individual 

financial institution. The Group’s maximum exposure to credit risk arising from financial assets is £57.9m (2019: £78.4m). The Company’s 

maximum exposure to credit risk arising from financial assets is £36.2m (2019: 46.7m).

Stock lending

Stock lending agreements are transactions in which the Group lends securities for a fee and receives cash as collateral. The Group 

continues to recognise the securities in their entirety in the statement of financial position because it retains substantially all of the risks 

and rewards of ownership. Because as part of the lending arrangement the Group sells the contractual rights to the cash flows of the 

securities, it does not have the ability to use the transferred assets during the term of the arrangement. 

Stock lending transactions are carried out with a number of approved counterparties. Details of the value of securities on loan at the year 

end can be found in note 28. In summary, the Group only transacts with counterparties that it considers to be credit worthy. 

Trade and other receivables

Trade and other receivables not impaired but past due by the following:

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Between 31 and 60 days

Between 61 and 90 days

More than 91 days

Total

IFRS 9 credit loss rates

2020 
£000

1,550

 1,044 

4,804

7,398

GROUP

2019 
£000

 1,225 

 219 

 2,330 

 3,774 

COMPANY

2019 
£000

2020 
£000

—

—

—

—

—

—

—

—

The Group applies the IFRS 9 simplified approach to measuring expected credit losses using a lifetime expected credit loss provision for 

trade receivables and contract assets. To measure expected credit losses trade receivables are grouped based on similar risk characteristics 

including business area and business geography and ageing.

The expected loss rates are based on the Company’s historical credit losses experienced over a three-year period prior to the year end. The 

historical loss rates are adjusted for current and forward-looking information on macroeconomic factors affecting the Company’s customers. 

The Group has identified gross domestic product (GDP) and unemployment trends act as key economic indicators which may impact our 

customers’ future ability to pay debt. At 31 December 2020 the provision in relation to IFRS 9 resulting from credit loss rates is £790,000.

The below table display the gross carrying amount against the expected credit loss provision on Group trade receivables. Excluded from 

the table below are specific provisions of £2,416,000 which relate to balances 91+ days overdue.

The total specific and credit loss provision at 31 December 2020 is £3,206,000 (2019: £2,907,000).

31 December 2020

Expected loss rate

Gross carrying amount (£000)

Loss provision (£000)

31 December 2019

Expected loss rate

Gross carrying amount (£000)

Loss provision (£000)

Current

£000

4.04%

1,781

(72)

2.54%

1,733

(44)

1-30 days 

31-60 days 

61-90 days 

overdue

£000

overdue

£000

overdue

£000

6.23%

1,638

(102)

4.16%

1,129

(47)

4.43%

1,557

(96)

5.85%

991

(58)

8.01%

724

(58)

0%

181

—

91+ days  

overdue

£000

6.66%

6,938

(462)

3.27%

3,637

(119)

Total

£000

6.25%

12,638

(790)

3.49%

7,670

(268)

119

 
Notes to the accounts continued 

for the year end 31 December 2020

20.  Financial instruments continued

Trade and other payables

Due in less than one month

Due in more than one month and less than three months

2020 
£000

27,139

 266 

27,405

GROUP

2019 
£000

 12,686 

 324 

 13,010 

2020 
£000

13,075

—

13,075

COMPANY

2019 
£000

1,420

—

1,420

Fair value

The Directors are of the opinion that the fair value of financial assets and liabilities of the Group are not materially different to their 

carrying values, with the exception of the long-term borrowings (see note 21). The Group’s basis of fair value calculation on these long-term 

borrowings uses quoted prices (unadjusted) in active markets for identical liabilities that the entity can access at the measurement date. 

The Group does not make adjustments to quoted prices, only under specific circumstances, for example when a quoted price does not 

represent the fair value (i.e. when a significant event takes place between the measurement date and market closing date).

Derecognition – financial assets

The Group enters into stock lending transactions whereby it transfers assets recognised on its statement of financial position, but retains 

either all or substantially all of the risks and rewards of the transferred assets or a portion of them. In such cases, the transferred assets are 

not derecognised.

21.  Long-term borrowings

Long-term borrowings are repayable as follows: 

In more than five years

Secured

6.125% guaranteed secured bonds 2034

3.77% secured senior notes 2045

2020 
£000

GROUP

2019 
£000

COMPANY

2019 
£000

2020 
£000

39,632 

74,569

114,201

39,606

74,551

114,157

—

74,569

74,569

—

74,551

74,551

The 6.125% bonds were issued by Law Debenture Finance p.l.c. and guaranteed by the Company. The £40m nominal tranche, which 

produced proceeds of £39.1m, is constituted by a trust deed dated 12 October 1999 and the Company’s guarantee is secured by a floating 

charge on the undertaking and assets of the Company. The bonds are redeemable at nominal amount on 12 October 2034. Interest (see 

note 6) is payable semi-annually in equal instalments on 12 April and 12 October in each year.

The 3.77% notes were issued by the Company. The £75m nominal tranche, which produced proceeds of £74.5m, is constituted by a note 

purchase agreement and the notes are secured by a floating charge which ranked pari passu with the charge given as part of the 6.125% 

bond issue. The notes are redeemable at nominal amount on 25 September 2045. Interest (see note 6) is payable semi-annually in equal 

instalments on 25 March and 25 September in each year.

The long-term borrowings are stated in the statement of financial position at book value. Including them at a fair value of £166.4m at 

31 December 2020 (2019: £151.2m) would have the effect of decreasing the year end NAV by 44.16p (2019: 31.29p). The estimated fair value 

is based on the redemption yield of reference gilts plus a margin derived from the spread of A rated UK corporate bond yields over UK gilt 

yields (2019: A).

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Notes to the accounts continued 

for the year end 31 December 2020

22.  Contingent liabilities

The Group is from time to time party to legal proceedings and claims, which arise in the ordinary course of the IPS business. The Directors 

do not believe that the outcome of any of these proceedings and claims, either individually or in aggregate, will have a material adverse 

effect upon the Group’s financial position.

The Company has provided a guarantee to a subsidiary undertaking in respect of the ongoing liabilities of the Group defined benefit 

pension scheme (see note 24). The Company has provided surety for the lease of the Group’s main property which is held by a subsidiary 

undertaking. The annual rental is currently £871,000 and its full term ends in 2030. The Company provided a guarantee in respect of 

liabilities that could arise from its US corporate trust business in the period before the business was sold. The guarantee ended in 2019.

23.  Leases

i)  Definition of a lease

The Group determines at contract inception whether an arrangement contains a lease. Under IFRS 16, a contract is, or contains, a lease if 

the contract conveys a right to control the use of an identified asset for a period of time in exchange for consideration.

The Group leases various office properties. Rental contracts are typically made for fixed periods of 1 to 10 years and lease terms are 

negotiated on an individual basis.

All leases are accounted for by recognising a right-of-use asset and a lease liability except for: 

•  Leases of low value assets (under £5,000); and 

•  Leases with a duration of 12 months or less. 

Lease liabilities are initially measured at the present value of the lease payments that are not paid at the commencement date, discounted 

using the interest rate implicit in the lease. If that rate cannot be readily determined, the Group’s incremental borrowing rate is used. 

Generally, the Group uses its incremental borrowing rate as the Group’s borrowing rate which is 4.589% as of 1 January 2020.

The lease liability is subsequently increased by the interest cost on the lease liability and decreased by lease payments made. It is 

remeasured when there is a change to future lease payments arising from a change in an index rate, a change in the estimate of the 

amount expected to be payable under the residual value guarantee, or as appropriate, changes in the assessment of whether a purchase 

or extension option is reasonably certain to be exercised or a termination option is reasonably certain not to be exercised.

Right of use assets are initially measured at the amount of the lease liability, reduced for any lease incentives received, and increased for: 

•  Lease payments made at or before commencement of the lease; 

• 

• 

Initial direct costs incurred; and 

 The amount of any provision recognised where the Group is contractually required to dismantle, remove or restore the leased asset 

(typically leasehold dilapidations). 

When the Group revises its estimate of the term of any lease (because, for example, it re-assesses the probability of a lessee extension or 

termination option being exercised), it adjusts the carrying amount of the lease liability to reflect the payments to make over the revised 

term, which are discounted using a revised discount rate. The carrying value of lease liabilities is similarly revised when the variable 
element of future lease payments dependent on a rate or index is revised, except the discount rate remains unchanged. In both cases an 

equivalent adjustment is made to the carrying value of the right-of-use asset, with the revised carrying amount being amortised over the 

remaining (revised) lease term. If the carrying amount of the right-of-use asset is adjusted to zero, any further reduction is recognised in 

profit or loss.

