TIDM63AS

RNS Number : 4287C

HSBC Bank plc

22 February 2022

22 February 2022

HSBC Bank plc 2021 Annual Report and Accounts

In fulfilment of its obligations under sections 4.1.3 and 6.3.5(1) of the Disclosure Guidance and Transparency Rules, HSBC Bank plc (the "Company") hereby releases the unedited full text of its 2020 Annual Report and Accounts for the year ended 31 December 2021.

The document is now available on the Company's website:

http://www.hsbc.com/investor-relations/subsidiary-company-reporting

The document has also been submitted to the National Storage Mechanism (NSM) and will shortly be available for inspection at: https://data.fca.org.uk/#/nsm/nationalstoragemechanism

HSBC Bank plc

Annual Report and Accounts 2021

Registered number - 00014259

 
Contents 
                                                                 Page 
Strategic Report 
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Highlights                                                          2 
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Key themes of 2021                                                  3 
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Key financial metrics                                               3 
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About HSBC Group                                                    4 
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Purpose and strategy                                                4 
Our Global Businesses                                               6 
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How we do business                                                  7 
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Key Performance Indicators                                         11 
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Economic background and outlook                                    13 
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Financial summary                                                  14 
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Risk overview                                                      20 
                                                             -------- 
Report of the Directors 
-----------------------------------------------------------  -------- 
Risk                                                               22 
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- Our approach to risk                                             22 
- Top and emerging risks                                           24 
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- Areas of special interest                                        30 
- Our material banking and insurance 
 risks                                                             32 
Corporate Governance Report                                        92 
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- Directors                                                        92 
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- Company Secretary                                                94 
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- Board of Directors                                               94 
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- Directors' emoluments                                            95 
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- Board committees                                                 95 
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- Dividends                                                        97 
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- Internal control                                                 93 
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- Employees                                                        99 
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- Auditors                                                        100 
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  *    Articles of association, conflicts of interest and 
       indemnification of directors                               101 
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- Statement on going concern                                      102 
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  *    Statement of directors' responsibilities in respect 
       of the financial statements                                103 
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Independent Auditors' Report                                      104 
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Financial Statements 
-----------------------------------------------------------  -------- 
Financial statements                                              107 
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Notes on the financial statements                                 118 
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Presentation of Information 
 

This document comprises the Annual Report and Accounts 2021 for HSBC Bank plc ('the bank' or 'the company') and its subsidiaries (together 'the group'). 'We', 'us' and 'our' refer to HSBC Bank plc together with its subsidiaries. It contains the Strategic Report, the Report of the Directors, the Statement of Directors' Responsibilities and Financial Statements, together with the Independent Auditors' Report, as required by the UK Companies Act 2006. References to 'HSBC', 'HSBC Group' or 'Group' within this document mean HSBC Holdings plc together with its subsidiaries.

HSBC Bank plc is exempt from publishing information required by The Capital Requirements Country-by-Country Reporting Regulations 2013, as this information is published by its parent, HSBC Holdings plc. This information is available on HSBC's website: www.hsbc.com.

Pillar 3 disclosures for the group are also available on www.hsbc.com, under Investors.

All narrative disclosures, tables and graphs within the Strategic Report and Report of the Directors are unaudited unless otherwise stated.

Our reporting currency is GBP sterling.

Unless otherwise specified, all $ symbols represent US dollars.

 
Cautionary Statement Regarding Forward- 
 Looking Statements 
 

This Annual Report and Accounts 2021 contains certain forward-looking statements with respect to the financial condition, results of operations and business of the group.

Statements that are not historical facts, including statements about the group's beliefs and expectations, are forward-looking statements. Words such as 'expects', 'anticipates', 'intends', 'plans', 'believes', 'seeks', 'estimates', 'potential' and 'reasonably possible', variations of these words and similar expressions are intended to identify forward-looking statements. These statements are based on current plans, estimates and projections, and therefore undue reliance should not be placed on them. Forward-looking statements speak only as of the date they are made. HSBC Bank plc makes no commitment to revise or update any forward-looking statements to reflect events or circumstances occurring or existing after the date of any forward-looking statement.

Forward-looking statements involve inherent risks and uncertainties. Readers are cautioned that a number of factors could cause actual results to differ, in some instances materially, from those anticipated or implied in any forward-looking statement.

 
Highlights 
 

For the year ended 31 December 2021

 
Reported profit/(loss) before tax 
 (GBPm) 
 

GBP1,023m

(2020: GBP(1,614)m)

 
Reported revenue (GBPm) 
 

GBP6,120m

(2020: GBP5,900m)

 
Reported risk-weighted assets at 
 period end (GBPbn) 
 

GBP104bn

(2020: GBP122bn)

.

 
Adjusted profit/(loss) before tax 
 (GBPm) 
 

GBP1,577m

(2020: GBP(184)m)

 
Total assets at period end (GBPbn) 
 

GBP597bn

(2020: GBP681bn)

 
Common equity tier 1 ratio at period 
 end (%) 
 

17.3%

(2020: 14.7%)

 
Key themes of 2021 
 

HSBC Bank plc continued to support the Group through progress on our strategic aims, although challenges in the geopolitical and economic environment remain.

 
Financial Performance 
 

Performance reflected an improvement in global economic conditions and the impact of lower interest rates. Revenue increased, there were releases of expected credit loss allowances, and operating expenses were lower reflecting the impact of our transformation programme. All of our global businesses generated higher profits compared with 2020. The outlook for net interest income is now more positive, although risks remain as inflation is anticipated to increase across Europe. Read more on pages 13 to 18.

 
Strategic Transformation 
 

We have continued to progress in our areas of strength and develop our digital capabilities. During the year we announced the planned sale of our retail banking business in France. We have formulated our response to the requirement for an Intermediate Parent Undertaking ('IPU') in line with European Union ('EU') Capital Requirements Directive, as a result of which our subsidiary HSBC Continental Europe plans to acquire HSBC Trinkaus & Burkhardt AG ('HSBC Germany'), HSBC Malta and HSBC Private Bank Luxembourg. More information can be found on pages 4 and 5.

 
Climate Ambition 
 

As demonstrated at COP26, the Group is playing a leading role in helping to mobilise the transition to a global net zero economy. Since 2020, HSBC Bank plc has supported our customers' transition to net zero and a sustainable future by providing them with $65.2bn of financing and investment; this contributes towards the Group's ambition to provide and facilitate $750bn to $1tn of sustainable financing and investment by 2030. In May 2021, a climate change resolution proposed by the Group's Board was backed by more than 99% of the Group's shareholders at its Annual General Meeting, including a commitment to publish a policy to phase out the financing of coal-fired power and thermal coal mining, by 2030 in the European Union ('EU') / Organisation for Economic Cooperation and Development ('OECD'), and 2040 in all other markets. We are also working with peers and industry bodies to take action on climate change, biodiversity and nature.

 
Key financial metrics 
 
 
                                                                                   2021                        2020 
----------------------------------------------------------------  ---------------------  -------------------------- 
For the year (GBPm) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Profit/(loss) before tax (reported basis)                                         1,023                     (1,614) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Profit/(loss) before tax (adjusted basis)(1)                                      1,577                       (184) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Net operating income before change in expected credit 
 losses and other credit impairment charges (reported basis)(2)                   6,120                       5,900 
----------------------------------------------------------------  ---------------------  -------------------------- 
Profit/(loss) attributable to the parent company                                  1,041                     (1,488) 
----------------------------------------------------------------  ---------------------  -------------------------- 
At year-end (GBPm) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Total equity attributable to shareholders of the parent 
 company                                                                         23,584                      23,666 
----------------------------------------------------------------  ---------------------  -------------------------- 
Total assets                                                                    596,611                     681,150 
----------------------------------------------------------------  ---------------------  -------------------------- 
Risk-weighted assets(3)                                                         104,314                     122,392 
----------------------------------------------------------------  ---------------------  -------------------------- 
Loans and advances to customers (net of impairment allowances)                   91,177                     101,491 
----------------------------------------------------------------  ---------------------  -------------------------- 
Customer accounts                                                               205,241                     195,184 
----------------------------------------------------------------  ---------------------  -------------------------- 
Capital ratios (%)(3) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Common equity tier 1                                                               17.3                        14.7 
----------------------------------------------------------------  ---------------------  -------------------------- 
Tier 1                                                                             21.0                        18.1 
----------------------------------------------------------------  ---------------------  -------------------------- 
Total capital                                                                      31.7                        27.3 
----------------------------------------------------------------  ---------------------  -------------------------- 
Performance, efficiency and other ratios (annualised %) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Return on average ordinary shareholders' equity(4)                                  4.3                       (7.9) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Return on tangible equity (%)(5)                                                    6.1                       (2.7) 
----------------------------------------------------------------  ---------------------  -------------------------- 
Cost efficiency ratio (reported basis)(6)                                          89.2                       113.6 
----------------------------------------------------------------  ---------------------  -------------------------- 
Cost efficiency ratio (adjusted basis)(6)                                          80.9                        89.6 
----------------------------------------------------------------  --------------------- 
Ratio of customer advances to customer accounts                                    44.4                        52.0 
----------------------------------------------------------------  ---------------------  -------------------------- 
 

1 Adjusted performance is computed by adjusting reported results for the effect of significant items as detailed on pages 15 to 16.

2 Net operating income before change in expected credit losses and other credit impairment charges is also referred to as revenue.

3 Unless otherwise stated, regulatory capital ratios and requirements are based on the transitional arrangements of the Capital Requirements Regulation in force at the time. These include the regulatory transitional arrangements for IFRS 9 'Financial Instruments', which are explained further on page 73. References to EU regulations and directives (including technical standards) should, as applicable, be read as references to the UK's version of such regulation and/or directive, as onshored into UK law under the European Union (Withdrawal) Act 2018, and as may be subsequently amended under UK law.

4 The return on average ordinary shareholders' equity is defined as profit attributable to shareholders of the parent company divided by the average total shareholders' equity.

5 The RoTE is calculated by adjusting reported profit attributable to ordinary shareholders by excluding movements in PVIF and significant items (net of tax), divided by average tangible shareholders' equity excluding fair value of own debt, debt valuation adjustment ('DVA') and other adjustments for the period. The calculation of this measure includes the UK bank levy incurred for the first time in 2021, which was previously paid by Group. Comparative data have not been re-presented.

6 Reported cost efficiency ratio is defined as total operating expenses (reported) divided by net operating income before change in expected credit losses and other credit impairment charges (reported), while adjusted cost efficiency ratio is defined as total operating expenses (adjusted) divided by net operating income before change in expected credit losses and other credit impairment charges (adjusted).

 
About HSBC Group 
 

With assets of $3.0tn and operations in 64 countries and territories at 31 December 2021, HSBC is one of the largest banking and financial services organisations in the world. Approximately 40 million customers bank with the Group and the Group employs around 220,000 full-time equivalent staff. The Group has around 187,000 shareholders in 128 countries and territories.

 
Purpose and strategy 
 
 
HSBC's purpose and ambition 
 

The Group's purpose is 'Opening up a world of opportunity' and the Group's ambition is to be the preferred international finance partner for the Group's clients.

HSBC values

HSBC values help define who we are as an organisation and are key to our long-term success.

We value difference

Seeking out different perspectives.

We succeed together

Collaborating across boundaries.

We take responsibility

Holding ourselves accountable and taking the long view.

We get it done

Moving at pace and making things happen.

HSBC Group strategy

The Group is implementing its strategy at pace across the four strategic pillars aligned to its purpose, values and ambition announced in February 2021.

The Group's strategy centres on four key areas: focus on our areas of strength, digitise at scale to adapt our operating model for the future; energise our organisation for growth and lead the transition to net zero.

Focus on our strengths : in each of our global businesses, the Group will focus on areas where we are strongest and have significant opportunities for growth.

Digitise at scale: the Group will focus investments in areas such as technology, to improve our customers' experience while ensuring security and resilience. These investments in technology will also help drive down costs, including through automating our middle and back offices and building solutions to free up office footprint.

Energise for growth : the Group is moving to a leaner and simpler organisation that is energised and fit for the future. The Group aim to inspire a dynamic culture and champion inclusion across the organisation, as well as help employees develop future skills.

Transition to net zero: the Group ambition is to support the transition to a net zero global economy. The Group have set out an ambitious plan to become a net zero bank, to support customers in their transition, and to unlock new climate solutions.

HSBC in Europe

Europe is an important part of the global economy, accounting for nearly 40% of global trade and one quarter of global Gross Domestic Product. In addition, Europe is the world's top exporter of services and second largest exporter of manufactured goods (UNCTAD, 2020). HSBC Bank plc facilitates trade within Europe and between Europe and other jurisdictions where the HSBC Group has a presence.

With assets of GBP597bn at 31 December 2021, HSBC Bank plc is one of Europe's largest banking and financial services organisations. We employ around 15,000 people across our locations. HSBC Bank plc is responsible for HSBC's European business, apart from UK retail and most UK commercial banking activity which, post ring-fencing, are managed by HSBC UK Bank plc.

HSBC Bank plc's ambition is to simplify its operating model; with a wholesale banking hub for the European Union ('EU') in Paris and a wholesale banking hub for western markets in London.

HSBC Bank plc operates in 20 markets(1) through the three principal operating units detailed below.

The London hub consists of the UK non-ring fenced bank, which provides overall governance and management for the Europe region as a whole and is a global centre of excellence for wholesale banking for the Group.

HSBC Continental Europe, comprises our Paris hub and its EU branches (Belgium, Czech Republic, Greece, Ireland, Italy, Luxembourg, Netherlands, Poland, Spain and Sweden) and Switzerland. We are creating an integrated Continental European bank anchored on Paris to better serve our clients and simplify our organisation.

HSBC Germany Holdings GmbH serves the European Union's largest economy and one of the leading export nations globally. HSBC Germany's business proposition mirrors the importance of trade and global connectivity.

1 Full list of markets where HSBC Bank plc has a presence: Armenia, Belgium, Channel Islands and Isle of Man, Czech Republic, France, Germany, Greece, Ireland, Italy, Israel, Luxembourg, Malta, Netherlands, Poland, Russia, South Africa, Spain, Sweden, Switzerland and the UK.

 
HSBC Bank plc's strategy and progress 
 on our 2021 commitments 
 

We have a clear vision to be the leading international wholesale bank in Europe, complemented by a targeted wealth and personal banking business (see our global businesses on page 6).

HSBC Bank plc exists to open up a world of opportunity for our customers by connecting them to international markets. Europe is the largest trading region in the world and Asia is Europe's biggest and fastest growing external trading partner (UNCTAD, 2020).

Below we provide a progress update on our commitments and strategic initiatives for 2021, in line with the Group's strategy.

Focus on our strengths

Through our transformation programme we are building a leaner, simpler bank with a sharper strategic focus. We have an ambition to grow, leveraging our industry leading positions in transaction banking, trade, capital markets and financing. We intend to be a market leader in sustainable financing and help the Group meet its ambition for net zero in its operations and supply chain by 2030.

New regulation in the EU provides an opportunity to simplify our structure. In response to the requirement for an IPU in line with the EU Capital Requirements Directive for European Union banking entities, our subsidiary HSBC Continental Europe plans to acquire HSBC Trinkaus & Burkhardt AG ('HSBC Germany'), HSBC Malta, and HSBC Private Bank Luxembourg. HSBC Germany would then be transferred into a newly created branch of HBCE in Germany. This legal entity restructuring remains subject to regulatory approvals.

Following the announcement in June 2021 regarding the planned sale of our French retail operations, a binding Framework Agreement was signed between HSBC Continental Europe and Promontoria MMB SAS ('My Money Group'), its subsidiary Banque des Caraïbes SA (the 'Purchaser') and My Money Bank ('MMB') on 25 November 2021. This step marks the start of an implementation process expected to complete in the second half of 2023, subject to obtaining the authorization of the competent financial, government and regulatory bodies. Until such point, the business remains part of, and will be managed by HSBC Continental Europe. See Note 34 on page 174 for further financial information on the transaction.

We intend to establish a Paris branch of HSBC Private Luxembourg, from which French clients will be served. The project is due to be completed during 2022 following the conclusion of the associated social process last year. This will enable us to provide an enhanced product range to clients leveraging our high quality infrastructure in Luxembourg.

Digitise at scale

We continue to focus our investments in areas that help optimise our technology capabilities and operations, as well as enhance client experience. Our main areas of focus are Transaction Banking, comprising Global Liquidity and Cash Management ('GLCM'), Global Trade and Receivable Finance ('GTRF') and Foreign Exchange ('FX'), which are central to our strategy.

Global Liquidity and Cash Management is focused on enhancing our digital and self-serve capabilities for our clients and improving our customer experience. In 2021, we continued to advance our proposition, an example of this involved developing our Liquidity Management Dashboard to facilitate customer cash flow forecasts. Looking ahead, we will continue to develop our offering, to improve our customer experience.

Our ambition for Global Trade and Receivables Finance is to make trade safer, faster and easier. In 2021, we improved key aspects of our proposition by taking steps to: simplify and digitise the client experience, upgrade our infrastructure and connect customers to technology partners. We aim to continue to invest in the future of trade by further developing our capabilities across key areas such as real-time credit decisioning, structured trade and sustainable trade finance.

In Foreign Exchange we further enhanced our electronic trading infrastructure to provide improved risk management to our clients. Our focus is to support customers' FX and cross-border payment needs through improved pricing tools and e-trading.

Our Wealth and Private Banking business in the Channel Islands and Isle of Man has focussed on digitising documentation, with the business saving over 600,000 pieces of paper through customers migrating to e-statements and telephone PINs being distributed vis SMS messaging.

During the same period, our technology investments have helped reduce operating costs across the bank.

Energise for growth

In February 2021, we committed to continuing to energise our people, which fundamentally contributes to a more effective, agile and empowered organisation. The main areas of focus are to inspire a dynamic culture, champion inclusion and develop future skills.

Since then, we have been engaging colleagues through numerous initiatives to apply our purpose and values to the delivery of our strategy, how we work and how we serve our customers.

Recruiting the right talent and diversifying our workforce remains important to us as is ensuring we create an environment for our colleagues to learn and grow. We are committed to increasing diverse representation in Europe, especially at senior levels. Our new pan-European Employee Resource Group 'Inclusive Europe' and the Diversity & Inclusion Council has sponsorship from our leaders and will support our actions.

We continue to energise our colleagues through initiatives that help develop their future skills and learning opportunities. During the year we promoted and engaged our employees with an expanded Future Skills curriculum that now incorporates the key strategic skills of Personal, Digital, Data and Sustainability.

Transition to net zero

Becoming a Net Zero Bank

In 2020, the HSBC Group set out ambitions to achieve net zero in the Group's operations and supply chain by 2030 or sooner and to align the Group's financed emissions to the Paris Agreement goal to achieve net zero by 2050 or sooner. To help achieve HSBC's ambitions, the Group passed a climate change resolution in the 2021 Annual General Meeting. The resolution included a commitment to set out the next steps in the Group's transition to net zero, including setting sector-based targets, publishing a thermal coal phase-out policy and reporting annually on progress. The resolution was backed by more than 99% of the Group's shareholders.

In 2021, the HSBC Group was one of 43 founding members of the Net Zero Banking Alliance ('NZBA'), which seeks to reinforce, accelerate, and support the implementation of decarbonisation strategies for the banking sector. The Group also launched a new climate leadership training programme for its top 250 leadership team, in which HSBC Bank plc non-executive directors and executives are included.

In 2021, travel restrictions and lower energy usage due to the Covid-19 outbreak favourably impacted HSBC Bank plc's greenhouse gas emissions figures. More detail can be found in our Environmental Social and Governance ('ESG') metrics disclosure on page 8.

Supporting our Customers

The Group's climate ambition is to support customers in their transition to net zero and a sustainable future. As part of this, the Group aims to provide and facilitate between $750bn and $1tn of sustainable finance and investment by 2030. To date, HSBC Bank plc has contributed $65.2bn to this ambition led by strong performance from debt capital markets, representing 51% of the Group's cumulative contribution towards sustainable finance and investments.

The breakdown of the Group's sustainable finance and investment progress is included in its ESG Data pack. The detailed definitions of the contributing activities for sustainable finance are available in the Group's revised Sustainable Finance Data Dictionary 2021. For the Group's ESG Data Pack, Sustainable Finance Data Dictionary and PwC Assurance Report, see www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre .

Case study: Debt Management Office

In September 2021, HSBC Bank plc acted as Joint Structuring Adviser and Joint Lead Manager on the United Kingdom Debt Management Office's GBP10bn 12-year inaugural Green gilt transaction with the proceeds to be used on projects to help the UK finance its Green Industrial Revolution. As Joint Structuring Adviser, we supported with establishing the UK Government's Green Financing Framework published in June 2021.

Unlocking New Climate Solutions

HSBC Group partnered with the World Resources Institute and World Wildlife Fund ("WWF") to launch the $100m Climate Solutions Partnership with the aim to accelerate support for innovative solutions tackling climate change. The programme will run for five years, as a part of this, there are two projects located in France in partnership with the French National Forestry Office and the Earthworm Foundation. Both of these local nature-based projects will contribute to net zero goals by better enabling CO2 capture, preserving biodiversity and engaging the community. HSBC also launched a Business Plan for the Planet campaign to help business transition to a sustainable model. In France, Germany and Malta we issued leadership content around carbon neutrality, ESG and Agrofood. These topics were illustrated with client case studies, content articles, videos and infographics published on our websites, media partnerships and social media. We also engaged on live sessions webinars series with HSBC experts, clients and partners to help small and medium companies transition.

 
Our Global Businesses 
 

The Group manages its products and services through its three global businesses: Global Banking and Markets ('GBM'); Commercial Banking ('CMB'); Wealth and Personal Banking ('WPB'); and the Corporate Centre (comprising, certain legacy assets, central stewardship costs, and interests in our associates and joint ventures).

 
Business segments 
 

Our operating model has the following material segments: WPB; CMB; a GBM business which is further split into 3 reportable segments MSS, GB and GBM Other reflecting the reorganisation of the GBM management structure during the year and a Corporate Centre. These segments are supported by Digital Business Services and 11 global functions, including Risk, Finance, Compliance, Legal, Marketing and Human Resources.

 
Markets & Securities    Global Banking          GBM Other               Commercial Banking      Wealth and Personal 
 Services ('MSS')        ('GB')                                          ('CMB')                 Banking ('WPB') 
Markets & Securities    HSBC Global             GBM Other primarily     We have a clear         In Europe, Wealth 
Services is              Banking delivers       comprises Principal     strategy to be          and Personal Banking 
a products group         tailored financial     Investments ('PI')      the Leading             serves customers 
that services            solutions to           and GBM's share         International           with their financial 
all of the Bank's        corporate and          of the Bank's           Corporate Bank          needs through 
clients, from            institutional          Markets Treasury        in Europe. We           Private Banking, 
those in Global          clients worldwide      function.               help to connect         Retail Banking, 
Banking to Commercial    opening up             The Principal           our European customers  Wealth Management, 
Banking and              opportunities          Investments portfolio   to our international    Insurance and 
Wealth and Personal      through the            ('PI') is focused       network of              Asset Management. 
Banking. We              strength of            on delivering           relationship            Our core retail 
offer clients            our global             investments that        managers and product    proposition offers 
a range of services      network and            align to the            specialists;            a full suite of 
and capabilities         capabilities.          group's strategy        supporting              products including 
including Trading,       We provide             and seeks to            their growth ambitions  personal banking, 
Financing and            a comprehensive        deliver strong          and targets. Our        mortgages, loans, 
Securities Services      suite of services      returns across          products, which         credit cards, 
across asset             including corporate    a diversified           are designed to         savings, investments 
classes and              banking, capital       portfolio. Our          help our customers      and insurance. 
geographies,             markets, advisory,     commitment to           seize growth            Alongside this, 
supported by             trade services         sustainable private     opportunities,          WPB offers various 
dedicated sales          and global             equity funds            range from term         propositions in 
and research             liquidity and          contributes directly    loans to region-wide    certain markets, 
teams.                   cash management.       to the Group's          treasury and trade      including Jade, 
Our European             Our European           aim to provide          solutions. Commercial   Premier, and Advance; 
teams play a             teams take             and facilitate          Banking is at           as well as wealth 
key role in              a client-centric       $750bn and $1tn         the centre of           solutions, financial 
providing cross-asset    approach bringing      of sustainable          creating revenue        planning and 
services, bridging       together relationship  finance and investment  synergies within        international 
Emerging and             and product            by 2030.                the Group: we           services. In the 
Developed Markets,       expertise to                                   collaborate closely     Channel Islands 
and collaborating        deliver financial                              with our Global         and the Isle of 
with other global        solutions customised                           Banking and Markets     Man, we serve 
businesses to            to suit our                                    colleagues to           local Islanders 
provide clients          clients' growth                                provide expertise       as well as 
across the Group         ambitions and                                  in capital finance      international 
with bespoke             financial objectives.                          and advisory solutions  customers through 
products and             We work closely                                to support our          our HSBC Expat 
solutions that           with our business                              Commercial Banking      proposition. 
support their            partners including                             clients. Our trade      Our Private Banking 
growth ambitions.        MSS, WPB and                                   teams within            proposition serves 
We continue              CMB, to provide                                Commercial              high net worth 
to invest in             a range of                                     Banking also provide    and ultra-high 
technology and           tailored products                              import and export       net worth clients 
digital transformation   and services                                   finance solutions       with investable 
to enhance client        that meet the                                  to Global Banking       assets greater 
experience,              needs of clients                               and Markets clients.    than $5m in Channel 
improve operational      across the                                     We also enable          Islands and Isle 
efficiencies             bank. Global                                   customers to gain       of Man, France 
and future proof         Banking Europe                                 visibility over         and Germany. The 
the business.            operates as                                    their liquidity         range of services 
We have taken            an integral                                    positions through       available to private 
actions to streamline    part of the                                    our main hubs           banking clients 
our cost base,           global business                                in France and           includes investment 
optimise the             and contributes                                Germany, which          management, Private 
usage of financial       significant                                    in turn helps           Wealth Solutions 
resources and            revenues to                                    clients to unlock       and bespoke lending 
enhance returns.         other regions                                  efficiencies in         such as lending 
Conduct is at            through our                                    their Treasury          against financial 
the heart of             European client                                structures. As          assets and residential 
everything we            base, supporting                               the European economy    mortgage financing 
do and we are            the Europe                                     pivots to a net         for high-end 
determined to            ambition to                                    zero carbon economy,    properties. 
have the highest         be the leading                                 we are expanding        Private Banking 
conduct standards        international                                  our services and        hosts a 'Next 
in the industry.         wholesale bank.                                products to provide     Generation' programme 
                                                                        customers with          of events to support 
                                                                        innovative sustainable  our client's next 
                                                                        finance solutions       generation in 
                                                                        and ensuring our        building and retaining 
                                                                        relationship managers   the wealth within 
                                                                        are informed to         the family. The 
                                                                        match these to          Private bank offers 
                                                                        our clients' net        this through its 
                                                                        zero ambitions.         philanthropy advisory 
                                                                                                to our clients, 
                                                                                                which looks at 
                                                                                                business succession 
                                                                                                planning. We continue 
                                                                                                to focus on meeting 
                                                                                                the needs of our 
                                                                                                customers, the 
                                                                                                communities we 
                                                                                                serve, and our 
                                                                                                people, whilst 
                                                                                                working to build 
                                                                                                the bank of the 
                                                                                                future. 
----------------------  ----------------------  ----------------------  ----------------------  ---------------------- 
Adjusted profit/(loss) before tax 
GBP(8)m                 GBP589m                 GBP99m                  GBP490m                 GBP323m 
(2020: GBP20m)          (2020: GBP55m)          (2020: GBP(52)m)        (2020: GBP152m)         (2020: GBP(132)m) 
----------------------  ----------------------  ----------------------  ----------------------  ---------------------- 
 

Our global businesses are presented on an adjusted basis, which is consistent with the way in which we assess the performance of our global businesses.

 
How we do business 
 

We conduct our business to support the sustained success of our customers, employees and other stakeholders.

 
Our approach 
 

The Group recognises that it is important to be clear about who we are and what we stand for to create long-term value for our stakeholders. This will help the Group deliver the strategy and operate our business in a way that is sustainable. Following an extensive consultation with the Group's people and customers, the Group refined our purpose and values. The Group's new purpose is 'Opening up a world of opportunity' with the ambition to be the preferred international financial partner for clients. To achieve this in a way that is sustainable, we are guided by values: we value difference; we succeed together; we take responsibility; and we get it done.

In 2021, our ability to help our stakeholders was more important than ever, as we continued to promote and encourage good conduct through our employees' behaviours and the decisions we take during these unprecedented times. The Group define conduct as delivering fair outcomes for its customers and not disrupting the orderly and transparent operation of financial markets. This is central to the Group's long-term success and ability to serve customers. We have clear policies, frameworks and governance in place to protect them. For further information on conduct, see page 81. Details on our conduct framework are available at www.hsbc.com/conduct.

Fair outcomes

Our conduct approach guides us to do the right thing and to focus on the impact we have for our customers and the financial markets in which we operate. It complements our purpose and values and - together with more formal policies and the tools we have to do our jobs - provides a clear path to achieving our purpose and delivering our strategy. For further information on conduct, see page 4. For further details on our purpose-led conduct approach framework, see www.hsbc.com/who-we-are. Our section 172 statement, detailing our Directors' responsibility to stakeholders, can be found on page 9.

Our Covid-19 actions

Having a clear purpose and strong values has never been more important, with the Covid-19 pandemic testing us all in ways we could never have anticipated. Since the world changed in 2020, we adapted to new ways of working and endeavoured to provide support to our customers during this challenging period. In the following section, we have set out further ways that we continued to support our stakeholders.

Our colleagues

We believe diversity makes us stronger and we are dedicated to building a diverse and connected workforce. In 2021, HSBC Bank plc increased representation of women in senior roles to 24.0% narrowly missing our target of 24.3%. However, as we progress beyond the Transformation and into growth mode, we are committed to stretching our gender target further and have set a target of 26.4% (2.4% higher than the 2021 actuals).

In July 2020, the Group set out HSBC's global race commitments, which included the goal of doubling the number of Black employees in senior roles over the following five years. In Europe, we continue to place a strong focus on the quality and transparency of our ethnicity data in countries where it is legally permissible. We are committed to improving our ethnic diversity and put in place important foundations in 2021 through leadership development programmes, inclusive hiring, and investing in the next generation of high-performing diverse talent.

Our Future Skills programme helps prepare our people for the changing skills required in the future workplace. We are encouraging our employees to take ownership of their development and supporting them to do so.

During our Future Skills Summer campaign our new Degreed Learning Experience Platform was formally launched to help colleagues shape their development using both internal and external learning content. As part of the campaign colleagues were encouraged to identify four skills they wanted to personally develop. By the end of 2021, 8,200 colleagues had successfully registered and accessed the platform. More than 8,500 hours of learning were completed by over 3,000 colleagues.

Our Climate ambition

We're playing a leading role in helping to mobilise the transition to a global net zero economy, not just by financing it, but by helping to shape and influence the global policy agenda. The Group has set on-balance sheet financed emissions targets for the oil and gas, and power and utilities sectors, aligned to the IEA's net zero scenario, underpinned by a clear science-based strategy. To support the Group's ambition of net zero financed emissions, unlocking transition finance for our portfolio of clients will be crucial. The Group has changed how disclosures are provided against the Task Force on Climate-Related Disclosures ('TCFD') framework by embedding the content previously provided in a stand-alone TCFD Update within the HSBC Holdings plc Annual Report and Accounts 2021. The summary TCFD disclosure can be found on page 63 of the HSBC Holdings plc Annual Report and Accounts 2021.

 
Engaging with our stakeholders 
 

Engaging with our stakeholders is core to being a responsible business. To determine material topics that our stakeholders are interested in, we conduct a number of activities throughout the year, including engagements outlined in the table below.

 
                                                Material 
                                                 topics highlighted 
Our stakeholders  How we engage                  by the engagement 
Customers         Our customers'                Customer 
                   voices are heard              advocacy 
                   through our interactions 
                   with them, surveys 
                   and by listening 
                   to their complaints 
----------------  ---------------------------- 
Employees         Our colleagues'               Future Skills 
                   voices are heard              and Diversity 
                   through our employee          & Inclusion 
                   Snapshot survey, 
                   Exchange meetings 
                   and our 'speak-up' 
                   channels, including 
                   our global whistleblowing 
                   platform, HSBC 
                   Confidential 
----------------  ---------------------------- 
Investors         Our ordinary shares           Coal financing 
                   are held by our               policies 
                   parent HSBC Holdings 
                   plc, however external 
                   parties invest 
                   in our bond issuance. 
                   We engage with 
                   these investors 
                   via our investor 
                   relations programme 
                   which enables investor 
                   queries alongside 
                   a broader programme 
                   of management meetings 
                   and market engagement 
----------------  ---------------------------- 
Communities       We welcome dialogue           Financial 
                   with external stakeholders,   Inclusion 
                   including non-governmental    and Community 
                   organisations ('NGOs')        Investment 
                   and other civil 
                   societies groups. 
                   We engage directly 
                   on specific issues 
                   and by taking part 
                   in external forums 
                   and working groups 
----------------  ---------------------------- 
Regulators        We proactively                Anti-bribery 
 and governments   engage with regulators        and Corruption 
                   and governments 
                   to facilitate strong 
                   relationships via 
                   virtual and in-person 
                   meetings, responses 
                   to consultations 
                   individually and 
                   jointly via the 
                   industry bodies 
----------------  ---------------------------- 
Suppliers         Our ethical and               Suppliers 
                   environmental code            ability to 
                   of conduct for                service HSBC 
                   suppliers of goods            at an appropriate 
                   and services sets             cost, risk 
                   out how we engage             profile and 
                   with our suppliers            ability to 
                   on ethical and                meet the 
                   environmental performance     demand by 
                                                 the bank 
----------------  ---------------------------- 
 

Supporting our stakeholders through Covid-19

The Covid-19 pandemic continues to create a great deal of uncertainty and disruption for the people, businesses and communities we serve around the world. It is affecting everyone in different ways, with markets at different stages of the crisis.

The outbreak continued to pose significant challenges for our customers. Our immediate priority has been to do what we can to provide them with support and flexibility; with customers doing more of their banking online, we have also deployed new technology to help enable them to engage with us in new ways.

Employee well-being remains a top priority as we transition to new ways of working and continue to navigate through the pandemic. The support we provide is driven by the feedback from our people surveys. In 2021, we launched new tools and training to support mental, physical and financial health. We are also enabling more colleagues to work flexibly and continue to follow social distancing and protection measures in line with local guidance. We firmly believe that helping our people to be healthy and happy is a key enabler of our strategy, and benefits the people and communities we serve.

 
Our ESG metrics and targets 
 

The Group has established targets, that guide how we do business, including how we operate and how we serve our customers. These include targets designed to help us to make our business - and those of our customers - more environmentally and socially sustainable. They also help us to improve employee advocacy and diversity at senior levels as well as strengthen our market conduct.

The 2021 annual incentive scorecards of the Group Chief Executive, Group Chief Financial Officer and members of the Group Executive Committee have 30% weightings for measures linked to outcomes that underpin the ESG metrics below. ESG metrics are also incorporated into the Europe Chief Executive and Executive Committee member scorecards.