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Notes to the accounts continued 

for the year end 31 December 2020

23.  Leases continued

Right-of-use asset 
Additional information on the right-of-use assets is as follows:

Opening balance at 1 January

Leases signed in year

Lease extension

Depreciation

Foreign exchange difference

Closing NBV at 31 December 

Lease liabilities 
Lease liabilities are presented in the statement of financial position as follows:

Current

Non-Current

Total lease liability

ii)  Leases signed in the year

Office building leases

Total right-of-use assets

31 December 
2020 
£000

31 December 
2019 
£000

31 December 
2020 
£000

31 December 
2019 
£000

GROUP

 1,057 

 5,157 

 388 

 (1,179)

(10) 

 5,413 

 2,009 

 149 

—

 (1,101)

—

 1,057 

 1,057 

 5,157 

 388 

 (1,179)

 (10) 

 5,413 

 2,009 

 149 

—

 (1,101)

—

 1,057 

GROUP

31 December 
2020 
£000

31 December 
2019 
£000

—

5,606

5,606

730

350

1,080

During the year the Group signed a 10-year lease for its new London Headquarters at 100 Bishopsgate. On the lease commencement 

date the Group recognised a right-of-use asset of £5,157,000 and leasehold liability of £5,263,000. The right-of-use asset is recognised at 

leasehold liability (£5,263,000), plus capitalised direct costs (£233,000), estimated costs of removal and restoring (£180,000) less landlord 

lease incentives received (£519,000).

24.  Pension commitments

For some employees, the Group operates a funded pension plan providing benefits for its employees based on final pensionable 

emoluments. The assets of the plan are held in a separate trustee administered fund. The Company has appointed an independent 

sole trustee to oversee the governance of the fund. The plan closed to future accrual of benefits on 31 December 2016 and benefits now 

increase broadly in line with inflation. 

Under the defined benefit pension plan, each member’s pension at retirement is related to their pensionable service and final 

pensionable emoluments. The weighted average duration of the expected benefit payments from the plan is around 20 years. The defined 

benefit scheme is operated from a trust, which has assets which are held separately from the Group and is overseen by an independent 

sole trustee who ensures the plan’s rules are strictly followed.

These figures were prepared by an independent qualified actuary in accordance with IAS19 (revised), and are based on membership 

data as at 31 December 2020. The funding target is for the plan to hold assets equal in value to the accrued benefits based on projected 

pensionable emoluments. If there is a shortfall against this target, then the Group and the Trustee will agree deficit contributions to meet 

this deficit over a period.

There is a risk to the Group that adverse experience could lead to a requirement for the Group to make additional contributions to reduce 

any deficit that arises.

122

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Notes to the accounts continued 

for the year end 31 December 2020

24.  Pension commitments continued

Contributions are set based upon funding valuations carried out every three years; the next valuation in respect of 31 December 2020 is 

currently underway. The estimated amount of total employer contributions expected to be paid to the plan during 2021 is £1.0m (2020 

actual: £0.9m).

Actuarial gains and losses are recognised immediately through other comprehensive income.

The major assumptions in the 31 December 2020 disclosure under IAS19 (revised) are shown below and are applied to membership data 

supplied at that date. This shows the net pension assets and liabilities.

Significant actuarial assumptions:

Retail Price Inflation

Consumer Price Inflation*

Discount rate

5% limited RPI pension increases in payment

General salary increases

* Relates to dividends unclaimed over 12 years old.

Life expectancy of male/female aged 65 in 2020

Life expectancy of male/female aged 65 in 2040

Weighted average duration

The amounts recognised in the income statement are as follows:

Interest income

Total (income)/expense recognised in the income statement

The current allocation of plan assets is as follows:

Equities

Bonds

Gilts

Pensioner annuities

Diversified growth funds

Infrastructure

Cash/other

Total

2020

2019

2.80%

2.20%

1.30%

n/a

n/a

2.90%

2.10%

2.10%

n/a

n/a

2020 
years

2019 
years

23.7/25.5

23.6 / 25.4

25.5/27.0

25.4 / 26.9

19.1

19.3

2020 
£000

—

—

Allocation %

50

9

25

1

13

—

2

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A
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N
T
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2019 
£000

(100)

(100)

2019

£000

30,000

5,600

14,900

700

8,100

—

1,200

Allocation %

41

9

24

1

13

10

2

2020

£000

25,800

5,900

15,000

800

8,300

6,000

1,200

100

63,000

100

60,500

• 

• 

• 

 The Plan holds a number of pensioner annuities which have been valued consistently with the defined benefit obligation using 

membership data as at 1 January 2021.

 At the time of writing, the value of the JP Morgan infrastructure fund on 31 December 2020 is unavailable. Therefore, the value of £6.0m 

used is at an effective date of 1 October 2020.

 The Plan's non-annuity assets are invested in pooled funds, which are not themselves quoted. However the pooled funds are invested in 

assets with prices quoted and traded on public exchanges. The exception to this is the JP Morgan infrastructure fund, where underlying 

investments are not quoted.

123

 
Notes to the accounts continued 

for the year end 31 December 2020

24.  Pension commitments continued

Reconciliation of present value of defined benefit obligation

At 1 January

Interest on plan liabilities

Actuarial losses/(gains) due to:

Experience on benefit obligations

Changes in financial assumptions

Changes in demographic assumptions

Benefits paid

Update to 31 December 2020 membership data (gain)/loss

At 31 December

Reconciliation of fair value of plan assets

At 1 January

Interest on plan assets

Actual returns net of interest

Contributions by the employer

Benefits paid

At 31 December

2020 
£000

2019 
£000

57,800

1,200

(400)

9,100

—

(1,600)

(300)

65,800

51,600

1,500

(100)

6,200

—

(1,400)

—

57,800

2020 
£000

2019 
£000

60,500

1,200

1,900

1,000

(1,600)

63,000

54,100

1,600

5,300

900

(1,400)

60,500

The pension plan is exposed to investment risk, (the movement of the discount rate used against the value of the plans assets,) interest rate 

risk (decreases/increases in the discount rate which will increase/decrease the defined benefit obligation) and longevity risk (changes in 

the estimation of mortality rates of members).

2020 
£000

2019 
£000

(2,700)

(2,500)

—

6,500

(1,000)

2,800

(100)

800

(900)

(2,700)

2020 
£000

2019 
£000

65,800

57,800

(63,000)

(60,500)

2,800

(2,700)

Movement in the net defined benefit obligations

(Asset) at 1 January

(Income)/expense charged to profit and loss

Amount recognised outside of profit and loss

Employer contributions

Closing net liability/(assets) at 31 December

Plan assets and obligations

Present value of defined benefit 

obligation

Fair value of plan assets

Deficit/(asset)

124

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Notes to the accounts continued 

for the year end 31 December 2020

24.  Pension commitments continued

Over the year to 31 December 2020, the balance sheet deteriorated from a surplus of £2.7m to a deficit of £2.8m.

This is driven by:

•  a significant decrease in the discount rate during the year, which increases the value of the pension obligations.

This was partially offset by:

• 

investment returns on assets being higher than anticipated; and

•  deficit reduction contributions paid by the Company of £1.0m during the year.

25.  Related party transactions

Group

Transactions between the Company and its subsidiaries, which are related parties, have been eliminated on consolidation.

Company

The related party transactions between the Company and its wholly owned subsidiary undertakings are summarised as follows:

Dividends from subsidiaries

Interest on intercompany balances charged by subsidiaries

Management charges from subsidiaries

2020 
£000

13,709 

2,378

700

2019 
£000

3,000

2,562

600

The key management personnel are the Directors of the Company. Details of their compensation are included in note 5 to the accounts 

and in Part 2 of the remuneration report on pages 67 to 82. Key management personnel costs inclusive of employers national insurance 

are £1,352,977 (2019: £1,529,583).

26.  Movement in borrowings

Under IAS 7, the movement in borrowings in the year are as follows:

GROUP

Long-term borrowings

6.125% guaranteed secured bonds 2034

3.77% secured senior notes 2045

COMPANY

Long-term borrowings

3.77% secured senior notes 2045

31 December 
2020 
£000

Non-cash items 
movement
£000

31 December 
2019
£000

Non-cash items 
movement
£000

31 December 
2018
£000

 39,632 

 74,569 

 114,201 

 74,569 

 74,569 

 26 

 18 

 44 

 18 

 18 

 39,606 

 74,551 

 114,157 

 74,551 

 74,551 

 28 

 17 

 45 

 17 

 17 

 39,578 

 74,534 

 114,112 

 74,534 

 74,534 

The Group had no short-term borrowings in 2020 (2019: nil).

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Notes to the accounts continued 

for the year end 31 December 2020

27.  Distributable reserves

All historical dividend payments have been made from revenue reserves. After paying the final dividend, the Company has retained 

earnings to pay 0.1 years of dividend payments at the current level. After paying the final dividend, the Group has retained earnings to 

pay 0.8 years of dividends at the current level. The Company has realised capital reserves of £637,959,000 (2019: £581,025,000) which 

would allow 19.6 (2019: 18.9) years of dividend payments at the current level. The Group has realised capital reserves of £572,642,000 

(2019: £151,708,000) which would allow 17.6 (2019: 16.8) years of dividend payments at the current level. The Company does not intend to 

make dividend payments from capital reserves.

28.  Stock lending revenue

At 31 December 2020 the total value of securities on loan by the Company for stock lending purposes was £19,325,000 (2019: nil). The 

maximum aggregate value of securities on loan at any one time during the year ended 31 December 2020 was £38,936,000 (2019: nil). 