Our Environmental metrics:

HSBC Holdings plc refreshed a number of metrics and targets to better align with its strategy and the vision for ESG, including its ambition to achieve zero net operational emissions by 2030. HSBC Bank plc reports emissions following the Greenhouse Gas Protocol, which incorporates the scope 2 market-based emissions methodology. We report greenhouse gas emissions resulting from the energy used in our buildings and employees' business travel. Due to the nature of our primary business, carbon dioxide is the main type of greenhouse gas applicable to our operations. While the amount is immaterial, our current reporting also incorporates methane and nitrous oxide for completeness. We do not report employee home working emissions. In 2021 we collected data on energy use and business travel for our operations in Europe in France, Germany, Malta, and Switzerland, which accounted for approximately 67% of our FTEs in HSBC Bank plc(1) .

At the end of 2021, HSBC Bank plc achieved a 12% reduction in greenhouse gas emissions compared to 2020. Emissions in 2021 were 0.61 tonnes CO(2) e per FTE.

For further information regarding our environmental footprint, please visit https://www.hsbc.com/who-we-are/our-climate-strategy/becoming-a-net-zero-bank.

Our Social metrics:

   --    Employee engagement w as 48% as at the end of 2021, up by by 2% compared to 2020(1) . 

-- Employee gender diversity, our target was 24.3% of women in senior leadership roles by the end of 2021. The outcome for 2021 was 24.0% of women in senior leadership roles(2) .

Our Governance metrics:

-- Sustained delivery of global conduct outcomes, with 97.8% of staff having completed conduct training in 2021. Our target for 2021 was 98%(3) .

1 To estimate the proportion of FTEs in HSBC Bank plc covered by the emissions data collected, we have calculated FTEs reporting into HSBC Bank plc in the relevant countries where emissions data is collected as a proportion of total FTEs in HSBC Bank plc.

2 Performance is based on our employee Snapshot results. We transitioned to the employee engagement index in 2020.

3 Senior leadership is classified as those at band 3 and above in the Group's global career band structure. We narrowly missed our 2021 target, our focus on improving gender balance in senior leadership across Europe remains a priority for HSBC Bank plc's executive committee for 2022.

4 The completion rate shown relates to the 2021 financial crime training module. The 2021 regulatory conduct training has been launched in January 2022 and will run through the first quarter of 2022.

 
Responsible Business Culture 
 

We have the responsibility to protect our customers, our communities and the integrity of the financial system. In this section, we outline our requirements under the Non-Financial Reporting Directive.

Environmental matters

In 2021, the Group joined the Net Zero Banking Alliance, a group of 43 international banks to establish a robust and transparent framework for monitoring progress and setting the standard for the banking industry.

In fulfilment of the Group's commitment approved by shareholders at the Group AGM in May 2021, the Group published a policy to phase out thermal coal financing in EU and OECD markets by 2030, and globally by 2040. This incorporates project finance, direct lending, or arranging or underwriting of capital markets transactions to in-scope clients, as well as the refinancing of existing finance facilities.

More information about the Group's assessment of climate risk can be found in the HSBC Holdings plc annual report, under the Task Force on Climate-related Financial Disclosures and climate strategy. HSBC has actively created opportunities for cross sectoral dialogue to advance the topic of sustainability, across key markets. In Germany, HSBC Bank plc and the International Chamber of Commerce organised a two day Pre COP event on climate action, global challenges, international climate policy and the role of business, involving international and national experts from the United Nations, European Union, governments, COP-Presidency (UK), civil society, business and academia. HSBC Armenia also organised, in partnership with the British Embassy, the first conference to promote sustainable finance, titled 'Joining for a Green Future'.

Employee matters

We want to encourage a dynamic and inclusive culture where our colleagues can expect to be treated with dignity, and respect. We are proud to be an organisation that takes action where we find behaviours that falls short of this expectation. We monitor achievement against this goal through metrics that we value. Listening to our colleagues is critical to the business we conduct and is reflected in our purpose and values, which were established through enterprise wide listening and engagement activities. We continue to seek innovative ways that encourage and provide opportunities for our people to speak up about things that are important to them. We recognise that at times people may not feel comfortable speaking up through the usual channels. HSBC Confidential is the Group's global whistleblowing channel, open to colleagues past and present as an anonymous route through which they can raise concerns confidentially at their discretion.

The development of our people is core to the success of our organisation. We continue to develop and implement practices that build employee capability and identify, develop and deploy talented employees; this ensures an appropriate supply of high calibre individuals with the right values, skills and experience for current and future senior management positions.

Since the launch of HSBC University in 2017, we have continued to add to the portfolio of world class leadership and professional development programmes for leaders and people managers including our flagship programmes, Accelerate into Leadership, Accelerating Female Leadership and Leading Business and Functions.

Communities

We have a responsibility to invest in the communities where we operate. We recognise that the world is evolving at a rapid pace and that a range of new and different skills are now needed for people to succeed. For this reason, much of our focus is on charitable partnerships that develop employability and financial capability skills. We also back climate solutions and innovation, and contribute to disaster relief efforts based on need. In 2021 in Europe, we contributed GBP1.7m to charitable programmes and our employees volunteered 4,200 hours to community activities during the working day.

Human rights

Our commitment to respecting human rights, principally as they apply to our employees, our suppliers and through our financial services lending, is set out in our Human Rights Statement. This statement, along with our statements under the UK's Modern Slavery Act ('MSA'), is available on www.hsbc.com/who-we-are/esg-and-responsible-business/esg-reporting-centre .

Anti-corruption and anti-bribery

We are committed to high standards of ethical behaviour and operate a zero-tolerance approach to bribery and corruption. Our anti-bribery and corruption policy sets the framework for the Group and this is followed throughout HSBC Bank plc, to comply with anti-bribery and corruption legislation in all jurisdictions in which we operate, and gives practical effect to global initiatives, such as the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Where local legislation is in place in a jurisdiction, local policies are in place as appropriate, for example in France the Sapin II law requirements is adhered to.

The principal risks addressed by our anti-bribery and corruption policy are the risk that our employees, associated persons or customers engage in bribery or corruption, or that the Group does so through its strategic activities.

HSBC conducts business with the commitment to supporting the sustained success of our customers, people and communities.

Non-Financial Information Statement

Disclosures required pursuant to the Companies, Partnerships and Groups (Accounts and Non-Financial Reporting) Regulations 2016 can be found on the following pages:

 
Environmental matters 
 (including the impact 
 of the company's business 
 on the environment)        Page 8 
--------------------------  ------------- 
The company's employees     Pages 7 to 
                             10 and 94 to 
                             95 
--------------------------  ------------- 
Social matters              Page 8 
--------------------------  ------------- 
Respect for human rights    Page 9 
--------------------------  ------------- 
Anti-corruption and         Page 9 
 anti-bribery matters 
--------------------------  ------------- 
Business model              Page 6 
--------------------------  ------------- 
Principal risks             Page 19 
--------------------------  ------------- 
 

HSBC creates value by providing products and services to meet our customers' needs. We aim to do so in a way that fits seamlessly into their lives. This helps us to build long-lasting relationships with our customers. HSBC maintains trust by striving to protect our customers' data and information, and delivering fair outcomes for them and if things go wrong, we need to address complaints in a timely manner. Operating with high standards of conduct is central to our long-term success and underpins our ability to serve our customers. Our Conduct Framework guides activities to strengthen our business and increases our understanding of how the decisions we make affect customers and other stakeholders. Details on our Conduct Framework are available at www.hsbc.com.

Section 172 statement

This section, from pages 9 to 11 forms our section 172 statement. It describes how the Directors have performed their duty to promote the success of the bank, including how they have considered and engaged with stakeholders and, in particular, how they have taken account of the matters set out in section 172(1)(a) to (f) of the Companies Act 2006 (the 'Act').

The Board considered a range of factors when making decisions and is supported in the discharge of its duties by:

a. an induction programme and ongoing training to provide an understanding of our business and financial performance and prospects;

b. management processes which help ensure that proposals presented to Board and committee meetings for decision include information relevant to determine the action that would most likely promote the success of the bank and involve engagement with stakeholders where relevant to support appropriate decision making; and

c. agenda planning for Board and committee meetings to provide sufficient time for the consideration and discussion of key matters.

Stakeholder Engagement

The Board understands the importance of effective engagement with its stakeholders and is committed to open and constructive dialogue. This helps build trust and allows the Board to better understand the impact of the bank's actions on its stakeholders and respond to the challenges facing the bank. Depending on the nature of the issue in question, however, the relevance of each stakeholder group may differ and not every decision the Board makes will necessarily result in a positive outcome for all stakeholders.

The Board continued to focus its engagement with the bank's six key stakeholders, namely the bank's customers, employees, shareholders and investors, communities, suppliers, and regulators and governments. In discharging its responsibilities, the Board seeks to understand, and have regard to, the interests and priorities of these stakeholders.

For further details regarding the role of the Board and the way in which it makes decisions, including key activities during 2021, please see page 89.

The Board regularly receives reports from management on issues concerning its stakeholders, which it takes into account in its discussions and in its decision-making process as part of their duties under section 172. In addition to this, the Board seeks to understand the interests and views of the bank's stakeholders by engaging with them directly as appropriate. The ongoing impact of the Covid-19 pandemic has restricted the Board's ability to engage with stakeholders face-to-face, but examples of how the Directors engaged with stakeholders are set out below:

Customers

Customers are at the core of the bank's business model: without customers there would be no bank. The Board strives to ensure it has a broad understanding of customers, their needs and challenges, and to give full consideration to these.

During the year, the CEO and his senior management team continued to engage directly with customers, while the Board continued to monitor the bank's approach to supporting customers. The Board received regular reports from senior management on interaction with customers, which included key performance indicators measuring the impacts and challenges to customers as a result of the ongoing Covid-19 pandemic and associated Covid-19 relief payment moratoria, the impact of the free trade agreement between the EU and UK which excluded EU-wide arrangements for financial services, the bank's Europe transformation programme and associated conduct considerations. Dedicated deep dive sessions were also held, with one such session focused on HSBC Life and the Insurance business.

Employees

Employees are critical to the successful operation of the bank and its long-term future.

During the year the Board received regular updates from senior management on various metrics and feedback tools in relation to employees, including updates on Diversity and Inclusion and the Gender Pay Gap. Updates were also provided on the impact on employee wellbeing and how the bank was supporting its staff. The focus on employees by the Board was also heightened through the frequent updates provided to the Board on the bank's Europe transformation programme and how staff were being impacted by the level of change. These updates considered key areas of people risk and the future of work in a post-pandemic environment.

Shareholders and Investors

The bank is a wholly owned subsidiary of the HSBC Holdings plc and, as such, the Board took into account the implications of its decisions with regard to its ultimate shareholder, HSBC Holdings plc, and its debt security investors.

During the course of the year, the Group Chairman held a number of principal subsidiary chair conferences which were attended by the Chairman of the Board. In addition, Chairs of the Audit and Risk Committees participated in regional Audit and Risk committee forums hosted by their Group counterparts. These were attended both by the bank's Directors as well as Audit and Risk Committee Chairs of material subsidiaries. The Board also received updates from management on the bank's debt issuance programmes.

Regulators and Governments

Directors periodically meet with the bank's regulators, the Financial Conduct Authority ('FCA') and Prudential Regulatory Authority ('PRA'). It is central to the success of the bank that it has strong relationships with these stakeholders and that there is a mutual understanding on expectations and challenges given their impact on customers, the business model and the bank's strategy.

During the year, members of the Board met regularly with regulators both in the UK and Europe and engagement continued during 2021 notwithstanding the logistical challenges posed by the impact and continued national and regional lock-downs due to the Covid-19 pandemic. The Board held a dedicated deep dive session on how HSBC interacts with regulators globally and at the European level to better understand the scope of engagement at executive level with relevant regulators in the region.

Suppliers

Suppliers are critical to supporting the infrastructure and operations of the business and have contractual relationships with the bank.

During the year, the Board received an update on the bank's performance against its statutory reporting obligations in respect of the payment of third party suppliers. This also provided an insight into the impact of its procurement processes and procedures on suppliers.

Communities and Environment

The bank has legal, regulatory and social responsibilities to the community and its environment.

During the year the Board received updates on the Group's evolving climate and sustainable finance strategy and net zero ambition. As we go into 2022, and as a sustainable finance strategy tailored for European business is further developed, the Board will receive updates on the bank's delivery against the ambition and strategy execution.

Employee Engagement

The Chief Executive Officer and senior management are actively involved in the engagement of employees through leadership calls and quarterly all employee webcasts to keep the workforce up-to-date on business developments and answer questions. In addition, the Chief Executive Officer issues a Europe-wide newsletter which updates employees on initiatives across the region. The Board receives regular updates from the Chief Executive Officer and the Head of HR on employee matters, including feedback received through Town Halls and Exchanges, as well as through regular employee surveys. One of the non-executive Directors also has a particular focus on employee matters to enhance the Board's view of people issues and to gain a better understanding of the employee perspective. Further details of the bank's engagement with employees can be found on pages 7 to 10 and 94 to 95.

Principal Decisions

Set out below are some of the principal decisions made by the Board during 2021. In each case, in taking such decisions, the Directors exercised their statutory duties, including the duty to act in the way that they consider, in good faith, would be most likely to promote the success of the bank for the benefit of its members as a whole.

Europe Transformation Programme

Following a revision of the bank's operating plan in 2020 in response to the revised Group strategy, in 2021 the Board continued to oversee and challenge management in their execution of the bank's Europe transformation programme. The bank's continued focus on simplification of its presence in the region included a proposal being brought to the Board in May 2021 for the disposal of the group's non-core retail banking business in France.

Prior to approval, the Board constructively challenged and engaged with senior management to consider the financial and commercial profile of the business itself, alternative proposals in respect of the retail business and the likely consequences of the disposal on the bank's key stakeholders, including customers and its shareholder and investors. In considering stakeholders, the Board also considered the consultation undertaken with relevant French works' councils, and the interests of the bank's employees, in respect of the disposal. Completion of the disposal will involve engagement with other key stakeholders, including relevant regulators.

In reaching its decision, the Board acknowledged the rationale for the transaction in the context of the strategy for the group set by its shareholder and considered the interests of its shareholder in undertaking the disposal. It concluded that the disposal would be a strong enabler in simplifying HSBC's business in Continental Europe, allowing management to accelerate the transformation of the European wholesale banking franchise. Additionally, the Board had regard to customers. In particular, the Board considered the terms negotiated as part of the transaction to help to ensure an effective transition of the business to the buyer in light of the importance of maintaining ongoing support for customers. Furthermore, the proposed sale to an experienced investor, with a strategic focus on retail banking, was recognised as giving support to the development of the retail business over the longer term.

Having taken all of these and other factors into account, including an assessment of the financial merits and risks, and the interests of employees, the Board agreed to proceed with the proposal on the basis that it considered that it was in the best interests of the bank's members as a whole and would promote the long term success of the bank, as subsequently announced by HSBC on 18 June 2021.

Legacy Capital Consent Solicitation

A key regulatory responsibility of the bank for a number of years has been to help facilitate an industry-wide transition from the use of interbank offered rates ('Ibors'), such as the London interbank offered rate ('Libor'), to using near risk free replacement rates ('RFRs') or alternative reference rates. The bank had two externally-issued outstanding English law capital instruments (one of which was issued through a Jersey Limited Partnership vehicle) that contained provisions requiring the interest rate to be determined by reference to a GBP Libor rate.

In view of the anticipated demise of GBP Libor from the end of 2021, in July 2021, the Board considered a proposal to seek consent from the bondholders to amend the terms and conditions of such instruments, to transition them from using GBP Libor to calculate the interest rate to instead use the Sterling Overnight Index Average ('SONIA') rate, which is the RFR recognised as the preferred alternative rate for sterling markets.

As part of its consideration, the Board took into account the impact of the project on the bank's key stakeholders, in particular its investors in such instruments, and its obligations to, and relationship with, its regulators. In this respect, the Board acknowledged the expectations of the regulators that the bank seeks to swiftly transition its portfolio of legacy GBP Libor contracts (which includes these instruments) prior to the anticipated demise date for GBP Libor. From an investor perspective, the Board was mindful of the need to adopt transition terms that were consistent with others in the market and that included the industry agreed adjustment spread to be added to the relevant SONIA rate, to compensate investors for the difference between SONIA and Libor reference rates.

 
Having considered these factors, 
 the Board recognised and approved 
 the need for the bank to seek the 
 consent of bondholders to transition 
 these instruments, acknowledging 
 that this would be in the best interests 
 of the bank's members as a whole 
 and would promote the long term 
 success of the bank. Tax 
 

Our approach to tax

We are committed to applying both the letter and the spirit of the law in all territories where we operate, and have adopted the UK Code of Practice for the Taxation of Banks. As a consequence, we seek to pay our fair share of tax in the countries in which we operate. We continue to strengthen our processes to help ensure our banking services are not associated with any arrangements known or suspected to facilitate tax evasion.

HSBC continues to apply global initiatives to improve tax transparency such as:

   --    the US Foreign Account Tax Compliance Act ('FATCA'); 

-- the OECD Standard for Automatic Exchange of Financial Account Information (also known as the Common Reporting Standard);

   --    the Capital Requirements Directive IV ('CRD IV') Country by Country Reporting; 
   --    the OECD Base Erosion and Profit Shifting ('BEPS') initiative; and 

-- the UK legislation on the corporate criminal offence ('CCO') of failing to prevent the facilitation of tax evasion.

We do not expect the BEPS or similar initiatives adopted by national governments to adversely impact our results.

 
Key Performance Indicators 
The Board of Directors tracks the 
 group's progress in implementing 
 its strategy with a range of financial 
 and non-financial measures or key 
 performance indicators ('KPIs'). 
 Progress is assessed by comparison 
 with the group strategic priorities, 
 operating plan targets and historical 
 performance. The group reviews its 
 KPIs regularly in light of its strategic 
 objectives and may adopt new or 
 refined measures to better align 
 the KPIs to HSBC's strategy and 
 strategic priorities. Financial 
 KPIs 
 
 
                                         2021                       2020 
-----------------------  --------------------  ------------------------- 
Profit/(loss) before 
 tax (reported) (GBPm)                  1,023                    (1,614) 
-----------------------  --------------------  ------------------------- 
Profit/(loss) before 
 tax (adjusted) (GBPm)                  1,577                      (184) 
Cost efficiency ratio 
 (reported) (%)                          89.2                      113.6 
-----------------------  --------------------  ------------------------- 
Cost efficiency ratio 
 (adjusted) (%)                          80.9                       89.6 
-----------------------  --------------------  ------------------------- 
Return on tangible 
 equity (%)                               6.1                      (2.7) 
-----------------------  --------------------  ------------------------- 
Common equity tier 
 1 capital ratio (%)                     17.3                       14.7 
-----------------------  --------------------  ------------------------- 
 

Profit/(loss) before tax (reported/adjusted): Reported profit/(loss) before tax is the profit/(loss) as reported under IFRS. Adjusted profit/(loss) before tax adjusts the reported profit/(loss) for the effect of significant items as detailed on pages 15 to 16.

Reported profit before tax in 2021 was GBP1,023m compared with a loss before tax of GBP(1,614)m in 2020. This was primarily driven by lower reported operating expenses driven by the non-recurrence of a GBP802m impairment of intangible assets in 2020

and lower restructuring and other related costs, including severance costs, arising from the bank's transformation programme. Expected credit losses and other credit impairment charges ('ECL') were significantly lower reflecting an improvement in the economic outlook. Revenue was higher compared with 2020, notably in our insurance manufacturing business in WPB, partly offset by higher restructuring and other related costs comprising disposal losses associated with RWA reductions which related to the commitments at our February 2020 business update.

Adjusted profit before tax was GBP1,577m compared with a loss before tax of GBP(184)m in 2020. This was driven by lower ECL and lower operating expenses as well as strong revenue performance. The increase in revenue included positive market impacts on the present value of in-force ('PVIF') insurance contracts in insurance manufacturing in WPB driven by an increase in interest rate yield curves and favourable movements in valuation adjustments in Markets and Securities Services ('MSS'). Operating expenses decreased as a result of the tight control of discretionary spend to reflect the economic outlook and the initial impact of our transformation of the bank. This was partly offset by the UK bank levy incurred in 2021, which was previously paid by the Group. In addition, there was a gain of GBP191m compared with a loss of GBP(1)m in 2020 recognised from our share of profit/(loss) from associates.

Reported cost efficiency ratio was 24.4 percentage points lower compared with 2020 driving by higher revenue and lower operating expenses. Reported revenue increased by 3.7% and reported operating expenses decreased by 18.5%, mainly driven by the factors mentioned above.

Adjusted cost efficiency ratio improved by 8.7 percentage points from 2020, reflecting higher revenue and lower costs Revenue increased by 5.6%, mainly driven by favourable PVIF and positive valuation adjustments. Operating expenses decreased by 4.7%, mainly driven by lower costs reflecting our transformation plans partly offset by the UK bank levy and higher variable pay.

Return on tangible equity ('RoTE') is computed by adjusting reported profit attributable to ordinary shareholders by excluding movements in PVIF and significant items (net of tax), divided by average tangible shareholders' equity excluding fair value of own debt, debt valuation adjustment ('DVA') and other adjustments for the period. The adjustment to reported results and reported equity excludes amounts attributable to non-controlling interests.

We provide RoTE as a way of assessing our performance, which is closely aligned to our capital positions.

CET1 capital ratio represents the ratio of common equity tier 1 capital to total risk-weighted assets ('RWA'). CET1 capital is the highest quality form of capital comprising shareholders' equity and related non-controlling interests less regulatory deductions and adjustments.

The group seeks to maintain a strong capital base to support the development of its business and meet regulatory capital requirements at all times.

The CET1 capital ratio of 17.3% in 2021 increased by 2.6 percentage points from 2020, mainly due to a reduction in RWAs.

 
Non-financial KPIs 
 

We monitor a range of non-financial KPIs focusing on customers, people, culture and values including customer service satisfaction, employee engagement and diversity and sustainability.

For details on customer service and satisfaction please refer below; for the remaining non-financial KPIs, refer to the Non financial reporting section on page 8 and Corporate Governance section on pages 88 to 96. Customer service, awards and satisfaction

MSS

Our customers are at the heart of what we do and we are committed to delivering services and capabilities that meet their needs and help them fulfil their ambitions.

In 2021, we won numerous awards and consistently ranked highly with our European clients, including winning Currency Manager of the Year at the European Pension Awards, Western Europe's Best Bank for SMEs by EuroMoney, ranking number one for overall service quality in Continental Europe in the Coalition Greenwich Foreign Exchange study, and ranking number one in both the UK and Ireland as best fund and administration provider in the R&M Investor Services Survey.

These accolades, coupled with multiple milestones and achievements in sustainable finance, demonstrate our unique capabilities to support clients locally and connect them to markets and expertise in the East, as well the key role Europe plays in supporting the Group's strategic priorities.

GB

Within Global Banking Europe we remain committed to providing excellent customer experience and we continue to strive towards improving our proposition to meet client needs.

In 2021, HSBC received a number of external awards, recognising the support we've provided to our clients for example, Investment Bank of the Year for Bonds by The Banker.

Aligned with our strategy of opening up opportunities for our clients, HSBC was also recognised with an Excellence Award in International Network Breadth by the Coalition Greenwich Awards and won seven bond awards from Environmental Finance in 2021. These awards, in particular, highlight the continued strength and differentiation of our ESG capabilities globally as well as the role we play in Europe helping our clients transition to net zero.

CMB

Customer experience and satisfaction are fundamental priorities for Commercial Banking in Europe. We measure a number of metrics, track customer service levels and gather direct customer feedback to ensure our solutions and channels remain relevant and fit for our customers' needs today. In 2021, we launched Europe 1 Form, a single document addressing all of a clients' onboarding requirements to enable an account being opened. These type of initiatives help to improve our customers' journeys and experience, and ensures that we continue to achieve internal operating efficiencies. We have also pivoted towards a centralised booking model, which has enabled us to provide regional coverage to our customers and helped to support our their needs on a pan-European basis. Looking ahead, we will continue to support our customers to formulate transition plans to achieve their net-zero targets.

WPB

In WPB Europe, enhancing customer experience and improving satisfaction remains integral to our strategy. This is monitored through a number of customer satisfaction metrics covering branch, contact centre and digital channels. We recognise the importance of customer feedback and continue to enhance our insights to gain a better understanding of our clients to provide a more personalised and relevant service.

Digital continues to be a principal area of investment; enhancing customer experience, reducing processing costs and driving the sustainability agenda. In Expat we have launched a new mobile app including the deployment of soft token. This will reduce the need for over 20,000 hard tokens being sent to customers globally. Our Private Banking arm is also committed to enhancing digital offerings, including enhanced capabilities to support our advisory offering, and improved internal platforms and software to support our people in delivering excellent client service.

We recognise that enhancing customer satisfaction is an evolving process and are committed to ensure our investments and focus are prioritised to achieve this.

 
Economic background and outlook 
 
 
UK 
 

Continued recovery amid high inflation

The UK economy grew by 1% in the fourth quarter of 2021, bringing the level of output to 0.4% above its pre-pandemic level. While the UK only tightened restrictions modestly over the winter in response to concerns surrounding the Omicron variant of COVID-19, the pace of economic growth slowed and uncertainty remains high. Much of the expansion through 2021 was driven by household and government spending. On the other hand, business investment and exports have been subdued (10% and 18% below their pre-pandemic peaks). Headwinds related to the UK's exit from the EU might have played a role.

As the economy has rebounded, it has run into supply constraints, both in terms of global supply chain disruption, and labour shortages. The former might be constraining trade and manufacturing, while the latter has been associated with record job vacancy levels.

These supply issues, coupled with significant rises in energy prices - wholesale gas prices in particular - have led to a sharp rise in inflationary pressure. The annual CPI inflation rate stood at 5.5% in January 2022, more than double the Bank of England's 2% target. Inflation is expected to rise further in the near term, with sharp rises in regulated utility prices set for April.

Looking ahead, HSBC Research expects the UK economy to continue to normalise following the worst of the pandemic-related disruption, with GDP growing by 4% in 2022 and by 1.6% in 2023. As energy and supply-related pressures eventually ease, HSBC Research expects CPI inflation to start falling back through 2022, then fall to around the 2% mark in 2023.

UK rates could rise this year

Given inflation strength and 'tightness' in the labour market, the Bank of England ('BoE') has begun to tighten monetary policy, with a 15 basis point rise in Bank Rate in December and a 25 basis point increase in January, lifting the rate to 0.50%. HSBC Research expects another three rate increases in 2022 bringing Bank Rate up to 1.25%. The BoE has announced that, with Bank Rate now at 0.50%, it will stop reinvesting maturing government bonds held as part of its Quantitative Easing ('QE') programme.

Fiscal policy, which has been highly supportive since the onset of the pandemic, is set to achieve a narrowing in the government budget deficit over the coming years. As part of the consolidation, and in order to meet the increasing spending commitments relating to an ageing population, taxes as a share of the overall economy are set to rise, according to the government's forecasts, to levels not seen since early the 1950s.

 
Eurozone 
 

Recovering from renewed Covid-19 concerns

Even before heightened concerns about the Omicron variant, Covid-19 cases were rising sharply in several European countries. In response, several countries curtailed hospitality-sector opening hours and tightened restrictions for unvaccinated people. This has compounded ongoing headwinds from supply chain disruption, which has weighed on the manufacturing sector in particular. And economic growth slowed in the fourth quarter, from 2.2% to 0.3%, though that allowed GDP to return to its pre-pandemic peak. More recently, case numbers have been in decline and the business surveys point to a pick-up in near-term growth.

Despite the softening in overall activity at the turn of the year, the labour market has remained robust. In December 2021, the eurozone unemployment rate declined from 7.1% to 7.0%. That compares to a December 2020 peak of 8.4% and a February 2020 level of 7.3%.

As a result of sharp rises in energy prices, and supply disruption, annual eurozone consumer price inflation reached a record high of 5.1% in January 2022. Importantly though, eurozone wage cost pressures remain fairly contained, keeping a lid on underlying inflation rates.

HSBC Research expects a continued economic recovery, with eurozone GDP growing by 3.5% in 2022 and 2.3% in 2023. Meanwhile, as long as wage pressures remain in check, and assuming an easing in supply disruption, inflation is likely to fall sharply over the coming months. HSBC Research sees the headline inflation rate falling to around the 2% mark in early 2023.

Eurozone interest rates could rise this year

Although eurozone wage pressures appear to remain fairly soft, significant upside news to inflation, alongside the ongoing economic recovery, means that the European Central Bank ('ECB') has signalled the possibility of paring back monetary policy stimulus. In December the ECB announced that it will end its Pandemic Emergency Purchase Programme ('PEPP') in March 2022.

Beyond that, HSBC Research expects the ECB to end net asset purchases under its regular Asset Purchase Programme ('APP') by the end of September 2022, paving the way for a 25 basis point rise in the Deposit Rate (from -0.50% to -0.25%) in October 2022, then another 25 basis point increase in March 2023. In mid-February, market prices pointed to a faster pace of ECB tightening, with more than 40bps of rate rises priced in for 2022.

 
Financial summary 
 
 
Use of alternative performance measures 
 

Our reported results are prepared in accordance with International Financial Reporting Standards ('IFRSs'), as detailed in the Financial Statements starting on page 107. In measuring our performance, the financial measures that we use include those derived from our reported results in order to eliminate factors that distort year-on-year comparisons. These are considered alternative performance measures.

All alternative performance measures are described and reconciled to the closest reported financial measure when used.

Adjusted performance

Adjusted performance is computed by adjusting reported results for the year-on-year effects of significant items that distort year-on-year comparisons.

We use 'significant items' to describe collectively the group of individual adjustments excluded from reported results when arriving at adjusted performance. These items are ones that management and investors would ordinarily identify and consider separately when assessing performance to understand better the underlying trends in the business. We consider adjusted performance provides useful information for investors by aligning internal and external reporting, identifying and quantifying items management believes to be significant and providing insight into how management assesses year-on-year performance.

 
Summary consolidated income statement for the year ended 
                                                                             2021                                 2020 
                                                                             GBPm                                 GBPm 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Net interest income                                                         1,754                                1,898 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Net fee income                                                              1,413                                1,400 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Net income from financial instruments 
 measured at fair 
 value                                                                      3,432                                2,314 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Gains less losses from financial investments                                   60                                   95 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Net insurance premium income                                                1,906                                1,559 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Other operating income                                                        594                                  417 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Total operating income(1)                                                   9,159                                7,683 
Net insurance claims, benefits paid and 
 movement in 
 liabilities to policyholders                                             (3,039)                              (1,783) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Net operating income before change in 
 expected credit 
 losses and other credit impairment 
 charges(1)                                                                 6,120                                5,900 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Change in expected credit losses and other 
 credit impairment 
 charges                                                                      174                                (808) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Net operating income                                                        6,294                                5,092 
Total operating expenses excluding impairment 
 of goodwill 
 and other intangible assets(2)                                           (5,416)                              (5,903) 
Impairment of goodwill and other intangible 
 assets                                                                      (46)                                (802) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Operating profit/(loss)                                                       832                              (1,613) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Share of profit/(loss) in associates and 
 joint ventures                                                               191                                  (1) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Profit/(loss) before tax                                                    1,023                              (1,614) 
Tax credit                                                                     23                                  136 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Profit/(loss) for the year                                                  1,046                              (1,478) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Profit/(loss) attributable to the parent 
 company                                                                    1,041                              (1,488) 
---------------------------------------------  ----------------------------------  ----------------------------------- 
Profit attributable to non-controlling 
 interests                                                                      5                                   10 
---------------------------------------------  ----------------------------------  ----------------------------------- 
 

1 Net operating income before change in expected credit losses and other credit impairment charges is also referred to as revenue.

   2   Total operating income and expense include significant items as detailed on pages 14 to 16. 

2

 
Reported performance 
 

Performance in 2021 was stronger compared with 2020, which was heavily impacted by the Covid-19 pandemic.

Reported profit before tax was GBP1,023m, compared with a loss before tax in 2020 of GBP(1,614)m, an increase of GBP2,637m. This was mainly due to a significant reduction in operating expenses, a net release in ECL compared with charges in 2020, and stronger revenue performance.

Reported revenue was GBP220m higher, largely driven by favourable market impacts on the present value of in-force ('PVIF') long-term insurance contracts in insurance manufacturing in WPB. Also, 2020 revenue included a significant negative impact from valuation adjustments in MSS. This was partly offset in 2021 by higher restructuring and other related costs comprising disposal losses associated with RWA reductions, related to the commitments at our February 2020 business update. ECL were lower driven by a net release in 2021 compared with net charge in 2020 as a result of the deteriorating economic outlook during the onset of the Covid-19 outbreak. Operating expenses were lower, mainly driven by the non-recurrence of a impairment of goodwill and other intangible assets and lower transformation costs, partly offset by the UK bank levy incurred for the first time in 2021. In addition, there was also a gain compared with a loss in 2020 recognised from our share of profit/(loss) from associates.

Net interest income ('NII') decreased by GBP144m or 8% compared with the prior year. NII was lower mainly driven by the impact of lower interest rate environment, notably in Retail deposits in WPB and in GLCM (in Global Banking). Revenue was also lower due to a reduction in balance sheet lending as a result of the transformation programme to reduce RWAs. This was partly offset by a reduction in the funding cost of trading assets, and through initiatives to reduce the overall funding costs of the bank through retiring more expensive wholesale funding.

Net fee income increased by GBP13m or 1% compared with the prior year, primarily in WPB largely in Asset Management driven by favourable market conditions and in Retail due to higher fees commission driven by increased levels of customer activity compared to 2020, which was impacted by the Covid-19 pandemic.

Net income from financial instruments measured at fair value increased by GBP1,118m or 48% compared with the prior year. In WPB, revenue increased primarily reflecting a stronger equity market performance and higher interest rate yields in France compared with 2020 when the value of equity and unit trust assets supporting insurance contracts were heavily impacted by the Covid-19 outbreak.

This favourable movement resulted in a corresponding movement in liabilities to policyholders, reflecting the extent to which policyholders participate in the investment performance of the associated assets. The offsetting movements are recorded in net insurance claims and benefits paid and movement in liabilities to policyholders.

Revenue also increased in MSS largely driven by lower adverse credit and funding valuation adjustments compared with 2020. Excluding this, revenue was lower, as 2020 benefited from higher market volatility supporting a particularly strong performance within Global Foreign Exchange and Global Debt Markets, notably in the UK.

By contrast, revenue decreased in GBM Other, mainly driven by higher restructuring and other related costs comprising disposal losses associated with RWA reductions, related to the commitments at our February 2020 business update.

Gains less losses from financial investments decreased by GBP35m, mainly driven by lower gains on the disposal of bonds held at fair value through other comprehensive income ('FVOCI') in Markets Treasury.

Net insurance premium income increased by GBP347m or 22%, in WPB, from insurance manufacturing revenue in France driven by higher new business volumes.

Net insurance claims, benefits paid and movement in liabilities to policyholders increased by GBP1,256m or 70%, primarily in the insurance business in WPB. The increase was driven by higher returns on financial assets supporting contracts

where the policyholder is subject to part or all of the investment risks. The gains recognised on the financial assets measured at fair value through profit and loss that are held to support these insurance contract liabilities are reported in 'Net income from financial instruments designated at fair value'. This was partly offset by a increase in premium income.