Revenue derived from stock lending in 2020 is £219,000 (2019: nil).

29.  Subsequent events

i)  Acquisition

On 29 January 2021, the Group completed an acquisition of the company secretarial business (CSS) of Konexo UK, a division of Eversheds 

Sutherland (International) LLP. The principal reason for this acquisition was to acquire a complementary business to the Group's 

existing IPS offering, to increase our market share in this area of professional services and to support our stated objective to provide our 

shareholders with a steadily increasing source of income. The total consideration for the acquisition is £20 million, paid in cash. Under the 

terms of the purchase agreement, Law Debenture has agreed to acquire the business on a cash and debt free basis. For the financial year 

ended 30 April 2020, CSS recorded revenues of £6.2m, estimated EBITDA of £2.2m. The acquisition completed at the end of January 2021. 

Established for fifteen years, CSS is a respected part of the Konexo business with UK and international sector expertise. The transferring 

team has 55 employees, with 15 based in London, 1 in Hong Kong and the remainder in Manchester. The business services a client base of 

c.450 in more than 100 jurisdictions.

ii)  Overdraft

During January 2021, the Company made arrangements to put in place a £50m unsecured overdraft facility. Interest is charged monthly in 

arrears at a an aggregate of 1.5% plus base rate, and there are no additional fees for this facility.

126 lawdebenture.com

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The photograph shown is Winner – Best Overall Picture of the annual LawDeb Lens competition.
Photo credit: Doug Moody

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Alternative performance measures

Alternative performance measures are numerical measures of the Company’s current, historical or future performance, financial position 

or cash flows, other than financial measures defined or specified in the financial framework that the Company has chosen to apply 

(International Financial Reporting Standards and the AIC SORP). The Directors use these measures as a means of assessing the Company’s 

performance. The measures are particularly relevant for investment trusts and are widely used across the investment trust sector. 

Net Asset Value per ordinary share

The value of the Company’s assets (i.e. investments (see note 14)) and cash at bank (see Statement of Financial Position) less any liabilities 

(i.e. long-term borrowings (see note 21)) for which the Company is responsible, divided by the number of shares in issue (see note 10). 

The aggregate NAV is also referred to as total shareholders’ funds in the Statement of Financial Position. In Law Debenture’s case, the 

published NAV will include adjustments to reflect the fair value of the IPS business and the Company’s long-term debt. There is a detailed 

summary of the NAV, including a description of how it is calculated, on page 37 of the annual report. From 1 July 2020, the NAV per 

ordinary share is published daily. Prior to that it was published weekly and immediately after each month end.

The change in NAV per share (see total return below) over one, three, five and ten years, as shown at page 3, is calculated by taking total 

return over the respective period and dividing by the opening NAV at the start of each period.

Net Asset Value with Debt at Fair Value

The Group’s debt (long-term borrowings, further details can be found in note 21 on page 120) is valued in the Statement of Financial 

Position (page 93) at amortised cost, which is materially equivalent to the repayment value of the debt on the assumption that it is held 

to maturity. This is often referred to as ‘Debt at Par’. The current fair value of the debt, which assumes it is repaid under current market 

conditions, is referred to as ‘Debt at Fair Value’. This fair value is detailed in note 20 on page 120. The difference between the fair and par 

values of the debt is subtracted from or added to the Statement of Financial Position to derive the NAV with debt at fair value (see note 10 

on page 108). The NAV with debt at fair value at 31 December 2020 was £726,994,000 (666.15 pence per ordinary share) and the NAV with 

debt at par was £787,219,000 (710.31 pence per ordinary share).

Discount or Premium

The amount by which the market price per share of an investment trust is either higher (premium) or lower (discount) than the NAV per 

share, expressed as a percentage of the NAV per ordinary share.

At 31 December 2020

At 31 December 2019

Gearing/(Net cash)

NAV per share 
at fair value 
pence

NAV per share 
at par value 
pence

Share price 
pence

Premium/ 
(discount) to 
fair value NAV

Premium/ 
(discount) to 
par value NAV

 666.15 

 702.17 

 710.31 

 733.46 

690

650

3.6 

(7.4)

(2.9)

(11.4)

Net gearing is calculated by dividing total borrowings less cash and cash equivalents by shareholders’ funds, expressed as a percentage. 

Borrowings  

Statement of financial position

Cash and cash equivalents  

Statement of financial position

2020 
£000

2019 
£000

 114,201 

 114,157 

 (41,762)

 (71,236)

Borrowings less cash 

(a)

 72,439 

 42,921 

Net assets per Balance Sheet

Fair value uplift for IPS business

Debt fair value adjustment

Shareholders’ funds 

Net gearing

128 lawdebenture.com

Page 37

(b)

 (a/b) 

726,994 

 775,272 

112,407 

 91,860 

(52,182)

 (36,993)

 787,219 

 830,139 

9%

5%

Alternative performance measures continued

We have reviewed our approach to the calculation of gearing. We believe that it is appropriate to show net gearing in relation to 

shareholders’ funds as it represents the amount of debt funding on the investment portfolio.

Ongoing charges

The ongoing charge ratio has been calculated in accordance with guidance issued by the AIC. It represents the total investment  

management fee and other administrative expenses expressed as a percentage of the average net asset values with debt at fair value 

throughout the year.

Management fee revenue expense

Other administration costs

Administration costs (see note 7 )

Management fee capital expense

Ongoing charge

Average net assets1

Ongoing charge ratio

1  Calculated using the average month-end net asset value with debt at fair value.

Revenue Earnings per Share

2020 
£000

 447 

 2,123 

 2,570 

 1,341 

 3,911 

2019 
£000

 512 

 1,674 

 2,186 

 1,537 

 3,723 

 717,235 

 770,001 

0.55%

0.48%

The revenue earnings per share is the revenue return for the year (see Income Statement) divided by the weighted average number of 

ordinary shares in issue during the year (see note 10 on page 108).

NAV Total Return

The total return is the return on the share price or NAV with debt at fair value taking into account both the rise and fall of NAVs/share 

prices and dividends paid to shareholders. Any dividends received by a shareholder are assumed to have been reinvested in either 

additional shares (for share price total return) or the Company’s assets (for NAV with debt at fair value total return). Dividends paid and 

payable are set out in note 9 on page 107.

NAV/Share price per share at 31 December 2019 (pence)

NAV/Share price per share at 31 December 2020 (pence)

Change in the year (%)

Impact of dividends reinvested (%)

Total return for the year (%)

Yield

The yield is the annual dividend expressed as a percentage of the year end share price.

Annual dividend (pence)

Share price (pence)

Yield (C = A / B) (%)

NAV per share 
with debt at  
fair value

Share price

702.17

666.15

(5.1)

 7.1 

 2.0 

2020 
£000

27

690

3.9%

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A
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I

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650

690

 6.2 

 6.7 

 12.9 

2019 
£000

26

650

4.0%

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Company advisers and information

Registered office

Broker

8th Floor, 100 Bishopsgate, London, EC2N 4AG

T:  020 7606 5451 

F:   020 7606 0643 

W: www.lawdebenture.com

(Registered in England – No. 30397)

Investment managers

J.P. Morgan Cazenove Limited 

25 Bank Street, London E14 5JP

AIC

A member of the Association of Investment 

Companies

James Henderson and Laura Foll are joint managers. They also manage 

Lowland Investment Company plc, Henderson Opportunities Trust plc 

Shareholder information

and the Henderson UK Equity Income & Growth Fund. 

James joined Henderson Global Investors (now Janus Henderson 

Investors) in 1983 and has been an investment trust portfolio manager 
since 1990. He first became involved in the management of Law 

Debenture’s portfolio in 1994 and took over lead responsibility for 

management of the portfolio in June 2003. 

Investment trust status
The Company carries on business as an investment trust company 

as defined in Sections 1158-1159 of the Corporation Tax Act 2010. 

Company share information
Information about the Company can be found on its website 

www.lawdebenture.com. The market price of its ordinary shares is 

Laura joined Janus Henderson Investors in 2009 and has held the 

also published daily in the Financial Times.

position of portfolio manager on the Global Equity Income team 

since 2014. She first became involved with Law Debenture’s portfolio 

in September 2011 and became joint portfolio manager in 2019.

Alternative Investment Fund Manager

The Law Debenture Corporation p.l.c.

Investment portfolio manager

Janus Henderson Global Investors 

201 Bishopsgate, London EC2M 3AE

Auditors

BDO LLP, 55 Baker Street, London W1U 7EU

Depositary 

Registrars
Our registrars, Computershare Investor Services PLC, operate a 

dedicated telephone service for Law Debenture shareholders 

– 0370 707 1129. Shareholders can use this number to access 

holding balances, dividend payment details, share price data, or 

to request that a form be sent to their registered address.

Share dealing
Computershare Investor Services PLC offers shareholders a share 

dealing service via the internet or by telephone, details of which 

are as follows:

www.computershare.trade
T:  0370 703 0084

Commission for the internet service is 1% with a minimum charge 

of £30 and 1% for the telephone service, plus £50. 