Other operating income increased by GBP177m or 42%, mainly due to favourable market impacts, notably on PVIF, in insurance manufacturing in WPB. This reflected a stronger equity market performance and higher interest rate yields on the valuations of the liabilities under insurance contracts. This was partly offset by lower revenue in GBM Other due to lower intercompany recharge recoveries from other entities in the Group, with an offsetting decrease in operating expenses.

Changes in expected credit losses and other credit impairment charges ('ECL') were a net release of GBP174m in 2021, compared with a net charge of GBP808m in 2020. The net release in 2021 reflected an improvement in the economic outlook and a stabilisation of credit risk. This compared with the significant build-up of stage 1 and stage 2 allowances in 2020 due to the worsening economic outlook at the onset of the Covid-19 outbreak. The reduction in ECL compared with 2020 also reflected lower levels of stage 3 charges.

Total operating expenses excluding impairment of goodwill and other intangible assets decreased by GBP487m or 8%, mainly driven by a reduction in staff costs, lower contractor and consultancy spend, and lower discretionary spend, in line with our transformation plan. In addition, there was also lower expenses related to severance costs arising from cost efficiency measures across our global businesses and function. This reduction was partly offset by the UK bank levy incurred in 2021, which was previously paid by the Group.

Impairment of goodwill and other intangible assets was GBP756m lower compared with the prior year. In 2020, operating expenses included a GBP802m goodwill impairment which principally comprised the write-off of capitalised software. This mainly related to our businesses in the UK and France and reflected the underperformance and deterioration in the future forecasts of these businesses, substantially relating to prior periods.

Share of profit/(loss) in associates and joint ventures was a profit of GBP191m compared with a loss of GBP(1)m in 2020. The profit in 2021 included a GBP93m true-up of prior year valuations in the underlying investments of an associate.

Tax credit was GBP113m lower compared with 2020. The effective tax rate of 2.3% for 2021 included favourable non-recurring items in respect of tax rate changes, prior period adjustments and the recognition of previously unrecognised deferred tax assets in France.

The effective tax rate of 8.4% for 2020, representing a tax credit on loss before tax, was mainly due to the non-recognition of deferred tax on the loss in France for the period.

 
Adjusted performance 
 
 
Significant revenue items by business segment - (gains)/losses for 
 the year ended 
                                                                                                                      GBM                                                            Corporate 
                                                                            MSS                    GB               Other                    CMB                    WPB                 Centre                  Total 
                                                                           GBPm                  GBPm                GBPm                   GBPm                   GBPm                   GBPm                   GBPm 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
31 Dec 2021 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
Reported revenue                                                          2,043                 1,367                 310                  1,096                  1,276                     28                  6,120 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
Significant revenue items                                                    12                     -                 269                    (1)                    (1)                   (69)                    210 
 
  *    fair value movements on financial instruments(1)                      12                     -                 (5)                    (1)                    (1)                      -                      5 
------------------------------------------------------- 
 
  *    restructuring and other related costs(2)                               -                     -                 274                      -                      -                   (69)                    205 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  --------------------- 
Adjusted revenue                                                          2,055                 1,367                 579                  1,095                  1,275                   (41)                  6,330 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
31 Dec 2020(3) 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
Reported revenue                                                          1,966                 1,381                 437                  1,132                  1,035                   (51)                  5,900 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
Significant revenue items                                                     2                     -                 187                      1                      -                   (93)                     97 
 
  *    fair value movements on financial instruments(1)                       2                     -                   2                      1                      -                    (2)                      3 
------------------------------------------------------- 
 
  *    restructuring and other related costs(2)                               -                     -                 185                      -                      -                   (91)                     94 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  --------------------- 
Adjusted revenue                                                          1,968                 1,381                 624                  1,133                  1,035                  (144)                  5,997 
-------------------------------------------------------  ----------------------  --------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
 

1 Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.

   2   Includes losses associated with the RWA reduction commitments. 

3 A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to

Note 9: Segmental Analysis on page 138.

 
Significant cost items by business segment - (recoveries)/charges for 
 the year ended 
                                                                                                                       GBM                                                            Corporate 
                                                                               MSS                    GB             Other                    CMB                    WPB                 Centre                  Total 
                                                                              GBPm                  GBPm              GBPm                   GBPm                   GBPm                   GBPm                   GBPm 
----------------------------------------------------------  ----------------------  --------------------  ----------------  ---------------------  ---------------------  ---------------------  --------------------- 
31 Dec 2021 
----------------------------------------------------------  ----------------------  --------------------  ----------------  ---------------------  ---------------------  ---------------------  --------------------- 
Reported operating expenses                                                (2,064)                 (918)             (588)                  (611)                  (981)                  (300)                (5,462) 
----------------------------------------------------------  ----------------------  --------------------  ----------------  ---------------------  ---------------------  ---------------------  --------------------- 
Significant cost items                                                           -                     -               103                    (1)                      6                    236                    344 
---------------------------------------------------------- 
 
  *    restructuring and other related costs                                     -                     -               103                    (1)                      6                    236                    344 
---------------------------------------------------------- 
 
  *    settlements and provisions in connection with legal 
       and regulatory matters                                                    -                     -                 -                      -                      -                      -                      - 
---------------------------------------------------------- 
                                                                                 -                     -                 -                      -                      -                      -                      - 
  *    impairment of other intangible assets 
---------------------------------------------------------- 
Adjusted operating expenses                                                (2,064)                 (918)             (485)                  (612)                  (975)                   (64)                (5,118) 
----------------------------------------------------------  ----------------------  --------------------  ----------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
31 Dec 2020(2) 
Reported operating expenses                                                (1,950)                 (878)           (1,351)                  (773)                (1,169)                  (584)                (6,705) 
----------------------------------------------------------  ----------------------  --------------------  ----------------  ---------------------  ---------------------  ---------------------  --------------------- 
Significant cost items                                                           1                     -               679                    114                     41                    498                  1,333 
 
  *    restructuring and other related costs(1)                                  -                     -               218                     79                      5                    377                    679 
---------------------------------------------------------- 
 
  *    settlements and provisions in connection with legal 
       and regulatory matters                                                    1                     -                 -                      -                      -                      8                      9 
---------------------------------------------------------- 
 
  *    impairment of other intangible assets                                     -                     -               461                     35                     36                    113                    645 
---------------------------------------------------------- 
Adjusted operating expenses                                                (1,949)                 (878)             (672)                  (659)                (1,128)                   (86)                (5,372) 
----------------------------------------------------------  ----------------------  --------------------  ----------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
   1   Includes the write down of software GBP148m. 

2 A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to

Note 9: Segmental Analysis on page 138.

 
Net impact on profit/(loss) before tax by business segment 
                                                                                              GBM                                                           Corporate 
                                                     MSS                    GB              Other                    CMB                    WPB                Centre                Total 
                                                    GBPm                  GBPm               GBPm                   GBPm                   GBPm                  GBPm                 GBPm 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
31 Dec 2021 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
Reported profit/(loss) before 
 tax                                                (20)                   589              (273)                    492                    318                  (83)                1,023 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
Net impact on reported profit 
 and loss                                             12                     -                372                    (2)                      5                   167                  554 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
 
  *    Significant revenue items                      12                     -                269                    (1)                    (1)                  (69)                  210 
-------------------------------- 
 
  *    Significant cost items                          -                     -                103                    (1)                      6                   236                  344 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  -------------------- 
Adjusted profit/(loss) before 
 tax                                                 (8)                   589                 99                    490                    323                    84                1,577 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
 
31 Dec 2020(1) 
Reported profit/(loss) before 
 tax                                                  17                    55              (918)                     37                  (173)                 (632)              (1,614) 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
Net impact on reported profit 
 and loss                                              3                     -                866                    115                     41                   405                1,430 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
 
  *    Significant revenue items                       2                     -                187                      1                      -                  (93)                   97 
-------------------------------- 
 
  *    Significant cost items                          1                     -                679                    114                     41                   498                1,333 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  -------------------- 
Adjusted profit/(loss) before 
 tax                                                  20                    55               (52)                    152                  (132)                 (227)                (184) 
--------------------------------  ----------------------  --------------------  -----------------  ---------------------  ---------------------  --------------------  ------------------- 
 

1 A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to

Note 9: Segmental Analysis on page 138.

Adjusted performance

Adjusted profit before tax was GBP1,577m compared with a loss before tax of GBP(184)m in 2020, up GBP1,761m. This reflected lower ECL, a strong revenue performance and lower operating expenses. There was also a gain in our share of profit in associates and joint ventures compared with a loss in 2020. ECL were significantly lower mainly reflecting an improvement in the economic outlook from 2020. Adjusted revenue performance was stronger largely driven by the impact of volatile items including favourable market impacts on insurance manufacturing in WPB and favourable valuation adjustments in MSS. Adjusted operating expenses were lower as a result of our transformation plans and continued prudent management of discretionary spend. This was partly offset by the UK bank levy which incurred in 2021.

Adjusted revenue increased by GBP333m or 6%, partly offset by unfavourable movements in foreign exchange. Excluding this, revenue increased primarily in WPB, MSS and Corporate Centre. The increase in WPB reflected favourable market impacts on insurance manufacturing as equity markets performance remained strong compared with 2020, which was heavily impacted by the Covid-19 pandemic. In MSS, adjusted revenue was higher driven by lower adverse credit and funding valuations and continued momentum in Equities performance, partly offset by lower revenue in Global FX driven by lower market volatility. Revenue also increased in Corporate Centre, primarily due to a fair value gain from a long-standing investment in a Germany-based company. There were also gains from disposals in Legacy Credit.

Adjusted ECL were GBP982m lower compared with 2020. There was a net release of GBP174m compared with a net charge of GBP808m in 2020. In 2021, there were releases of stage 1 and 2 provisions reflecting an improvement in the economic outlook and a stabilisation of credit risk, compared with a significant build-up of allowances in the first half of 2020 at the onset of the Covid-19 outbreak. There were also lower charges against specific wholesale customers during 2021 compared with 2020.

Adjusted operating expenses decreased by GBP254m or 5%, in part due to favourable movements in foreign exchange. Excluding this, operating expenses decreased as we reviewed and re-prioritised spend aligning with our transformation plans and to reflect the economic outlook. This resulted in a reduction in FTE, tight control of contractor and consultancy spend as well as lower discretionary spend. This decrease was partly offset by the UK bank levy booked in 2021, which was previously paid by the Group.

Share of profit/(loss) in associates and joint ventures was a profit of GBP191m compared with a loss of GBP(1)m in 2020. Profit in 2021 included a GBP93m true-up of prior year valuations in the underlying investments of an associate.

Markets and Securities Services

Adjusted loss before tax was GBP(8)m compared to a profit before tax of GBP20m, down GBP28m compared with 2020. This was driven by higher operating expenses, largely offset by higher revenue.

Revenue increased by GBP87m or 4%, mainly driven by lower adverse credit and funding valuations compared with 2020 and a stronger performance in Equities, notably in structured derivatives, driven by higher market volatility. This was partly offset by lower revenue in Global FX as, in 2020, there was an exceptional level of volatility and client activity driven by the onset of the Covid-19 outbreak.

Operating expenses increased by GBP115m or 6%, largely driven by an increase in performance-related pay reflecting higher revenue and a higher Single Resolution Fund ('SRF') levy in France and Germany. This was partly offset by a reduction in staff costs resulting from our transformation cost-saving initiatives.

Global Banking

Adjusted profit before tax was GBP589m, an increase of GBP533m compared with 2020, largely driven by lower ECL, partly offset by higher operating expenses.

Revenue decreased by GBP14m or 1%, mainly driven by unfavourable movements in foreign exchange. Excluding this, revenue remained broadly stable compared with 2020. This was despite a reduction in interest rates in the first half of 2020 and lower customer balances in 2021, reflecting actions taken to reduce RWAs as part of our transformation. Revenue in 2020 included mark-to-market losses which were not repeated in 2021.

ECL net credit of GBP139m compared to a net charge of GBP448m in 2020. The net credit in 2021 mainly reflected releases of stage 1 and stage 2 allowances as the economic outlook improved. This compared with the significant build-up of charges in 2020 resulting from the deterioration in the economic situation due to the Covid-19 outbreak.

Operating expenses were GBP40m or 5% higher compared with 2020, mainly driven by higher performance-related pay, partly offset by a reduction in staff costs resulting from our transformation cost-saving initiatives.

Global Banking and Markets Other

Adjusted profit before tax was GBP99m, compared with a loss before tax of GBP(52)m in 2020. This was largely driven by lower operating expenses and gains from disposals in Principal Investments ('PI').

Revenue decreased by GBP45m or 7%, mainly driven by lower intercompany cost recoveries which resulted from a change in billing methodology of GBM costs, where recharges and recoveries were moved to other entities in the Group (with an offsetting reduction in operating expenses). This was partly offset by higher revenue in PI driven by gains following disposals of a number of funds in 2021 compared with losses in 2020.

Operating expenses decreased by GBP187m or 28% compared with 2020, including the move of certain GBM costs from the bank to other entities in the Group (offset by lower intercompany recoveries in revenue). In addition, there was a reduction in staff costs and performance-related pay resulting from our transformation initiatives. This was partly offset by the UK bank levy incurred in 2021.

Commercial Banking

CMB performed well in 2021 as we continued to implement our strategy to focus on serving our international customers.

Adjusted profit before tax was GBP490m, up by GBP339m compared with 2020. This was mainly driven by lower ECL and lower operating expenses, partly offset by lower revenue.

Revenue decreased by GBP38m or 3% compared with 2020. This was primarily in Credit and Lending due to lower customer balances reflecting actions taken to reduce RWAs as part of transformation. Revenue also decreased in GLCM driven by the lower interest rate environment despite growth in average deposit balances. This was partly offset by an increase in revenue allocated from Markets Treasury.

ECL net credit of GBP7m compared with a net charge of GBP322m in 2020. The net credit in 2021 largely reflected releases of stage 1 and stage 2 allowances reflecting the improved economic outlook. In 2020, there was significant build-up of charges resulting from the deterioration in the economic situation driven by the Covid-19 outbreak. In addition, stage 3 charges were lower compared with 2020.

Operating expenses decreased by GBP47m or 7%, mainly driven by a reduction in staff costs resulting from transformation initiatives. There were also lower corporate real estate costs due to lower depreciation as certain assets have been fully written down.

Wealth and Personal Banking ('WPB')

Adjusted profit before tax of GBP323m, up GBP456m compared with 2020. This was primarily due to higher revenue, lower operating expenses and lower ECL.

Revenue increased by GBP241m or 19%, mainly in insurance manufacturing in France and in the UK, largely from positive market impacts, notably on PVIF, driven by favourable equity market performance and higher interest rate yields on insurance contracts. This partly offset by lower revenue in Retail in France and in the Channel Islands and Isle of Man, mainly from deposits due to the low interest rate environment, despite growth in average balances.

ECL net credit of GBP23m compared with a net charge of GBP39m in 2020. This mainly reflected an improvement in the economic outlook from 2020.

Operating expenses decreased by GBP152m or 23%. This was driven by the non-recurrence of an impairment of real estate assets in France in 2020. In addition, there were lower technology costs and lower corporate real estate costs due to lower depreciation as certain assets have been fully written down.

Corporate Centre

Adjusted profit before tax of GBP96m compared with a loss before tax of GBP227m in 2020. This was mainly driven by a profit in associates and joint ventures compared with a loss in 2020, lower operating expenses and higher revenue.

Revenue was higher by GBP104m, primarily driven by gains on portfolio disposals in Legacy Credit compared with losses in 2020. The increase was also driven by a fair-value gain from a long-standing investment in a Germany-based brokerage company.

ECL net charge of GBP2m in 2021 compared with a net release of GBP5m in 2020, mainly driven by losses in Legacy Credit following disposals.

Operating expenses decreased by GBP22m or 26%, largely driven by lower intercompany recharges from other entities in the Group, with an offsetting decrease in revenue.

Shares of profit/(loss) in associates and joint ventures was a profit of GBP191m, of which GBP93m was due to a true-up of prior year valuations in the underlying investments of an associate. This compared with a loss of GBP(1)m in 2020.

 
Dividends 
 

The consolidated reported profit for the year attributable to the shareholders of the bank was GBP1,041m.

No dividend in respect of 2021 was declared on the ordinary share capital during the year.

Further information about the results is given in the consolidated income statement on page 108.

 
Review of business position 
 
 
Summary consolidated balance sheet at 31 Dec 
                                                                                   2021                       2020 
                                                                                   GBPm                       GBPm 
-------------------------------------------------------------  ------------------------  ------------------------- 
Total assets                                                                    596,611                    681,150 
-------------------------------------------------------------  ------------------------  ------------------------- 
 
  *    cash and balances at central banks                                       108,482                     85,092 
------------------------------------------------------------- 
 
  *    trading assets                                                            83,706                     86,976 
------------------------------------------------------------- 
 
  *    financial assets designated and otherwise mandatorily 
       measured at fair value through profit or loss                             18,649                     16,220 
------------------------------------------------------------- 
 
  *    derivatives                                                              141,221                    201,210 
------------------------------------------------------------- 
 
  *    loans and advances to banks                                               10,784                     12,646 
------------------------------------------------------------- 
 
  *    loans and advances to customers                                           91,177                    101,491 
------------------------------------------------------------- 
 
  *    reverse repurchase agreements - non-trading                               54,448                     67,577 
------------------------------------------------------------- 
 
  *    financial investments                                                     41,300                     51,826 
------------------------------------------------------------- 
 
  *    other assets                                                              46,844                     58,112 
------------------------------------------------------------- 
Total liabilities                                                               572,896                    657,301 
-------------------------------------------------------------  ------------------------  ------------------------- 
 
  *    deposits by banks                                                         32,188                     34,305 
------------------------------------------------------------- 
 
  *    customer accounts                                                        205,241                    195,184 
------------------------------------------------------------- 
 
  *    repurchase agreements - non-trading                                       27,259                     34,903 
------------------------------------------------------------- 
 
  *    trading liabilities                                                       46,433                     44,229 
------------------------------------------------------------- 
 
  *    financial liabilities designated at fair value                            33,608                     40,792 
------------------------------------------------------------- 
 
  *    derivatives                                                              139,368                    199,232 
------------------------------------------------------------- 
 
  *    debt securities in issue                                                   9,428                     17,371 
------------------------------------------------------------- 
 
  *    liabilities under insurance contracts                                     22,264                     22,816 
------------------------------------------------------------- 
 
  *    other liabilities                                                         57,107                     68,469 
------------------------------------------------------------- 
Total equity                                                                     23,715                     23,849 
-------------------------------------------------------------  ------------------------  ------------------------- 
Total shareholders' equity                                                       23,584                     23,666 
-------------------------------------------------------------  ------------------------  ------------------------- 
Non-controlling interests                                                           131                        183 
-------------------------------------------------------------  ------------------------  ------------------------- 
 

Total reported assets were 12.4% lower than at 31 December 2020. The group maintained a strong and liquid balance sheet with the ratio of customer advances to customer accounts decreasing to 44.4% from 52.0% as at 31 December 2020 driven by ongoing loan book optimisation efforts.

Assets

Cash and balances at central banks increased by 27.5% as a result of increased customer deposits and decreased reverse repurchase agreements and advances to customers positions.

Trading assets and financial assets designated at fair value slightly reduced due to changes in business and product mix during the year.

Derivative assets decreased by 29.8% due to a combination of market movement and trades compression and novation.

Non-trading reverse repurchase agreements decreased by 19.4% primarily due to changes in market conditions.

Financial investments decreased by 20.3% as a result of optimisation strategy.

Liabilities

Customer accounts increased by 5.2%, which is consistent with our funding strategy to grow customer deposits and increase

stable funding.

Total of trading liabilities and financial liabilities designated at fair value balances has decreased by 5.9%.

Debt securities in issue decreased by 45.7% in line with the funding strategy.

Non-trading repurchase agreements decreased by 21.9% as a result of market activities.

Derivative liabilities decreased by 30.0%. This is in line with derivative assets as the underlying risk is broadly matched.

Equity

Total shareholder's equity remained broadly unchanged as compared to 2020.

 
Net interest margin 
 

Net interest margin is calculated by dividing net interest income as reported in the income statement by the average balance of

interest-earning assets. Average balances are based on daily averages of the group's activities.

 
Net interest income 
                                  ------------------  -------------------- 
                                                2021                  2020 
                                                GBPm                  GBPm 
--------------------------------  ------------------  -------------------- 
Interest income                                3,149                 4,086 
--------------------------------  ------------------  -------------------- 
Interest expense                             (1,395)               (2,188) 
--------------------------------  ------------------  -------------------- 
Net interest income                            1,754                 1,898 
--------------------------------  ------------------  -------------------- 
Average interest-earning assets              354,324               369,617 
--------------------------------  ------------------  -------------------- 
                                                   %% 
--------------------------------  ------------------ ------------------- 
Gross interest yield(1)                         0.51                  0.74 
--------------------------------  ------------------  -------------------- 
Less: gross interest payable(1)               (0.01)                (0.27) 
--------------------------------  ------------------  -------------------- 
Net interest spread(2)                          0.50                  0.47 
--------------------------------  ------------------  -------------------- 
Net interest margin(3)                          0.50                  0.51 
--------------------------------  ------------------  -------------------- 
 

1 Gross interest yield is the average annualised interest rate earned on average interest-earning assets ('AIEA'). Gross interest payable is the average annualised interest cost as a percentage of average interest-bearing liabilities.

2 Net interest spread is the difference between the average annualised interest rate earned on AIEA, net of amortised premiums and loan fees, and the average annualised interest rate payable on average interest-bearing liabilities.

   3   Net interest margin is net interest income expressed as an annualised percentage of AIEA. 
 
Summary of interest income by asset type 
                                          2021                                                 2020 
                   --------------------------------------------------  ----------------------------------------------------- 
                            Average                Interest                       Average                 Interest 
                            balance                  income  Yield(1)             balance                   income  Yield(1) 
                               GBPm                    GBPm         %                GBPm                     GBPm         % 
Short term funds 
 and loans and 
 advances to 
 banks                      119,025                   (221)    (0.19)              90,841                    (113)    (0.12) 
-----------------  ----------------  ----------------------  --------  ------------------  -----------------------  -------- 
Loans and 
 advances to 
 customers                   99,151                   1,585      1.60             116,518                    2,058      1.77 
-----------------  ----------------  ----------------------  --------  ------------------  -----------------------  -------- 
Reverse 
 repurchase 
 agreements - 
 non-trading                 57,630                   (132)    (0.23)              68,573                       22      0.03 
-----------------  ----------------  ----------------------  --------  ------------------  -----------------------  -------- 
Financial 
 investments                 45,142                     497      1.10              51,335                      652      1.27 
-----------------  ----------------  ----------------------  --------  ------------------  -----------------------  -------- 
Other 
 interest-earning 
 assets                      33,376                      67      0.20              42,350                      118      0.28 
-----------------  ----------------  ----------------------  --------  ------------------  -----------------------  -------- 
Total 
 interest-earning 
 assets                     354,324                   1,796      0.51             369,617                    2,737      0.74 
-----------------  ----------------  ----------------------  --------  ------------------  -----------------------  -------- 
 

1 Interest yield calculations include negative interest on assets recognised as interest expense in the income statement.

 
Summary of interest expense by type of liability and equity 
                                         2021                                                 2020 
                   -------------------------------------------------  ---------------------------------------------------- 
                            Average                Interest                      Average                 Interest 
                            balance                 expense  Cost(1)             balance                  expense  Cost(1) 
                               GBPm                    GBPm        %                GBPm                     GBPm        % 
Deposits by banks            32,891                   (186)   (0.57)              28,812                     (60)   (0.21) 
Customer accounts           150,048                      95     0.06             143,807                      321     0.22 
-----------------  ----------------  ----------------------  -------  ------------------  -----------------------  ------- 
Repurchase 
 agreements - 
 non-trading                 32,916                   (192)   (0.58)              38,829                    (129)   (0.33) 
-----------------  ----------------  ----------------------  -------  ------------------  -----------------------  ------- 
Debt securities 
 in issue - 
 non-trading                 38,727                     258     0.67              52,781                      546     1.03 
-----------------  ----------------  ----------------------  -------  ------------------  -----------------------  ------- 
Other 
 interest-bearing 
 liabilities                 36,811                      68     0.18              47,384                      160     0.34 
-----------------  ----------------  ----------------------  -------  ------------------  -----------------------  ------- 
Total 
 interest-bearing 
 liabilities                291,393                      43     0.01             311,613                      838     0.27 
-----------------  ----------------  ----------------------  -------  ------------------  -----------------------  ------- 
 

1 Interest payable calculations include negative interest on liabilities recognised as interest income in the income statement.

 
Risk overview 
 

The group continuously identifies and monitors risks. This process, which is informed by its risk factors and the results of its stress testing programme, gives rise to the classification of certain financial and non-financial risks. Changes in the assessment of these risks may result in adjustments to the group's business strategy and, potentially, its risk appetite.

Our banking risks include credit risk, treasury risk, market risk, resilience risk, regulatory compliance risk, financial crime and fraud risk and model risk. We also incur insurance risk. In addition to these banking risks, we have identified top and emerging risks with the potential to have a material impact on our financial results, or reputation and the sustainability of our long-term business model.

The exposure to our risks and risk management of these are explained in more detail in the Risk section of the Report of the Directors on pages 21 to 87.

During 2021, a number of changes to our top and emerging risks have been made, to reflect the revised assessment of their effect on the group. Some risks were removed towards the end of 2021 as current concerns in these areas were considered as having been absorbed effectively into business as usual risk management practices. These risks were the UK's exit from the EU, market illiquidity and Covid-19. Covid-19 has been maintained as an Area of Special Interest reflecting the continued impact of the pandemic on our operations in 2021.

Environmental, social and governance also replaced Climate-related risks to cover the wider scope of climate, nature and human rights risks.

 
 
Externally driven 
Geopolitical       p  We continually assess the impact of geopolitical events, 
 risk                  including the ongoing impacts of the Covid-19 pandemic, on 
                       our businesses and exposures across the group, and take steps 
                       to mitigate them, where required and possible, to help ensure 
                       we remain within our risk appetite. The relationship between 
                       the UK and the EU may come under more severe strain in 2022 
                       over multiple disputes, most notably the Northern Ireland 
                       Protocol and possible triggering of Article 16 that could 
                       have potential repercussions on the terms of trade between 
                       the UK and the EU. We will continue to work with regulators, 
                       governments and our customers to manage the risks created 
                       by the UK's exit from the EU as they arise, particularly 
                       across those industry sectors most impacted. In addition 
                       with tensions continuing to rise between Russia and Ukraine, 
                       we will continue to monitor the development of this situation 
                       and any potential implications for the group. 
-----------------     ------------------------------------------------------------------ 
Cyber threat       u  We protect the group and our customers by strengthening our 
 and unauthorised      cyber defences, helping us to execute our business priorities 
 access                safely and keep our customers' information secure. We employ 
 to systems            a defence in depth approach to cyber security and continue 
                       to focus on controls to prevent, detect and mitigate the 
                       impacts of persistent and increasingly advanced cyber threats 
                       with a specific emphasis on vulnerability management, malware 
                       defences, protections against unauthorised access and third-party 
                       risk. We closely monitor the continued dependency on widespread 
                       remote working and online facilities. 
-----------------     ------------------------------------------------------------------ 
Regulatory         u  We proactively monitor for regulatory developments to ensure 
 focus on              they are interpreted and implemented effectively and in a 
 conduct               timely way. We engage with regulators, policy makers and 
 of business           standard setters as appropriate, to help make a positive 
                       contribution to the evolving regulatory landscape. We also 
                       track closely the key themes currently driving the regulatory 
                       compliance agenda, which include: consumer protection and 
                       customer vulnerability; the impact of digital services and 
                       innovation; Ibor transition; regulatory reporting obligations; 
                       mitigating the risk of inappropriate market conduct; and 
                       environmental, social and governance ('ESG') matters, with 
                       a particular focus on climate change, diversity and inclusion 
                       considerations and enhancements to ESG disclosure and reporting 
                       obligations. 
-----------------     ------------------------------------------------------------------ 
Financial          u  We continued to support our customers as the Bank's financial 
 crime and             crime landscape evolved due to the Covid-19 pandemic and 
 fraud risk            as broad geopolitical, socioeconomic and technological shifts 
                       happened across our markets. We continued to make improvements 
                       to our financial crime controls as emerging risks were identified 
                       and to invest in advanced analytics and artificial intelligence 
                       as key elements of our next generation of tools to fight 
                       financial crime. 
-----------------     ------------------------------------------------------------------ 
Ibor transition    u  We remain focused on completing the system and product updates 
                       to support the transition of demising Libor benchmarks, in 
                       particular US dollar Libor. We continue to support the transition 
                       of all legacy contracts referencing demised and demising 
                       Ibor benchmarks, including from any sterling or Japanese 
                       yen contracts using 'synthetic' Libor. Throughout 2022 there 
                       will be an increasing focus on customer engagement for US 
                       dollar Libor related transition activities. 
-----------------     ------------------------------------------------------------------ 
Environmental,     p  We continue to develop our approach to managing ESG risk, 
 social                noting that the risk has increased owing to the pace and 
 and governance        volume of regulatory developments globally, with the focus 
                       on formalising climate risk management, enhanced disclosures, 
                       and integration of other ESG risks such as nature-related 
                       risks and human rights. Some stakeholders are also placing 
                       more emphasis on financial institutions' actions and investment 
                       decisions in respect of ESG. 
-----------------     ------------------------------------------------------------------ 
Internally driven 
---------------------------------------------------------------------------------------- 
People             p  We monitor workforce capacity and capability requirements 
 risk                  in line with our published growth strategy. We have put in 
                       place measures to support our people to work safely during 
                       the Covid-19 pandemic, and to integrate them back into the 
                       workplace as government restrictions ease. We monitor people 
                       risks that may arise due to business transformation to help 
                       sensitively manage redundancies and support impacted employees. 
                       People Risk is heightened as a result of the ongoing pandemic 
                       conditions, including long periods of working from home, 
                       and impacts from our transformation programme. This has affected 
                       our staff's resilience, wellbeing and level of engagement 
                       over time, with increased attrition seen in some areas of 
                       our business. 
-----------------     ------------------------------------------------------------------ 
IT systems         u  We continue to monitor and improve our IT systems and network 
 infrastructure        resilience, both on our premises and on the Cloud to minimise 
 and resilience        service disruption and improve customer experience. To support 
                       the business strategy, we strengthened our end to end management, 
                       build and deployment controls and system monitoring capabilities. 
                       We continue to seek to reduce the complexity of our technology 
                       estate and consolidate our core banking systems onto a single 
                       strategic platform. 
-----------------     ------------------------------------------------------------------ 
 
 
 
Internally driven 
Execution         p  We monitored and managed our change execution risk, including 
 risk                 capacity and resources to meet the increased delivery demand 
                      across both strategic transformation projects, regulatory 
                      deliverables and remediation activities throughout 2021. 
                      Our transformation programme continues to oversee all initiatives 
                      mobilised to deliver the commitments made to restructure 
                      the business and reduce costs by the end of 2022. Execution 
                      risk is heightened by the inter-dependencies between projects 
                      within our transformation programme, which are primarily 
                      centred on France and Germany. A number of these initiatives 
                      impact our colleagues and are supported by increased levels 
                      of investment in technology. We are working to strengthen 
                      our change management practices to deliver sustainable change 
                      efficiently and safely, aligned to a new Group change framework 
                      launched during the first half of 2021. 
----------------     ------------------------------------------------------------------ 
Model risk        u  We continue to strengthen our oversight of models. Our model 
                      risk policy is fully embedded, including updated controls 
                      around the monitoring and use of models. New model risk appetite 
                      measures have been rolled out which are more forward looking 
                      and will help our businesses and functions manage model risk 
                      more effectively. Redevelopment of capital models to reflect 
                      the evolving regulatory requirements are also either in progress 
                      or pending regulatory approval for implementation. 
----------------     ------------------------------------------------------------------ 
Data management   u  We protect our customers and organisation by making focused 
                      investments in capabilities that manage data risk. We focus 
                      on controls that manage data governance, usage, integrity, 
                      privacy and retention. During 2021, we refreshed our data 
                      strategy and continued to improve our approach to data risk 
                      management and reporting. 
----------------     ------------------------------------------------------------------ 
Third party       u  We continually enhance our third-party risk management framework 
 risk management      as our supply chain evolves, and to stay aligned to the latest 
                      regulatory expectations. We closely monitor for Covid-19-related 
                      impacts on the delivery of services to the group, with businesses 
                      and functions taking appropriate action where needed. 
----------------     ------------------------------------------------------------------ 
 
 
p  Risk has heightened during 2021 
u  Risk remains at the same level 
    as 2020 
 
 
On behalf of the Board 
Dave Watts, Director 
21 February 2022 
Registered number 
 00014259 
 
 
Risk 
                                     Page 
Our approach to risk                   22 
-----------------------------------  ---- 
Our risk appetite                      22 
-----------------------------------  ---- 
Risk management                        24 
-----------------------------------  ---- 
Key developments and risk profile      24 
-----------------------------------  ---- 
Top and emerging risks                 24 
-----------------------------------  ---- 
Externally driven                      25 
-----------------------------------  ---- 
Internally driven                      28 
-----------------------------------  ---- 
Areas of special interest              30 
Risks related to Covid-19              30 
-----------------------------------  ---- 
Climate-related risks                  30 
-----------------------------------  ---- 
Our material banking and insurance 
 risks                                 32 
-----------------------------------  ---- 
Credit risk                            34 
-----------------------------------  ---- 
Treasury risk                          73 
-----------------------------------  ---- 
Capital risk in 2021                   77 
-----------------------------------  ---- 
Market risk                            81 
-----------------------------------  ---- 
Resilience risk                        84 
-----------------------------------  ---- 
Regulatory compliance risk             85 
-----------------------------------  ---- 
Financial crime risk                   85 
-----------------------------------  ---- 
Model risk                             87 
-----------------------------------  ---- 
Insurance manufacturing operations 
 risk                                  87 
-----------------------------------  ---- 
 
 
Our approach to risk 
 
 
Our risk appetite 
 

We recognise the importance of a strong culture, which refers to our shared attitudes, values and standards that shape behaviours related to risk awareness, risk taking and risk management. All our people are responsible for the management of risk, with the ultimate accountability residing with the Board.

We seek to build our business for the long term by balancing social, environmental and economic considerations in the decisions we make. Our strategic priorities are underpinned by our endeavour to operate in a sustainable way. This helps us to carry out our social responsibility and manage the risk profile of the business. We are committed to managing and mitigating climate-related risks, both physical and transition, and continue to incorporate consideration of these into how we manage and oversee risks internally and with our customers.

The following principles guide the group's overarching appetite for risk and determine how our businesses and risks are managed.

Financial position

   --    Strong capital position, defined by regulatory and internal ratios. 
   --    Liquidity and funding management for each entity on a stand-alone basis. 

Operating model

-- Ambition to generate returns in line with our risk appetite and strong risk management capability.

   --    Ambition to deliver sustainable earnings and appropriate returns for shareholders. 

Business practice

-- Zero tolerance for knowingly engaging in any business, activity or association where foreseeable reputational risk or damage has not been considered and/or mitigated.