The service is available only to those shareholders who hold their 

shares on the register (i.e. it is not available to those who hold 

NatWest Trustee and Depositary Services Limited 

their shares via a nominee).

250 Bishopsgate, London EC2M 4AA

Global custodian

HSBC Bank plc (under delegation by the depositary) 

8 Canada Square, London E14 5HQ

Registrar 

Computershare Investor Services PLC 

The Pavilions, Bridgwater Road, Bristol BS99 6ZZ

Shareholders using the internet service will need their 

Shareholder Reference Number (SRN) and post code to complete 

their trade. The SRN can be found printed on your proxy card.

Computershare Brokerage Services are provided by The Share 

Centre Ltd, which is a member of the London Stock Exchange 

and is authorised and regulated by the FCA. The Company is not 

responsible or liable for anything arising from a shareholder’s 

decision to use the service. The Company is not acting as an 

introducer for the share dealing service and receives no financial 

benefit, either from making shareholders aware of the service 

or from any share deals conducted by shareholders who use 

T:  0370 707 1129

the service.

130 lawdebenture.com

Financial calendar

Dividend and interest payments

Ordinary shares: 

Three interim dividends 

Final dividend 

Announced in June, September and December

Paid, July, October and January

Announced in February 

Paid April

6.125% guaranteed secured notes 

Paid April and October

3.77% senior secured notes 

Paid March and September

Group results:

Half year results 

Full year results 

Report and accounts 

Annual general meeting 

Factsheets 

Announced in July

Announced in February

Published in March

Held each year in April

Published monthly on the Company’s website

Payment methods for dividends

Dividends and interest can be paid to shareholders by means of BACS. Mandate forms for this purpose are available on request from the 

Company’s registrars.

Subsidiary company details

Subsidiary companies not incorporated in the United Kingdom, as listed at pages 111 and 112, are registered at the following addresses:

Companies registered in Hong Kong  

 Suite 1301 Ruttonjee House, Ruttonjee Centre,  

11 Duddell Street, Central, Hong Kong

Companies registered in the Republic of Ireland 

38/39 Fitzwilliam Square, Dublin 2, Ireland

Companies registered in USA 
other than Delaware Corporate Services 

801 2nd Avenue, Suite 403, New York,  

NY 10017, USA 

Companies registered in USA -  
Delaware Corporate Services 

919 N Market St, Suite 725, Wilmington,  

DE 19801, USA 

Company registered in Jersey 

 3rd Floor, Standard Bank House, 47-49 La Motte Street, 

St Helier, Jersey JE2 4SZ

Company registered in Cayman Islands 

 Governors Square, Suite 5-204, 23 Lime Tree Bay Avenue, P.O. Box 477, 

Camana Bay, KY1-1108

Company registered in Australia  

 Watson Erskine and Co Pty Ltd, Level 4, 55 Clarence Street 

Sydney NSW 2000

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C O R P O R A T E   I N F O R M A T I O N

Notice of annual general meeting

NOTICE IS HEREBY GIVEN that the 131st annual general meeting of the Company will be held electronically in accordance with the 

information provided on page 142 on 7 April 2021 at 11.00am to transact the following business:

Ordinary resolutions

To consider and, if thought fit, to pass the following resolutions which will be proposed as ordinary resolutions:

1. 

 To receive the report of the Directors, the strategic report and the audited accounts and the auditor’s report for the year 

ended 31 December 2020.

2.  To receive and approve the Directors’ remuneration report for the year ended 31 December 2020.

3. 

To declare a final dividend of 8.00p per share in respect of the year ended 31 December 2020.

4. 

To re-elect Denis Jackson as a Director.

5.  To re-elect Robert Hingley as a Director.

6.  To re-elect Mark Bridgeman as a Director.

7. 

To re-elect Tim Bond as a Director.

8.  To re-elect Claire Finn as a Director.

9. 

To elect Trish Houston as a Director.

10. 

 To re-appoint BDO LLP as auditors of the Company to hold office until the conclusion of the next general meeting at which 

the accounts of the Company are laid.

11.  To authorise the Audit and Risk Committee to determine the auditor’s remuneration.

12.  General authority to allot shares.

THAT:

(a)   in substitution for all existing authorities (but without prejudice to any allotments made pursuant to the terms of such 

authorities), the Directors be generally and unconditionally authorised pursuant to and in accordance with section 551 of 

the Companies Act 2006 (the ‘Act’) to exercise for the period ending on the date of the Company’s next annual general 

meeting, all the powers of the Company to allot shares in the Company or to grant rights to subscribe for or to convert any 

security into shares in the Company up to an aggregate nominal amount (within the meaning of sections 551(3) and (6) of 

the Act) of £592,279 (representing 11,845,573 ordinary shares) (or, if less, the number representing 10% of the total ordinary 

shares in issue (excluding treasury shares) as at the date of passing of this resolution); and

(b)   the Company may during such period make offers or agreements which would or might require the making of allotments 

of equity securities or relevant securities as the case may be after the expiry of such period.

Special resolutions

To consider and, if thought fit, to pass the following resolutions which will be proposed as special resolutions:

13.  Disapplication of statutory pre-emption rights.

 THAT if resolution 12 is passed, the Directors be authorised to allot equity securities (as defined in the Act) for cash under the 

authority given by that resolution and/or to sell ordinary shares held by the Company as treasury shares for cash as if section 561 

of the Act did not apply to any such allotment or sale, such authority to be limited to:

(a)   the allotment of equity securities or sale of treasury shares in connection with a rights issue, open offer or other issue or 

offer to ordinary shareholders in proportion (as nearly as possible) to their existing holding of shares (but subject to such 

exclusions as the Directors may deem necessary or appropriate to deal with fractional entitlements, record dates or legal, 

regulatory or practical problems arising in any overseas territory, the requirements of any regulatory body or stock exchange 

or any other matter); and

(b)   the allotment of equity securities or sale of treasury shares (otherwise than under paragraph (a) above up to a nominal 

amount of £296,139 (representing 5,922,787 ordinary shares), 

132
132

lawdebenture.com

 
 
 
 
 
 
Notice of annual general meeting continued 

 such authority to expire at the next AGM of the Company (or, if earlier, at the close of business on 6 July 2022) but, in each case, 

prior to its expiry the Company may make offers, and enter into agreements, which would, or might, require equity securities 

to be allotted (and treasury shares to be sold) after the authority expires and the Directors may allot equity securities (and sell 

treasury shares) under any such offer or agreement as if the authority had not expired.

14.  Additional authority to disapply pre-emption rights for acquisitions or specified capital investment.

 THAT, if resolution 12 is passed, the Directors be authorised in addition to any authority granted under resolution 13 to allot 

equity securities (as defined in the Act) for cash under the authority given by that resolution and/or to sell ordinary shares 

held by the Company as treasury shares for cash as if section 561 of the Act did not apply to any such allotment or sale, such 

authority to be: 

(a) 

 l imited to the allotment of equity securities or sale of treasury shares up to a nominal amount of £296,139 (representing 

5,922,787 ordinary shares); and

(b)    used only for the purposes of financing (or refinancing, if the authority is to be used within six months of the original 

transaction) a transaction which the Directors of the Company determine to be an acquisition or other capital investment 

of a kind contemplated by the Statement of Principles on disapplying Pre-Emption Rights most recently published by the 
Pre-Emption Group prior to the date of this notice,

 such authority to expire at the next AGM of the Company (or, if earlier, at the at the close of business on 6 July 2022) but, in 

each case, prior to its expiry the Company may make offers, and enter into agreements, which would, or might, require equity 

securities to be allotted (and treasury shares to be sold) after the authority expires and the Directors may allot equity securities 

(and sell treasury shares) under any such offer or agreement as if the authority had not expired. 

15.  General authority to buy back shares.

 THAT the Company be and is generally and unconditionally authorised in accordance with sections 693 and 701 of the Act 

to make market purchases (within the meaning of section 693(4) of the Act) of any of its issued ordinary shares of 5p each in 

the capital of the Company, in such manner and upon such terms as the Directors of the Company may from time to time 

determine, provided always that:

(a)  the maximum aggregate number of shares that may be purchased is 17,756,514;

(b)  the minimum price which may be paid for a share shall be 5p;

(c) 

 the maximum price which may be paid for a share shall be an amount equal to 105% of the average of the middle 

market quotations (as derived from the London Stock Exchange Daily Official List) for the shares for the five business days 

immediately preceding the day on which the share is purchased; and

(d)   unless previously revoked, renewed or varied, the authority hereby conferred shall expire on the date of the Company’s 

next annual general meeting provided that a contract of purchase may be made before such expiry which will or may be 

executed wholly or partly thereafter, and a purchase of shares may be made in pursuance of any such contract.

16.  Adoption of new articles.

 THAT the Articles of Association contained in the document produced to the Meeting and signed by the Chairman for the 

purposes of identification, be approved and adopted as the new Articles of Association of the Company in substitution for, and 

to the exclusion of, the existing Articles of Association, with effect from the conclusion of the Meeting. 

17.  Authority to convene a general meeting – notice.

 THAT a general meeting of the Company, other than an annual general meeting, may be called on not less than 14 clear days’ 

notice.

By order of the Board

Law Debenture Corporate Services Limited 
Secretary  |  25 February 2021

Registered No. 30397 

Registered office:  

8th Floor 

100 Bishopsgate 

London EC2N 4AG

133133

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The Law Debenture Corporation p.l.c.

Summary of Proposed Amendments to the Articles of Association

25 February 2021

ARTICLE

AMENDMENT

2 – Interpretation

The definitions have been updated so that they are in alphabetical order.

A definition of “Adjusted Capital and Reserves” has been included. This is used in Article 100.3 

(Borrowing Powers). 

A definition of “adjusted price” has been included. This is used in Article 119.4 (Capitalisation of 

profits and reserves).

A definition of “Articles” has been included in order to clarify that all references to “Articles” means 

these Articles of Association as amended from time to time. This is used throughout the Articles.

A definition of “Auditors” has been included. This is used in Articles 46.2 (Notice of General Meetings), 

91.1 (Interests and conflicts of interest), 96 (General powers), 100.3 (Borrowing powers), 123 (Auditors) 

and 124 (Auditor’s right to attend General Meetings).

A definition of “Board” has been included. This is used throughout the Articles. 

A definition of “clear days” has been included. This is used in Articles 46 (Notice of General Meetings) 

and 50 (Lack of quorum).  

A definition of “Directors” has been included. This is used throughout the Articles. 

A definition of “elected Ordinary Shares” has been included. This is used in Article 120.6 (Scrip 

dividends). 

A definition of “General Meeting” has been included. This is used throughout the Articles. The 

amended Articles use terminology from the Companies Act 2006, and therefore all General 

Meetings are referred to as General Meetings, with Annual General Meetings being specifically 

referred to as such, where appropriate. The concept of Extraordinary General Meetings has 

been removed. 

A definition of “holding company” has been included. This is used in Article 96 (General powers). 

A definition of “Listing Rules” has been included. This is used in Article 12 (Issue of share certificates).

A definition of “Market Rules” has been included. This is used in Articles 15 (Warrants or options to 

subscribe for shares) and 39 (Further provisions on shares in uncertificated form). 

A definition of “minority proportion” has been included. This is used in Article 100.3 (Borrowing 

Powers).A definition of “Ordinary Resolution” has been included. This is used in Articles 6 (Rights 

attaching to shares on issue), 54 (Amendments to resolutions), 70 (Number of directors), 72 (Directors’ 

fees), 79 (Re-election of retiring Director), 81 (Election or appointment of additional Director), 83 

(Removal of Director), 92.4 (Restrictions on voting), 100.2 (Borrowing powers), 107 (Final dividends), 109 

(Distribution in specie), 119.1 (Capitalisation of profits and reserves) and 120.2 (Scrip dividends). 

A definition of “New Share” has been included. This is used in Article 119.4 (Capitalisation of profits 

and reserves).

A definition of “principal meeting place” has been included. This is used in Article 47A (General 

Meetings at more than one place). 

A definition of “Relevant Company” has been included. This is used in Article 134.3 (Indemnity).

The definition of “Seal” has been updated to clarify that the Corporation only has one seal. This is 

used in Articles 11 (Form of share certificate) and 103 (The Seal), 

The definition of “Securities Seal” has been removed as this is no longer used by the Corporation.  

A definition of “Special Resolution” has been included. This is used in Articles 5 (Purchase of own 

shares), 30.1 (Manner of variation of rights), 47.2 (Contents of notice of General Meetings), 54.2 

(Amendments to resolutions), 96 (General powers) and 132 (Distribution of assets in specie).

A definition of “subsidiary undertaking” has been included. This is used in Article 96 (General 

powers). 

The definition of “in writing” has also been amended to clarify that information may be sent or 

supplied in hard copy, in electronic form or by being made available on a website. This is used 

throughout the Articles.  

134134 lawdebenture.com

The Law Debenture Corporation p.l.c.

Summary of Proposed Amendments to the Articles of Association continued

25 February 2021

ARTICLE

AMENDMENT

2A – Unrestricted objects

A new Article 2A has been included to note that the Corporation’s objects shall be unrestricted. On 

its incorporation, the Corporation was required to include an objects clause in its Memorandum of 

Association. This set out the purpose of the Corporation and listed the activities that the Corporation 

was able to undertake.

Following the implementation of the Companies Act 2006, the Corporation’s objects automatically 

became part of its Articles of Association. As the objects clause only serves to limit the activities of 

the Corporation and no longer reflect the current activities of the Corporation, it is proposed that 

the Corporation’s objects shall be unrestricted. 

2B – Change of name 

As permitted by the Companies Act 2006, a new Article 2B has been included to allow the 

Corporation to change its name by a resolution of the Directors. 

4A – Redeemable shares

A new Article 4A has been included to authorise the Directors to issue redeemable shares. Any such 

issue is subject to the provisions of the Companies Act 2006 and the Companies (Shareholders’ 

Rights) Regulations 2009, and to any rights previously conferred on the holders of any other shares. 

7 – Directors’ power to allot

The language that referred to an allotment period ending in 2004 has been removed on the basis it 

is now redundant. 

12 – Issue of share certificates

Language has been included to note that a shareholder is entitled to a share certificate within 

whichever is the earliest of (1) any time period required by the Listing Rules of the FCA; and (2) any 

time limits prescribed by law. 

15 – Warrants or options to 
subscribe for shares

This Article has been simplified and notes that, subject to any restrictions prescribed by law, 

the Articles, the Admission and Disclosure Standards of the London Stock Exchange and the 

requirements of the FCA, the Corporation may issue warrants or options to subscribe for shares on 

such terms and subject to such conditions as the Directors may determine. 

32 – Form of transfer

The last sentence of Article 32.1 has been removed as it simply repeated the wording of Article 35.

Article 32.2 has been updated to clarify that all transfers of shares which are in uncertificated form 

may be effected in accordance with the Uncertificated Securities Regulations 2001 and the rules of 

any relevant system pursuant to such Regulations. 

34.1 – Right to refuse 
registration

This Article has been updated to clarify that an instrument of transfer must be lodged at the 

Corporation’s registered office.

39 – Further provisions on 
shares in uncertificated form

This Article has been updated to include reference to the FCA and the Admission and Disclosure 

Standards of the London Stock Exchange, and to further clarify the position on shares held in 

uncertificated form. 

In particular, this Article authorises the Directors to permit title to shares to be evidenced other than 
by a share certificate. This allows the holding and transfer of shares in electronic form, i.e. where 

shares are held and traded in CREST. 

This Article also notes that shares may be changed from an uncertificated share to a certificated 

share (and vice versa) in accordance with the Uncertificated Securities Regulations 2001, and 

clarifies that the Corporation shall not issue to any person a certificate in respect of an uncertificated 

share.   

44 – Annual General Meetings

As noted above and in accordance with the Companies Act 2006, reference to “Extraordinary 

General Meetings” has been removed. All General Meetings are referred to as General Meetings, with 

Annual General Meetings being referred to as such where appropriate.

46 – Notice of General 
Meetings 

Article 46.1 has been updated to provide that, subject to the provisions of the Companies Act 2006, 

an Annual General Meeting shall be called by not less than 21 clear days’ notice in writing and any 

other General Meeting shall be called by not less than 14 clear days’ notice in writing.

Article 46.2 has been updated to provide that notice of a General Meeting shall be given to the 

Auditors, to the Directors and to all members who are entitled under the Articles to receive such 

notices from the Corporation.

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The Law Debenture Corporation p.l.c.

Summary of Proposed Amendments to the Articles of Association continued

25 February 2021

ARTICLE

AMENDMENT

46 – Notice of General 
Meetings continued

47.2 – Contents of notice of 
General Meetings

47B – Omission or non-receipt 
of notice

Article 46.3 has been updated to provide that the Directors may determine that persons entitled 

to receive notice of meetings are those persons entered on the register of members at the close of 

business on a day determined by the Directors, but if the Corporation is a participating issuer, the 

day determined by the Directors may not be more than 21 clear days before the date on which the 

relevant notice is being sent.

As section 307A of the Companies Act 2006 sets the minimum notice periods for General Meetings 

of the Corporation, the consent to short notice provisions have been removed. 

This Article has been updated to note that a notice of General Meeting shall also include any 

statements required by law. 

A new Article 47B has been included to provide that the accidental omission to give notice of a 

General Meeting or of any resolution intended to be moved at a General Meeting or the accidental 

omission to send any document relating to any General Meeting to, or the non-receipt of any such 

notice or document by, any person entitled to receive the notice or document shall not invalidate 

the proceedings at that meeting.  

48 – Chairman

At Article 48.1, the time allowed for the Directors to choose a Director to act as chairman of a 

General Meeting in the event that the Chairman or Deputy Chairman is not present has been 

extended from five to fifteen minutes. This is simply for practical reasons. 

A new Article 48.2 has been included to clarify that the decision of the chairman on points of order, 

matters of procedure or arising incidentally out of the business of a General Meeting is conclusive.