-- No appetite for deliberately or knowingly causing detriment to consumers arising from our products and services or incurring a breach of the letter or spirit of regulatory requirements.

   --    No appetite for inappropriate market conduct by a member of staff or by any group business. 

Enterprise-wide application

Our risk appetite encapsulates consideration of financial and non-financial risks and is expressed in both quantitative and qualitative terms. It is applied at the global business level, at the group level and to material European entities.

Our risk management framework

An established risk governance framework and ownership structure ensures oversight of, and accountability for, the effective management of risk within the group. HSBC's Risk Management Framework ('RMF') fosters the continuous monitoring of the risk environment and an integrated evaluation of risks and their interactions. Integral to the RMF are risk appetite, stress testing and the identification of emerging risks.

The bank's Risk Committee focuses on risk governance and provides a forward-looking view of risks and their mitigation. The Risk Committee is a committee of the Board and has responsibility for oversight and advice to the Board on, amongst other things, the bank's risk appetite, tolerance and strategy, systems of risk management, internal control and compliance. Additionally, members of the Risk Committee attend meetings of the Chairman's Nominations and Remuneration Committee at which the alignment of the reward structures to risk appetite is considered.

In carrying out its responsibilities, the Risk Committee is closely supported by the Chief Risk Officer, the Chief Financial Officer, the Head of Internal Audit and the Head of Compliance, together with other business functions on risks within their respective areas of responsibility.

Responsibility for managing both financial and non-financial risk lies with our people. They are required to manage the risks of the business and operational activities for which they are responsible. We maintain oversight of our risks through our various specialist Risk Stewards, as well as the accountability held by the Chief Risk Officer. Non-financial risk includes some of the most material risks HSBC faces, such as cyber-attacks, poor customer outcomes and loss of data. Actively managing non-financial risks is crucial to serving our customers effectively and having a positive impact on society. During 2021 we continued to strengthen the control environment and our approach to the management of non-financial risks, as is broadly set out in our risk management framework. The management of non-financial risk focuses on governance and risk appetite, providing a single view of the non-financial risks that matter most, and associated controls. It incorporates a risk management system designed to enable the active management of non-financial risk. Our ongoing focus is on simplifying our approach to non-financial risk management, while driving more effective oversight and better end-to-end identification and management of non-financial risks. This is overseen by the Operational and Resilience Risk function, headed by the Group Head of Operational and Resilience Risk.

Three lines of defence

To create a robust control environment to manage risks, we use an activity-based three lines of defence model, whereby the activity a member of staff undertakes drives which line they reside within. This model delineates management accountabilities and responsibilities for risk management and the control environment.

The model underpins our approach to risk management by clarifying responsibility, encouraging collaboration and enabling efficient coordination of risk and control activities. The three lines are summarised below:

-- The first line of defence owns the risks and is responsible for identifying, recording, reporting and managing them, and ensuring that the right controls and assessments are in place to mitigate them.

-- The second line of defence challenges the first line of defence on effective risk management, and provides advice and guidance in relation to the risk.

-- The third line of defence is our Internal Audit function, which provides independent assurance that the group's risk management approach and processes are designed and operating effectively.

Risk appetite

We formally articulate our risk appetite through our risk appetite statement ('RAS'), which is approved by the Board on the recommendation of the Risk Committee. Setting out our risk appetite ensures that planned business activities provide an appropriate balance of return for the risk we are taking, and that we agree a suitable level of risk for our strategy. In this way, risk appetite informs our financial planning process and helps senior management to allocate capital to business activities, services and products.

The RAS consists of qualitative statements and quantitative metrics, covering financial and non-financial risks. It is fundamental to the development of business line strategies, strategic and business planning and senior management balanced scorecards. Performance against the RAS is reported to the Risk Management Meeting ('RMM') so that any actual performance that falls outside the approved risk appetite is discussed and appropriate mitigating actions are determined. This reporting allows risks to be promptly identified and mitigated, and informs risk-adjusted remuneration to drive a strong risk culture.

.

 
Risk management 
 

As a provider of banking and financial services, the group actively manages risk as a core part of its day-to-day activities. It continues to maintain a strong liquidity position and is well positioned for the evolving regulatory landscape.

Stress testing

Stress testing is an important tool that is used by banks, as part of their internal risk management, and regulators to assess vulnerabilities in individual banks and/or the financial banking sector under hypothetical adverse scenarios. The results of stress testing are used to assess banks' resilience to a range of adverse shocks and to assess their capital adequacy.

HSBC Bank plc is subject to regulatory stress testing in several jurisdictions. These requirements are increasing in frequency and granularity. They include the programmes of the Bank of England ('BoE'), Prudential Regulation Authority ('PRA') and the European Banking Authority ('EBA'). Assessment by regulators is on both a quantitative and qualitative basis, the latter focusing on our portfolio quality, data provision, stress testing capability and capital planning processes.

A number of internal macroeconomic and event-driven scenarios specific to the European region were considered and reported to senior management during the course of the year. The selection of stress scenarios is based upon the output of our top and emerging risks identified and our risk appetite. The results help the Board and senior management to set our risk appetite and confirm the strength of our strategic and financial plans. Our risk appetite is set at a level that enables the group to withstand future stress impacts.

In 2021, the Group participated in the successful completion of the BoE solvency stress testing exercise. The Solvency Stress Test Scenario depicts a synchronised, global, double-dip recession in 2021, driven by a continuation and intensification of economic and financial shocks experienced in 2020 as a result of the Covid-19 pandemic. Unemployment rises sharply in the stress, with certain sectors such as hospitality, leisure, construction and transport more affected than others.

Traded risk shocks are consistent with the macro-economic scenario. The global stress causes financial market participants' perceptions of risk to increase, and their risk appetite to diminish. The traded risk shocks are lower than those included in the 2019 exercise. This is, in part, because of a smaller rise in risk premia in the stress scenario given an expectation from market participants

that markets remain functional despite the broader macroeconomic stress.

The BoE published the results of the 2021 Solvency Stress Test in December 2021, confirming that these tests did not reveal any capital inadequacies for the HSBC Group. In 2021, the Group participated also in the Climate Biennial Exploratory Scenario ('CBES') exercise of BoE.

The CBES objective was to test the resilience of the UK financial system to the physical and transition risks associated with different climate pathways. The BoE has indicated that CBES was a learning exercise for both participating banks and the BoE. CBES will not be used to set capital requirements but to understand the collective impact on the wider economy and also explore vulnerabilities of current business models to future climate policy pathways and how the Group is expected to adjust it's business models in response to these climate change impacts.

 
Key developments and risk profile 
 

Key developments in 2021

We continued to actively manage the risks resulting from the Covid-19 pandemic and its impacts on our customers and operations during 2021, as well as other key risks described in this section. In addition, we enhanced our risk management in the following areas:

-- We streamlined the articulation of our risk appetite framework, providing further clarity on how risk appetite interacts with strategic planning and recovery planning processes.

-- We continued to simplify our approach to non-financial risk management, with the implementation of more effective oversight tools and techniques to improve end-to-end identification and management of these risks.

-- We accelerated the transformation of our approach to managing financial risks across the businesses and risk functions, including initiatives to enhance portfolio monitoring and analytics, credit risk, traded risk and treasury risk management, as well as the models used to manage financial risks.

-- We are progressing with a comprehensive regulatory reporting programme to strengthen our processes, improve consistency, and enhance controls.

-- We continued to enhance our approach to portfolio and concentration risk management, through clearly defined roles and responsibilities, and improving our data and management information reporting capabilities.

-- We continued the development of our climate risk management capabilities. Our climate risk programme will shape our approach to climate risk across four key pillars: governance and risk appetite; risk management; stress testing; and disclosures. We enhanced our risk appetite statement with quantitative climate risk metrics.

-- We continued to improve the effectiveness of our financial crime controls with a targeted update of our fraud controls. We refreshed our financial crime and fraud policies, ensuring they remained up to date and addressed changing and emerging risks, and we continued to meet our regulatory obligations.

-- We introduced enhanced governance and oversight around model adjustments and related processes for IFRS 9 models.

--

 
Top and emerging risks 
 

Top and emerging risks are those that may impact on the financial results, reputation or business model of the bank. If these risks were to occur, they could have a material effect on the group. The exposure to these risks and our risk management approach are explained in more detail below.

Externally driven

Geopolitical risk

Our operations and portfolios are exposed to risks associated with political instability, civil unrest and military conflict, which could lead to disruption of our operations, physical risk to our staff and/ or physical damage to our assets.

We will increasingly need to consider potential regulatory, reputational and market risks arising from the evolving geopolitical landscape.

The Covid-19 pandemic brought supply chain issues into focus and has heightened geopolitical tensions, which could have potential ramifications for the group and our customers.

Tensions between Russia and the US and a number of European states have heightened significantly following the escalation of hostilities between Russia and Ukraine. While negotiations are ongoing to seek a resolution, a continuation of or any further deterioration to the situation could have significant geopolitical implications, including economic, social and political repercussions on the group and its customers. In addition, the US, the UK and the EU have threatened a significant expansion of sanctions and trade restrictions against Russia in the event of a Russian incursion into Ukraine, and Russian countermeasures are also possible.

Political disagreements between the UK and the EU, notably over the future operation of the Northern Ireland Protocol, has meant work on the creation of a framework for voluntary regulatory cooperation in financial services following the UK's withdrawal from the EU has stalled. While negotiations are continuing, it is unclear whether or when an agreement will be reached, and this has led to speculation that the UK may trigger Article 16 of the Protocol, which could suspend the operation of the Protocol in certain respects. Any decision to do so could be met with retaliatory action by the EU, complicating the terms of trade between the UK and the EU and potentially preventing progress in other areas such as financial services.

Mitigating actions

-- We closely monitor geopolitical and economic developments in key markets and sectors and undertake scenario analysis where appropriate. This helps us to take portfolio actions where necessary, including enhanced monitoring, amending our risk appetite and/or reducing limits and exposures.

-- We stress test portfolios of particular concern to identify sensitivity to loss under a range of scenarios, with management action being taken to rebalance exposures and manage risk appetite where necessary.

-- We regularly review key portfolios to help ensure that individual customer or portfolio risks are understood and our ability to manage the level of facilities offered through any downturn is appropriate.

-- We continue to monitor geopolitical tensions involving Russia and Ukraine and any potential impacts on the group and our customers.

-- We continue to monitor the UK's relationship with the EU, and assess the potential impact on our people, operations and portfolios.

-- We have taken steps, where necessary, to enhance physical security in those geographical areas deemed to be at high risk from terrorism and military conflicts.

Cyber threat and unauthorised access to systems

We continue to operate in a challenging cyber threat environment, which requires ongoing investment in business and technical controls to defend against these threats.

Key threats include unauthorised access to our data, advanced malware attacks, attacks on third-party suppliers and security vulnerabilities being exploited.

Mitigating actions

-- We continually evaluate threat levels for the most prevalent attack types and their potential outcomes. To further protect our business and our customers we strengthened our controls to reduce the likelihood and impact of advanced malware, data leakage, exposure through third parties and security vulnerabilities.

-- We continue to enhance our cybersecurity capabilities, including cloud security, identity and access management, metrics and data analytics, and third-party security reviews. An important part of our defence strategy is ensuring our people remain aware of cybersecurity issues and know how to report incidents.

-- We report and review cyber risk and control effectiveness regularly at executive and non-executive Board level. We also report it across our businesses and functions, to help ensure appropriate visibility and governance of the risk and mitigating actions.

-- We participate globally in several industry bodies and working groups to share information about tactics employed by cyber-crime groups and to collaborate in fighting, detecting and preventing cyber-attacks on financial organisations.

Regulatory focus on conduct of business

We keep abreast of the emerging regulatory compliance and conduct agenda, which currently includes, but is not limited to: ESG matters; operational resilience; how digital and technology changes, including payments, are impacting financial institutions; how we are ensuring good customer outcomes, including addressing customer vulnerabilities; regulatory reporting; and employee compliance. We monitor regulatory developments closely and engage with regulators, as appropriate, to help ensure new regulatory requirements are implemented effectively and in a timely way.

The competitive landscape in which we operate may be impacted by future regulatory changes and government intervention. In the UK, potential regulatory developments include any legislative changes resulting from a statutory review for ring-fencing, which has been undertaken by an independent panel appointed by HM Treasury. The panel has recommended several adjustments to the regime and HM Treasury is reviewing these recommendations. Legislative amendments may be proposed in due course.

Mitigating actions

-- We monitor for regulatory developments to understand the evolving regulatory landscape and respond with changes in a timely way.

-- We engage, wherever possible, with governments and regulators to make a positive contribution to regulations and ensure that new requirements are considered properly and can be implemented effectively. We hold regular meetings with relevant authorities to discuss strategic contingency plans, including those arising from geopolitical issues.

-- We launched our simplified conduct approach to align to our new purpose and values, in particular the value 'we take responsibility'.

Financial crime and fraud risk

Financial institutions remain under considerable regulatory scrutiny regarding their ability to prevent and detect financial crime. The financial crime threats we face have continued to evolve, often in tandem with broader geopolitical, socioeconomic and technological shifts in our markets, leading to challenges such as managing conflicting laws and approaches to legal and regulatory regimes. Financial crime risk evolved during the Covid-19 pandemic, notably with the manifestation of fraud risks linked to the economic slowdown and resulting deployment of government relief measures. The accelerated digitisation of financial services has fostered significant changes to the payments ecosystem, including a multiplicity of providers and new payment mechanisms, not all of which are subject to the same level of regulatory scrutiny or regulations as financial institutions.

This is presenting increasing challenges to the industry in terms of maintaining required levels of transparency, notably where institutions serve as intermediaries. Developments around digital assets and currencies, notably the role of stablecoins and central bank digital currencies, have continued at pace, with an increasing regulatory and enforcement focus on the financial crimes linked to these types of assets.

Expectations with respect to the intersection of ESG issues and financial crime as our organisation, customers and suppliers transition to net zero, are increasing, not least with respect to potential 'greenwashing'. Companies also face a heightened regulatory focus on both human rights issues and environmental crimes, from a financial crime perspective. We also continue to face increasing challenges presented by national data privacy requirements, which may affect our ability to manage financial crime risks holistically and effectively.

Mitigating actions

-- We are strengthening our fraud and surveillance controls, and investing in next generation capabilities to fight financial crime through the application of advanced analytics and artificial intelligence.

-- We are looking at the impact of a rapidly changing payments ecosystem to ensure our financial crime controls remain appropriate for changes in customer behaviour and gaps in regulatory coverage, including the development of procedures and controls to manage the risks associated with direct and indirect exposure to digital assets and currencies.

-- We are assessing our existing policies and control framework to ensure that developments in the ESG space are considered and the risks mitigated.

-- We work with jurisdictions and relevant international bodies to address data privacy challenges through international standards, guidance, and legislation to help enable effective management of financial crime risk.

-- We work closely with our regulators and engage in public-private partnerships, playing an active role in shaping the industry's financial crime controls for the future, notably with respect to the enhanced, and transparent, use of technology.

Ibor transition

Interbank offered rates ('Ibors') have historically been used extensively to set interest rates on different types of financial transactions and for valuation purposes, risk measurement and performance benchmarking.

Following the UK's Financial Conduct Authority ('FCA') announcement in July 2017 that it would no longer continue to persuade or require panel banks to submit rates for the London interbank offered rate ('Libor') after 2021, we have been actively working to transition legacy contracts from Ibors to products linked to near risk-free replacement rates ('RFRs') or alternative reference rates. In March 2021, in accordance with the 2017 FCA announcement, ICE Benchmark Administration Limited ('IBA') announced that it would cease publication of 24 of the 35 main Libor currency interest rate benchmark settings from the end of 2021, and that the most widely used US dollar Libor settings would cease from 30 June 2023. The FCA subsequently used its regulatory powers to compel IBA to publish the remaining six sterling and Japanese yen settings, from 1 January 2022, under an amended methodology, commonly known as 'synthetic' Libor. As a result, our focus during 2021 was on the transition of legacy contracts referencing the Euro Overnight Index average ('Eonia') and the Libor settings that demised from the end of 2021, including those settings subsequently being published on a 'synthetic' basis.

During 2021, we continued the development of IT and RFR product capabilities, implemented supporting operational processes, and engaged with our clients to discuss options for the transition of their legacy contracts. The successful implementation of new processes and controls, as well as the transition of contracts away from Ibors, reduced the heightened financial and non-financial risks to which we were exposed. However, while all but exceptional Libor contract issuance ceased in 2021, or from the end of 2021 for US dollar Libor, we remain exposed to material risks. These include, from so-called 'tough legacy' contracts, that have not been able to be transition to a new rate and will use a 'synthetic' Libor or a contractual fallback rate, and from legacy contracts that reference US dollar Libor, which are expected to demise from June 2023.

Financial risks have been largely mitigated as a result of the implementation of model and pricing changes. However, differences in US dollar Libor and its replacement RFR, Secured Overnight Funding Rate ('SOFR'), create a basis risk in the trading book and banking book due to the asymmetric adoption of SOFR across assets, liabilities and products that we need to actively manage through appropriate financial hedging. Additionally, the comparatively limited use of SOFR for new RFR products to date and lack of alignment around conventions could potentially delay transition of some US dollar Libor contracts into 2023. This would compress the amount of time to transition these contracts, which could lead to heightened operational and conduct-related risk as a result.

Additional non-financial risks, including regulatory compliance risk, resilience risk, financial reporting risk, and legal risk also remain for 'tough legacy' contracts, and the US dollar legacy portfolio. These risks continue to be actively managed and mitigated with a focus on ensuring that fair outcomes for our clients are achieved.

These risks are present in different degrees across our product offering.