A new Article 48.3 has been included to clarify that nothing in the Articles is intended to restrict or 

exclude any of the powers or rights of a chairman of a meeting which are given by law.

48C – Entitlement to attend 
and speak

Article 71 previously set out that a Director who is not a member of the Corporation is entitled to 

attend and speak at a shareholders’ meeting. This language has been updated and added as a new 

Article 48C.1.

A new Article 48C.2 has been included to note that the chairman of the meeting may permit other 

persons, who are not members or otherwise entitled to exercise the rights of members in relation to 

General Meetings, to attend and speak at a General Meeting.

49 – Quorum

The quorum required to conduct a General Meeting has been changed from three to two members 

present in person or by proxy and entitled to vote.

50 – Lack of quorum

The time allowed for a General Meeting to be dissolved in the event a quorum is not present has 

been increased from five to thirty minutes. This is simply for practical reasons.

54 – Amendments to 
resolutions

New Articles 54.1 and 54.2 have been included to clarify how ordinary and special resolutions to be 

proposed at a General Meeting may be amended. 

Article 54.3 has also been amended to note that, with the consent of the chairman, an amendment 

may be withdrawn by the proposer before it is voted on. 

66 – Deposit of form of proxy

This Article has been updated to clarify that, if a form of proxy does not specify where it is to be 

delivered, it must be delivered to the Corporation’s registered office.

68 – Revocation of proxy

This Article has been updated to clarify that written notice of the death or mental disorder of a member 

or revocation of the appointment of a proxy must be delivered to the Corporation’s registered office. 

The previous reference to “insanity” has been replaced with “mental disorder”. 

71 – Share qualification 

The reference to a Director who is not a member of the Corporation being entitled to attend and 

speak at shareholders’ meeting has been removed, as this is now covered at Article 48C. 

76 – Appointment of executive 
Directors

Article 76.2 relating to the cessation of an executive Director’s appointment to the Board upon the 

termination of their employment with the Corporation has been removed as it is redundant.

Article 76.3 relating to the cessation of an executive Director’s employment with the Corporation not 

being automatic upon the cessation of their appointment as an executive Director to the Board has 

been removed as it is redundant.

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The Law Debenture Corporation p.l.c.

Summary of Proposed Amendments to the Articles of Association continued

25 February 2021

ARTICLE

AMENDMENT

78 – Retirement and 
re-election of Directors

This Article has been updated to clarify that at each annual general meeting of the Corporation, the 

directors may resolve that all of the directors shall retire and may offer themselves for election or 

re-election as appropriate.

80 – Nomination of Director 
for election

A new Article 80.2 has been included to provide that the names of the persons submitted for 

election or re-election shall be accompanied by sufficient biographical details and other relevant 

information to enable shareholders to make an informed decision on the election or re-election of 

such persons.

81 – Election of two or more 
Directors

This Article has been removed as it is no longer relevant. 

82 – Vacation of office

The list of events in which the office of a Director shall be vacated has been updated as follows: 

• 

• 

• 

• 

 to include reference to the expiry of a fixed term of appointment;

 to include reference to section 253 of the Insolvency Act 1986;

 to allow the Directors to resolve that a Director’s office be vacated in the event that such Director 

becomes incapable by reason of illness or injury of administering his property and affairs; and

 to include reference to a Director not being re-elected in accordance with Article 78.

84 – Convening of meetings 
of Directors

All references to fax machines deleted.

96 – General Powers 

The historic reference to "wives and widows" has been updated as it is no longer appropriate. 

101 – President

The authority granted to Directors to elect a President either on an honorary or paid basis, with 

the right to attend and speak but not vote at Board meetings has been removed, as it is no longer 

relevant to the Corporation.

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Explanatory notes to the notice of annual general meeting

The notice of the Annual General Meeting (the ‘Notice’) to be held 

Risk Committee, recommends the re-appointment of BDO LLP as 

on 7 April 2021 (the ‘Meeting’) is set out on pages 132 and 133. The 

the Company’s auditors.

following notes provide an explanation as to why the resolutions 

set out in the notice are being put to shareholders.

Resolution 1
Under the Companies Act 2006 (the ‘Act’), the Directors are 

required to present the annual accounts and reports of the 

Company to shareholders at a general meeting. These are 

contained in the Company’s 2020 annual report and financial 

statements for the year ended 31 December 2020 (the ‘2020 

Annual Report’), which was sent to shareholders on 3 March 2021.

Resolution 2
In accordance with the provisions of the Act, the Company’s 

Resolution 11
This resolution, if passed, will authorise the Audit and Risk 

Committee to agree the remuneration of BDO LLP for their 

services as auditors.

Resolution 12
Under the Act, Directors may not allot shares in the Company 

(or grant certain rights over shares) without the authority of 

shareholders in general meeting (other than pursuant to an 

employee share scheme). In certain circumstances this could be 

unduly restrictive. The Directors’ existing authority to allot ordinary 

shares, which was granted at the annual general meeting of 

Report on Directors’ Remuneration will be put to an annual 

the Company held on 7 April 2020, will expire at the end of this 

shareholder vote by ordinary resolution. This vote is advisory in 

year’s AGM.

nature and is in respect of the overall remuneration package 

which is in place for Directors – it is not specific to individual 

levels of remuneration nor is the entitlement of a Director to 

remuneration conditional on the vote being passed. The report is 

set out in full on pages 67 to 82 of the 2020 Annual Report.

Resolution 3
The Board proposes a final dividend of 8.00 pence per share in 

The Investment Association’s Share Capital Management 

Guidelines and the Pre-Emption Group Principles permit, and 

regard as routine, an authority to allot up to two-thirds of a 

company’s existing issued share capital. Subject to the passing of 

this resolution, which will be proposed as an ordinary resolution, 

the Directors will be authorised, in place of all existing authorities, 

to allot shares (pursuant to section 551 of the Act)up to an 

respect of the year ended 31 December 2020. If approved, the 

aggregate nominal amount of £592,279 (representing 11,845,573 

recommended final dividend will be paid on 15 April 2021 to all 

ordinary shares), representing approximately ten per cent of the 

ordinary shareholders who are on the register of members on 

nominal value of the issued ordinary shares on 25 February 2021 

12 March 2021. The shares will be marked ex-dividend on 11 March 

(being the last practicable date prior to the publication of this 

2021.

document). As at 25 February 2021, the Company did not hold any 

Resolutions 4 – 9
Under the Company’s Articles of Association (the ‘Articles’), one 

shares in treasury.

The authority conferred will expire (unless previously revoked, 

third of the Directors must retire from office by rotation at each 

varied or renewed) at the end of the next annual general meeting. 

annual general meeting and may offer themselves for re-election 

However, the Company may make an offer or agreement prior to 

(this does not include Directors appointed to the Board since the 

the expiry of this authority which would or might require shares 

last annual general meeting). The 2018 UK Corporate Governance 

to be allotted after the expiry of this authority – in this case, the 

Code recommends that all directors of premium listed companies 

Directors will be permitted to allot securities pursuant to such 

should be subject to annual re-election, so Denis Jackson, Robert 

offer or agreement as if this authority had not expired.

Hingley, Mark Bridgeman, Tim Bond and Claire Finn will retire 

from office and offer themselves for re- election. Robert Laing will 

not seek re-election. The UK Corporate Governance Code and the 

Articles also require any new Directors appointed by the Board 

since the last annual general meeting to stand for election at the 

next annual general meeting. Accordingly, Trish Houston, having 

joined the Board in September 2020, also retires from office and 

offers herself for election.

Resolution 13
Unless they are given an appropriate authority by shareholders, if 

the Directors wish to allot any shares for cash or grant rights over 

shares (other than pursuant to an employee share scheme) they 

must first offer them to existing shareholders in proportion to 

their existing holdings. These are known as pre-emption rights. 

The existing disapplication of these statutory pre-emption rights, 

which was granted at the annual general meeting held on 7 April 

The biographical details for each Director are set out on pages 50 

2020, will expire at the end of this year’s annual general meeting.

and 51 of the 2020 Annual Report.

Resolution 13 seeks approval to disapply the pre-emption rights, 

In proposing the election/re-election of the Directors, the 

by allowing Directors to allot equity securities (including a sale 

Chairman confirms that, following rigorous external performance 

of treasury shares) for cash: (i) in connection with rights issues 

evaluations (described on pages 56 and 57 of the 2020 Annual 

and other preemptive issues in favour of existing shareholders in 

Report), each individual continues to make an effective 

proportion to their existing holdings (subject to certain exclusions); 

and valuable contribution to the Board and demonstrates 

(ii) by way of an open offer or other issue of securities in favour 

commitment to their role. Accordingly, the Board recommends 

of existing shareholders in proportion to their existing holdings 

their election or re-election as appropriate.

(subject to certain exclusions); and (iii) to persons other than 

Resolution 10
The Company’s auditors must offer themselves for reappointment 

at each annual general meeting at which accounts are presented. 

Accordingly, the Board, on the recommendation of the Audit and 

existing shareholders up to an aggregate nominal amount of 

£296,139 (representing 5,922,787 ordinary shares), being no more 

than five per cent of the issued ordinary share capital in issue on 

the 25 February 2021, in each case without the equity securities 

138 lawdebenture.com

Explanatory notes to the notice of annual general meeting

continued

first being offered to the existing shareholders in proportion to 

This authority shall expire at the Annual General Meeting to 

their existing holdings.  

be held in 2022 when a resolution to renew the authority will 

The Directors confirm that in accordance with the Pre-Emption 

Group’s Statement of Principles, they do not intend to issue 

shares for cash representing more than seven and a half per cent 

be proposed.

Resolution 16
The Board is proposing to make amendments to the Company’s 

of the Company’s issued ordinary share capital in any rolling 

current Articles of Association approved by shareholders on 11 

three-year period other than to existing shareholders, save as 

February 2021. A summary of the proposed changes is set out on 

permitted in connection with an acquisition or specified capital 

pages 134 to 137.

investment as described below, unless shareholders have been 

notified and consulted in advance. 

Resolution 14
Resolution 14 seeks an additional and separate approval to 

Resolution 17
The Act requires that all general meetings must be held on at least 

21 clear days’ notice. Notwithstanding the notice provisions in the 

Articles, a general meeting (other than an annual general meeting) 

disapply pre-emption rights by allowing Directors to allot equity 

may be held on at least 14 clear days’ notice where:

securities (or sell treasury shares) for cash, of up to a further 

five per cent of the total ordinary share capital, representing 

up to an aggregate nominal amount of £296,139 (representing 

5,922,787 ordinary shares), as at 25 February 2021, without such 

equity securities first being offered to the existing shareholders 

in proportion to their holdings, where the allotment is to 

finance an acquisition or capital investment, and/or refinance a 
transaction of that nature entered into within six months of the 

original transaction. 

The Directors confirm that they will only allot securities (or sell 

treasury shares for cash) pursuant to this authority where that 

allotment is in connection with an acquisition or specified capital 

investment (as described in the Pre-Emption Group’s Statement 

of Principles) which is announced at the same time as the 

allotment, or which has taken place in the preceding six-month 

period and is disclosed in the announcement of that allotment.

Further, the Directors confirm that they intend to adhere to 

the Pre-Emption Group’s Statement of Principles and not to 

allot shares for cash on a non-pre-emptive basis in excess 

of an amount equal to seven and a half per cent of the total 

issued share capital (excluding any treasury shares) within a 

rolling three-year period other than in connection with an 

acquisition or specified capital investment which is announced 

contemporaneously with the allotment or which has taken 

place in the preceding six-month period and is disclosed in the 

announcement of the allotment. 

Resolution 15
Resolution 15 is a special resolution that will grant the Company 

authority to make market purchases of up to 17,756,514 shares, 

representing 14.99% of the issued ordinary share capital as 

at the date of the Notice. Any shares bought back will either 

be cancelled or placed into treasury at the determination of 

the Directors.

The maximum price which may be paid for each share must 

not be more than 105% of the average of the mid-market values 

of the Ordinary Shares for the five business days before the 

purchase is made. The minimum price which may be paid for 

each ordinary share is 5p.

The Directors are committed to managing the Company’s capital 

effectively and do not intend to exercise such authority at present. 

Purchases would only be made after considering the effect on 

earnings per share and the benefits for shareholders generally.

• 

 the Company makes an electronic means of voting available 

to all shareholders for the meeting. This condition is met by 

the Company providing the facility for shareholders to appoint 

a proxy via an online shareholder portal operated by our 

Registrars; and

• 

 the shareholders pass a special resolution reducing the period 

of notice to not less than 14 days either at the immediately 

preceding annual general meeting or a general meeting held 

since that annual general meeting. 

It is not the Company’s intention to use the shorter notice period 

as a matter of routine but only when the flexibility is merited by 

the business of the meeting and is thought to be in the interests 

of shareholders as a whole. If given, this approval will be effective 

until the end of the next annual general meeting.

Recommendation
Full details of the above resolutions are contained in the Notice. 

The Directors consider that all the resolutions to be proposed 

at the Meeting are in the best interests of the Company and its 

members as a whole. The Directors unanimously recommend that 

shareholders vote in favour of all the resolutions, as they intend to 

do in respect of their own beneficial holdings.

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Shareholder notes

The following notes explain your general rights as a shareholder 

(d)   in the case of shares held through CREST, via the CREST 

and your right to attend and vote at the Meeting or to appoint 

system (see notes 8-11 on pages 140 and 141).

someone else to vote on your behalf.

4.  

 Any person to whom this Notice is sent who is a person 

1. 

 To be entitled to attend and vote at the meeting (and for the 

nominated under Section 146 of the Companies Act 2006 

purpose of the determination by the Company of the number 

(the 'Act') to enjoy information rights (a ‘Nominated Person’) 

of votes they may cast), shareholders must be registered in 

may, under an agreement between him/her and the 

the register of members of the Company at close of business 

shareholder by whom he/she was nominated, have a right to 

on Thursday, 1 April 2021 (or, in the event of any adjournment, 

be appointed (or to have someone else appointed) as a proxy 

close of business on the date which is 48 hours before the 

for the meeting. If a Nominated Person has no such proxy 

time of the adjourned meeting). Changes to the register of 

appointment right or does not wish to exercise it, he/she may, 

members after the relevant deadline shall be disregarded in 

under any such agreement, have a right to give instructions to 

determining the rights of any person to attend and vote at the 

the shareholder as to the exercise of voting rights.

meeting. In the case of joint holders of a share, the vote of the 

senior who tenders a vote, whether in person or by proxy, shall 

be accepted to the exclusion of the votes of the other joint 

holders and for this purpose seniority is determined by the 

order in which the names stand in the register of members in 

5.  

 The statement of the rights of shareholders in relation to 

the appointment of proxies in notes 2 and 8 do not apply to 

Nominated Persons. The rights described in these paragraphs 

can only be exercised by shareholders of the Company.

respect of the share.

6. 

 A vote withheld is not a vote in law, which means that the vote 

2. 

 Shareholders are entitled to appoint a proxy to exercise all or 

part of their rights to attend, and to speak and vote on their 
behalf at the meeting. A shareholder may appoint more than 

one proxy in relation to the meeting provided that each proxy 

is appointed to exercise the rights attached to a different 

will not be counted in the calculation of votes for or against 

the resolution. If no voting indication is given, your proxy will 

vote or abstain from voting at his/her discretion. Your proxy 
will vote (or abstain from voting) as he/she thinks fit in relation 

to any other matter which is put before the meeting.

ordinary share or ordinary shares held by that shareholder. A 

7. 

 If you return more than one proxy appointment (except where 

proxy need not be a shareholder of the Company. A form of 

multiple proxies have been appointed), either by paper or 

proxy, which accompanies this Notice, may be used to make 

electronic communication, that appointment received last by 

such appointment and give proxy instructions. If you do not 

the Registrar before the latest time for the receipt of proxies 

have a form of proxy and believe that you should have one, or 

will take precedence. You are advised to read the terms 

if you require additional forms, please contact the Company's 

and conditions of use carefully. Electronic communication 

registrar, whose contact details are provided above.

facilities are open to all shareholders and those who use them 

3.  

 Dispatch instructions: To be valid, any form of proxy and 

will not be disadvantaged.

any power of attorney or other authority under which it 

8. 

 The return of a completed form of proxy, electronic filing or 

is executed (or a duly certified copy of any such power or 

any CREST proxy instruction (as described in note 10 below) 

authority), must be returned by no later than 11:00 am on 

will not prevent a shareholder from attending the meeting 

Thursday, 1 April 2021 through any one of the following 

and voting in person if he/she wishes to do so. 

methods:

9. 

 CREST members who wish to appoint a proxy or proxies 

(a)   by post at Computershare Investor Services PLC, The 

through the CREST electronic proxy appointment service may 

Pavilions, Bridgwater Road, Bristol, BS99 6ZY, United 

do so for the meeting (and any adjournment of the meeting) 

Kingdom

 (Tel: 0370 707 1129 if dialling from the UK and  

+44 370 707 1129 if dialling from abroad); or

by using the procedures described in the CREST Manual 

(available from https://www.euroclear.com/site/public/

EUI). CREST personal members or other CREST sponsored 

members, and those CREST members who have appointed 

(b)   by hand or courier (during normal business hours only) to 

a service provider/(s), should refer to their CREST sponsor 

the Company’s UK registrar at: Computershare Investor 

or voting service provider/(s), who will be able to take the 

Services PLC, The Pavilions, Bridgwater Road, Bristol, BS13 

appropriate action on their behalf.

8AE, United Kingdom

10. 

 In order for a proxy appointment or instruction made by 

 (Tel: 0370 707 1129 if dialling from the UK and  

means of CREST to be valid, the appropriate CREST message 

+44 370 707 1129 if dialling from abroad); or

(a ‘CREST Proxy Instruction’) must be properly authenticated 

(c)   electronically through the website of the Company’s 

UK registrar at www.investorcentre.co.uk/eproxy, where 

the following details, which can be found on your proxy 

card or in an email received from Computershare, will 

be required:

•  the meeting control number;

•  your shareholder reference number; and

•  your unique pin code; or

in accordance with Euroclear UK & Ireland Limited’s 

specifications and must contain the information required 

for such instructions, as described in the CREST Manual. The 

message must be transmitted so as to be received by the 

issuer’s agent by 11:00 am on Thursday, 1 April 2021. For this 

purpose, the time of receipt will be taken to mean the time 

(as determined by the timestamp applied to the message by 

the CREST application host) from which the issuer’s agent 

is able to retrieve the message by enquiry to CREST in the 

manner prescribed by CREST. After this time, any change of 

140140 lawdebenture.com

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Shareholder notes continued

instructions to proxies appointed through CREST should be 

15. 

 Any shareholder attending the meeting has the right to ask 

communicated to the appointee through other means.

questions. The Company must answer any such question 

11. 

 CREST members and, where applicable, their CREST sponsors, 

or voting service providers should note that Euroclear UK & 

Ireland Limited does not make available special procedures 

in CREST for any particular message. Normal system timings 

and limitations will, therefore, apply in relation to the input 

of CREST Proxy Instructions. It is the responsibility of the 

CREST member concerned to take (or, if the CREST member 

is a CREST personal member, or sponsored member, or has 

relating to the business being dealt with at the meeting, but 

no such answer need be given if: (a) to do so would interfere 

unduly with the preparation for the meeting or involve the 

disclosure of confidential information; (b) the answer has 

already been given on a website in the form of an answer 

to a question; or (c) it is undesirable in the interests of the 

Company or the good order of the meeting that the question 

be answered.

appointed a voting service provider, to procure that his CREST 

 Registered shareholders may submit their questions to the 

sponsor or voting service provider takes such action as shall 

Directors in advance of the meeting by sending an email to 

be necessary to ensure that a message is transmitted by 

the Company Secretary at TSU.cosec@lawdeb.com and the 

means of the CREST system by any particular time. In this 

Company will answer these in due course.

connection, CREST members and, where applicable, their 

CREST sponsors or voting system providers are referred, in 

particular, to those sections of the CREST Manual concerning 

practical limitations of the CREST system and timings. The 

Company may treat a CREST Proxy Instruction as invalid 

16. 

 The following documents are, subject to any security 

arrangements or restrictions in place as a result of the current 

Covid-19 pandemic, available for inspection from Monday, 

15 March 2021 until the time of the meeting:

in the circumstances set out in Regulation 35(5)(a) of the 

(a)   copies of the Directors’ letters of appointment or service 

Uncertificated Securities Regulations 2001.

contracts; 

12. 

 Any corporation which is a member can appoint one or more 

(b)  a copy of the proposed new Articles of Association of the 

corporate representative/(s) who may exercise, on its behalf, 

Company; and

all its powers as a member provided that no more than one 

corporate representative exercises powers in relation to the 

same shares.

13. 

 As at 25 February 2021 (being the latest practicable business 

day prior to the publication of this Notice), the Company had 

an issued share capital of 118,455,732 ordinary shares, carrying 

one vote each and no restrictions and no special rights with 

regard to the control of the Company. There are no other 

classes of share capital and none of the Company’s issued 

shares are held in treasury. Therefore, the total voting rights in 

the Company is 118,455,732.

14. 

 Under Section 527 of the Act, shareholders meeting the 

threshold requirements set out in that Section have the right 

to require the Company to publish, on a website, a statement 

(c)   a copy of the existing Articles of Association of the 

Company.

 Inspection of these documents may only take place in 

accordance with measures imposed by the UK Government 

in connection with the Covid-19 pandemic. The Company has 

its own procedures in place to comply with those measures. 

Accordingly, if you wish to inspect any of these documents, 

you should email TSU.cosec@lawdeb.com to arrange an 

appointment.

17. 

 You may not use any electronic address provided in either this 

Notice or any related documents (including the form of proxy) 

to communicate with the Company for any purposes other 

than those expressly stated.

setting out any matter relating to: 

18. 

 Personal data provided by shareholders at or in relation to the 

(i)   the audit of the Company’s financial statements (including 

the auditor’s report and the conduct of the audit), which 

are to be laid before the meeting; or

meeting will be processed in line with the Company’s privacy 

policy. Detailed information on how the Company processes 

your personal data and what your rights are under applicable 

data privacy laws can be accessed on the Company’s website 

(ii)   any circumstances connected with an auditor of the 

at https://www.lawdebenture.com/privacy-and-cookie-policy.

A copy of this Notice and other information required by section 

311A of the Act, can be found on the Company’s website at 

https://www.lawdebenture.com/investment-trust/shareholder-

information/corporate-governance/agm.

Company ceasing to hold office since the previous 

meeting at which annual accounts and reports were laid 

in accordance with Section 437 of the Act. The Company 

may not require the shareholders requesting any such 

website publication to pay its expenses in complying with 

Sections 527 or 528 of the Act. Where the Company is 

required to place a statement on a website under Section 

527 of the Act, it must forward the statement to the 

Company’s auditor not later than the time when it makes 

the statement available on the website. Business which 

may be dealt with at the meeting for the relevant financial 

year includes any statement that the Company has been 

required to publish on a website under Section 527 of 

the Act.

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Annual general meeting online user guide

HOW TO JOIN

Annual general meeting virtual meeting

required to enter the 

110-084-910.

meeting, you will be 

unique 9-digit Meeting ID:  

1 To participate in the 
2 To register as a 

shareholder, please 

enter your SRN and 

voting form.

PIN, which may be found on your 

WELCOME PAGE 
Once logged in, you 

will see the welcome 

3 

page, which displays the meeting 

documents (if any) and information 

on the meeting. Icons will be 
displayed in different areas, 

depending on the device you 

are using.

VIEW  
LIVESTREAM 
•  Click on the ‘Broadcast’ 

4 

arrow to watch the livestream. 
•  Video and/or slides will 
appear after approx. 30 seconds 

(depending on the speed of 

your internet).

TO ASK QUESTIONS 
• Click on the questions 
icon to submit a question.  

5 

•  Type your question in the 
chat box at the bottom of 

Meeting ID: 110-084-910

Meeting Access

Shareholders can participate in the AGM electronically, should they wish to do so. This can 
be done by accessing the meeting website: https://web.lumiagm.com

This can be accessed online using most well-known internet browsers such as Internet 

Explorer (not compatible with versions 10 and below), Chrome, Firefox and Safari on a PC, 

laptop or internet-enabled device such as a tablet or smartphone.

On accessing the meeting website, you will be asked to enter a Meeting ID which is:  

110-084-910

You will then be prompted to enter your unique shareholder reference number (SRN) and 

PIN. These can be found printed on your voting form.

Access to the meeting will be available from 10:00 am on 7 April 2021; however, please note 

that your ability to vote will not be enabled until the Chairman formally declares the poll open.

Broadcast

The meeting will be broadcast in audio format. Once logged in, and at the commencement 

of the meeting, you will be able to listen to the proceeding of the meeting on your device.

Voting

Once the Chair has formally opened the meeting, the voting procedure will be explained. 

Once voting has opened, the polling icon will appear on the navigation bar. From here, the 

resolutions and voting choices will be displayed.

Select the option that corresponds with how you wish to vote. Once you have selected your 

choice, the option will change colour and a confirmation message will appear to indicate 

your vote has been cast and received. There is no submit button. If you make a mistake or 

wish to change your vote, simply select the correct choice. If you wish to “cancel” your vote, 

select the “cancel” button. You will be able to do this at any time whilst the poll remains 

open and before the Chair announces its closure.

the screen and click the 

‘Send’ arrow to the right.  
•  A confirmation that your 
message has been received will 

be displayed.

Questions

Shareholders attending electronically may ask questions by typing and submitting their 

question in writing. Select the messaging icon from within the navigation bar and type 
your question at the bottom of the screen. To submit your question, click on the arrow icon 

TO VOTE 
•  Once the poll has 
been opened, you will 

6 

automatically see it on the screen.  
•  To vote, tap one of the voting 
options. Your response will 

be highlighted. 
•  If there is more than one answer 
option, press ‘Send’ to cast 

your vote. 
•  You can change your vote until 
the Chairman closes the poll. 

to the right of the text box.

Requirements

An active internet connection is required at all times in order to allow you to cast your 

vote when the poll opens, submit questions and listen to the audiocast. It is the user’s 

responsibility to ensure you remain connected for the duration of the meeting.

Duly appointed proxies and corporate representatives

Following receipt of a valid appointment, please contact the Company’s registrar before 

11.00 am on Thursday, 1 April 2021 on 0370 707 1129 or +44 370 707 1129 if you are calling 

Simply select another option or 

from outside the UK for your SRN and PIN. Lines are open 8:30am to 5:30pm Monday to 

click ‘Cancel’.

Friday (excluding public holidays in England & Wales).

142 lawdebenture.com

The Law Debenture Corporation p.l.c.  8th Floor, 100 Bishopsgate, London, EC2N 4AG

Tel: 020 7606 5451 | www.lawdebenture.com