Transition of Legacy contracts

During 2021, we successfully transitioned over 90% of legacy Ibor lending contracts in sterling, Swiss franc, euro and Japanese yen Libor interest rates, as well as Eonia, directly or via appropriate fallback mechanisms. The majority of the remaining contracts will transition in advance of their next interest payment date, with only a small proportion of 'tough legacy' contracts remaining. We expect that out of approximately 1000 lending contracts there will be less than 20 'tough legacy' contracts, the majority of which will be transitioned to alternative rates during 2022. Our approach to transition 'tough legacy' and US dollar legacy Ibor contracts will differ by product and business area, but will be based on the lessons learned from the successful transition of contracts during 2021. We will continue to communicate with our clients and investors in a structured manner and be client led in the timing and nature of the transition.

For derivatives, approximately 99% of our sterling, Swiss franc, euro and Japanese yen Libor interest rate exposures at the end of 2021 had successfully transitioned directly or via appropriate fallback mechanisms, leaving a small number of 'tough legacy' contracts. There are expected to be less than 20 bilateral derivatives trades that remain 'tough legacy,' the majority of which are expected to mature or transition in 2022. We anticipate our 'tough legacy' and US dollar exposure will continue to reduce through 2022 as a result of contract maturities, and active transition. We will continue to look to actively reduce our US dollar exposure by transitioning trades ahead of the demise date of 30 June 2023, by working with our clients to determine their needs and how we transition their contracts. Additionally, we are working with market participants, including clearing houses, to ensure we are able to transition our cleared derivative contracts as the US dollar Libor benchmark demise date approaches.

For our loan book, approximately 85% of our reported exposure at the end of 2021 linked to sterling, Swiss franc, euro and Japanese yen Libor interest rate contracts that required no further client negotiation but remained drawn on Libor as they have yet to reach their next interest payment date. The majority of the remaining exposure linked to benchmarks that demised from the end of 2021 relates to contracts where discussions with our clients and other market participants, for syndicated transactions, have continued in early 2022, in advance of their next scheduled interest payment date, and this has led to further transitions being completed.

A small number of 'tough legacy' contracts, less than 20, that were unable to transition prior to their first interest payment date in 2022, are expected to use legislative reliefs, such as 'synthetic' Libor, or an alternative rate determined by the contractual fallback language and in the main will be transitioned during 2022. For the remaining demising Ibors, notably US dollar Libor, we have implemented new products and processes and updated our systems in readiness for transition. Global Banking, Commercial Banking and Global Private Banking have begun to engage with clients who have upcoming contract maturities with a view to refinancing using an appropriate replacement rate. Further communications and outreach to customers with US dollar Libor contracts with later maturities will occur in due course.

Where we hold bonds issued by other institutions, we have remained dependent on the issuer's agents to engage in the transition process, although analysis will be undertaken of the issuers in US dollar Libor bonds to reduce our exposure, as occurred through 2021.

The completion of an orderly transition from the remaining Ibors, notably US dollar Libor, continues to be our programme's key objective through 2022 and 2023, with the aim of putting systems and processes in place to help achieve this.

Mitigating actions

-- The global Ibor transition programme, which is overseen by the Group Chief Risk and Compliance Officer, will continue to deliver IT and operational processes to meet its objectives.

-- We carry out extensive training, communication and client engagement to facilitate appropriate selection of new rates and products.

   --    We have dedicated teams in place to support the transition. 

-- We actively transitioned legacy contracts and ceased new issuance of Libor-based contracts, other than those allowed under regulatory exemptions, with associated monitoring and controls.

-- We assess, monitor and dynamically manage risks arising from Ibor transition, and implement specific mitigating controls when required.

-- We continue to actively engage with regulatory and industry bodies to mitigate risks relating to 'tough legacy' contracts.

Financial instruments impacted by IBOR reforms

Interest Rate Benchmark Reform Phase 2, the amendments to IFRSs issued in August 2020, represents the second phase of the IASB's project on the effects of interest rate benchmark reform.

The amendments address issues affecting financial statements when changes are made to contractual cash flows and hedging relationships.

Under these amendments, changes made to a financial instrument measured at other than fair value through profit or loss that are economically equivalent and required by interest rate benchmark reform, do not result in the derecognition or a change in the carrying amount of the financial instrument. Instead they require the effective interest rate to be updated to reflect the change in the interest rate benchmark. In addition, hedge accounting will not be discontinued solely because of the replacement of the interest rate benchmark if the hedge meets other hedge accounting criteria.

(audited)

 
                                                         Financial instruments yet 
                                                        to transition to alternative 
                                                        benchmarks, by main benchmark 
                                 USD Libor                  GBP Libor                      EONIA                  Others(1) 
At 31 Dec 2021                        GBPm                       GBPm                       GBPm                       GBPm 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Non-derivative 
financial 
assets(2) 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Loans and 
 advances to 
 customers                           5,999                      2,562                          -                         26 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Financial 
 investments                         1,171                        140                          -                          - 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Others                                 693                        499                          -                          - 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Total 
 non-derivative 
 financial 
 assets                              7,863                      3,201                          -                         26 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Non-derivative 
financial 
liabilities 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Subordinated 
liabilities                          1,145                          -                          -                          - 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Others                                 479                        181                          -                          - 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Total 
 non-derivative 
 financial 
 liabilities                         1,624                        181                          -                          - 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Derivative 
notional 
contract amount 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Foreign 
 exchange                            8,288                      1,568                          -                      1,080 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Interest rate                    1,567,577                    215,377                      1,679                     76,059 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Others                                   -                          -                          -                          - 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
Total 
 derivative 
 notional 
 contract 
 amount                          1,575,865                    216,945                      1,679                     77,139 
---------------  -------------------------  -------------------------  -------------------------  ------------------------- 
 
 
At 31 Dec 2020 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Non-derivative 
financial 
assets(2) 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Loans and 
 advances to 
 customers                             7,782                      4,323                            1                          183 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Financial 
 investments                           1,187                        406                            -                            - 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Others                                 1,043                      1,033                            -                            1 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Total 
 non-derivative 
 financial 
 assets                               10,012                      5,762                            1                          184 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Non-derivative 
financial 
liabilities(2) 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Subordinated 
 liabilities                           1,135                        900                            -                            - 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Others                                   798                        510                            3                            1 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Total 
 non-derivative 
 financial 
 liabilities                           1,933                      1,410                            3                            1 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Derivative 
notional 
contract amount 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Foreign 
 exchange                              6,296                      2,768                            -                        8,148 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Interest rate                      1,694,279                    865,545                      196,515                      126,545 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Others                                     7                          -                            -                            - 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
Total 
 derivative 
 notional 
 contract 
 amount                            1,700,582                    868,313                      196,515                      134,693 
---------------  ---------------------------  -------------------------  ---------------------------  --------------------------- 
 

1 Comprises financial instruments referencing other significant demising benchmark rates (euro Libor, Swiss franc Libor, Japanese Yen Libor, SOR and THBFIX Sibor).

   2   Gross carrying amount excluding allowances for expected credit losses. 

3 The amounts in the above table do not represent amounts at risk as the steps to transition for certain trades have been completed.

The amounts in the above table relate to the group's main operating entities where we have material exposures impacted by Ibor reform, including in the United Kingdom, France and Germany. The amounts provide an indication of the extent of the group's exposure to the Ibor benchmarks that are due to be replaced. Amounts are in respect of financial instruments that:

-- contractually reference an interest rate benchmark that is planned to transition to an alternative benchmark;

-- have a contractual maturity date beyond the date by which the reference interest rate benchmark is expected to cease; and

   --    are recognised on the group's consolidated balance sheet. 

In March 2021, the administrator of Libor, IBA, announced that the publication date of most US dollar Libor tenors has been extended from 31 December 2021 to 30 June 2023. Publication of one-week and two-month tenors ceased after 31 December 2021. This change, together with the extended publication dates of Sibor, SOR and THBFIX, reduce the amounts presented at 31 December 2021 in the above table as some financial instruments included at 31 December 2020 will reach their contractual maturity date prior to the extended publication dates. Comparative data have not been re-presented.

Environmental, social and governance risk

We are subject to financial and non-financial risks associated with environmental, social and governance related matters ('ESG') which can impact us both directly and indirectly through our customers.

Climate-related risk increased over 2021, owing to the pace and volume of policy and regulatory changes regionally, particularly on climate risk management, stress testing and scenario analysis and disclosures. If we fail to meet regulatory expectations or requirements on climate risk management, this could have regulatory compliance and reputational impacts.

We face increased reputational, legal and regulatory risks as we make progress towards the HSBC Group's net zero ambition, as stakeholders are likely to place greater focus on our actions, disclosures and financing decisions related to this. We will face additional risks if we are perceived to mislead stakeholders regarding our climate strategy, the climate impact of a product or service, or regarding the commitments of our customers.

To track and report on our progress towards achieving our ambition, we rely on internal and external data, guided by certain industry standards. While emissions reporting has improved over time, data remains of limited quality and consistency. Methodologies we have used may evolve in line with market practice and regulation as well as due to developments in climate science. Any developments in data and methodologies could result in revisions, meaning that reported figures may not be reconcilable or comparable year-on-year. We may also have to re-evaluate our progress towards the HSBC Group's climate-related ambition in future and this could result in reputational, legal and regulatory risks.

Climate risk will also have an impact on model risk, as models play an important role in risk management and the financial reporting of climate-related risks. The uncertain impacts of climate change and data limitations, present challenges to creating reliable and accurate model outputs.

We could also face increased resilience; retail credit; and wholesale credit risks owing to the increase in frequency and severity of weather events and chronic shifts in weather patterns.

These risks could impact our own critical operations, resulting in customer detriment and operational losses for the group. Our customers' operations and assets could also be affected, reducing their ability to afford mortgage or loan repayments, leading to credit risk impacts for the firm.

There is increasing evidence that a number of nature-related risks beyond climate change - which include risks that can be represented more broadly by economic dependence on nature - can and will have significant economic impact. These risks arise when the provision of natural services - such as water availability, air quality, and soil quality - is compromised by overpopulation, urban development, natural habitat and ecosystem loss, and other environmental stresses beyond climate change. They can show themselves in various ways, including through macroeconomic, market, credit, reputational, legal and regulatory risks, for both the group and our customers.

Mitigating actions

-- We continue to deepen our understanding of the drivers of climate risk and managing our exposure to climate risk is a priority. Our dedicated Climate Risk Oversight Forums are responsible for shaping and overseeing our approach and providing support in managing climate risk in the region.

-- Our climate risk programme continues to accelerate the development of our climate risk management capabilities across four key pillars - governance and risk appetite, risk management, stress testing and scenario analysis and disclosures. We are also enhancing our approach to greenwashing risk.

-- In December 2021, the HSBC Group published its thermal coal phase-out policy committing to phase out the financing of coal-fired power and thermal coal mining in EU/OECD markets by the end of 2030, and globally by the end of 2040. The policy helps us chart the path to net zero and is a component of our approach towards managing the climate risk of our lending portfolio and wider banking activities.

-- We have started to incorporate the outcomes and insights from the Bank of England's Climate Biennial Exploratory Scenario into climate risk management, and are currently engaged in the 2022 ECB Climate Risk Stress Test.

   --    We have delivered climate risk training to our legal entity board and wider target audiences. 
   --    In 2021, we joined several industry working groups dedicated to helping us access and manage nature-related risks, such as the Taskforce on Nature-Related Financial Disclosure ('TNFD'). Our asset management business also published its biodiversity policy to publicly explain how our analysts address nature-related issues. 

-- We continue to engage with our customers, investors and regulators proactively on the management of climate risks. We also engage with initiatives actively, including the EU Taxonomy disclosures, Climate Financial Risk Forum, Equator Principles, Taskforce on Climate-related Financial Disclosures and CDP (formerly the Carbon Disclosure Project) to drive best practice for climate risk management.

For further details on ESG, see our ESG review on page 8 and for further details on our approach to climate risk management, see 'Areas of special interest' on page 28. For further details on ESG risk management see 'Financial crime and fraud risk on page 23.

Internally driven

People risk

Our success in delivering our strategic priorities and managing the regulatory environment proactively depends on the development and retention of our leadership and high-performing employees. The ability to continue to attract, develop and retain competent individuals in an employment market impacted by the Covid-19 pandemic is challenging particularly due to organisational restructuring. Changed working arrangements, local Covid-19 restrictions and health concerns during the pandemic also impact on employee mental health and well-being.

Mitigating actions

-- We have put in place measures to help support our people so they are able to work safely during the Covid-19 pandemic.

-- We promote a diverse and inclusive workforce and provide active support across a wide range of health and wellbeing activities. We continue to build our speak up culture through active campaigns.

-- We monitor people risks that have arisen due to organisational restructuring, helping to ensure we manage redundancies sensitively and support impacted employees.

-- Launch of the Future Skills Curriculum through HSBC University to help provide the critical skills that will enable employees and HSBC to be successful in the future.

-- We continue to develop succession plans for key management roles, with actions agreed and reviewed on a regular basis by the group's Executive Committee.

-- We have robust plans in place, driven by senior management, to mitigate the effect of external factors that may impact our employment practices. Political, legislative and regulatory challenges are closely monitored to minimise the impact on the attraction and retention of talent and key performers.

IT systems infrastructure and resilience

HSBC is committed to investing in the reliability and resilience of its IT systems and critical services. HSBC does so in order to protect its customers and ensure they do not receive disruption to services, which could result in reputational and regulatory damage.

The group's strategy includes simplification of our technology estate to reduce complexity and costs; this includes consolidation of our core banking systems onto a single strategic platform. The target state will leverage existing and known technology, and will be simpler and easier to maintain. However, as with any strategic transformation programme risks associated with implementation must be managed continuously.

Mitigating actions

-- We continue to invest in transforming how software solutions are developed, delivered and maintained, with a particular focus on providing high-quality, stable and secure services. As part of this, we are concentrating on improving system resilience and service continuity testing. We have enhanced the security features of our software development life cycle and improved our testing processes and tools.

-- During 2021, we have upgraded many of our IT systems, simplified our service provision and replaced older IT infrastructure and applications. These enhancements led to continued global improvements in service availability during 2021 for both our customers and employees.

-- We manage implementation risks arising from the simplification of our technology estate continuously via thorough oversight of these risks at all levels of the programme and reporting up to our Risk Committee.

Execution risk

In order to deliver our strategic objectives and meet mandatory regulatory requirements, it is important for the group to maintain a strong focus on execution risk. This requires robust management of significant resource-intensive and time-sensitive programmes. Risks arising from the magnitude and complexity of change may include regulatory censure, reputational damage or financial losses. Current major initiatives include managing the operational implications of the disposal of our French retail business, large transformation programmes including the simplification and integration of our IT Systems and other restructuring programmes across Europe.

Mitigating actions

-- Our prioritisation and governance processes for significant projects are monitored by the group's Executive Committee.

-- We continue to work to strengthen our change management practices to deliver sustainable change, increased adoption of Agile ways of working, and a more consistent standard of delivery. For HSBC Bank plc, this includes embedding of an improved Group-wide change framework released in the first half of 2021, which sets out the mandatory principles and standards to be adhered to when leading and delivering change.

Model risk

Model risk arises whenever business decision-making includes reliance on models. We use models in both financial and

non-financial contexts and in a range of business applications such as customer selection, product pricing, financial crime transaction monitoring, creditworthiness evaluation and financial reporting. Assessing model performance is a continuous undertaking. Models can need redevelopment as market conditions change. This was required following the outbreak of Covid-19 as some models used for estimating credit losses needed to be redeveloped due to the significant change to inputs including GDP, unemployment rates and housing prices; and the varying government support measures introduced.

Prior to the Covid-19 outbreak a key area of focus was improving and enhancing our model risk governance, and this activity continued throughout 2021. We prioritised the redevelopment and validation of internal ratings-based ('IRB') and internal models methods ('IMM') models, in relation to counterparty credit, as part of the IRB repair and Basel III programmes with a key focus on enhancing the quality of data used as model inputs.

Mitigating actions

-- We appointed model risk stewards for our key entities to support, oversee and guide the global businesses and functions on model risk management. The risk stewards provide close monitoring of changes in model behaviour, working closely with business and function model owners and sponsors.

-- We worked with the model owners of IRB models and traded risk models to increase our engagement on management of model risk with key regulators including the PRA and the ECB.

-- We embedded the model risk policy and model risk standards in all business and functions to enable a more risk-based approach to model risk management.

-- We made further enhancements to our control framework for models used in financial reporting processes to address the control weaknesses that emerged as a result of significant increases in model adjustments and overlays that were applied to compensate for the impact of Covid-19 on models and to introduce a requirement for the second line of defence to approve material models prior to use.

-- The model inventory system was enhanced to support the management of model risk for multiple applications of a single model.

-- We have submitted the first set of IRB models for regulatory approval in 2021. The redevelopment and validation of remaining IRB and IMM models for counterparty credit and our internal models approach ('IMA') for traded risk models is in progress. Models are expected to undergo PRA approval over the next 12 months.

Data management

We use a large number of systems and growing quantities of data to support our customers. Risk arises if data is incorrect, unavailable, misused, or if the privacy of our customers and colleagues is unprotected. Along with other banks and financial institutions, we need to meet external regulatory obligations and laws that cover data, such as the Basel Committee on Banking Supervisions 239 guidelines and the General Data Protection Regulation ('GDPR').

Mitigating actions

-- Through our global data management framework, we monitor proactively the quality, availability and security of data that supports our customers and internal processes. We resolve any identified data issues in a timely manner.

-- We have made improvements to our data policies and are implementing an updated control framework to enhance the end-to-end management of data risk by our businesses and functions.

-- We protect customer data via our data privacy framework, which establishes practices, design principles and guidelines that enable us to demonstrate compliance with data privacy laws and regulations.

-- We continue to modernise our data and analytics infrastructure through investments in Cloud technology, data visualisation, machine learning and artificial intelligence.

-- We educate our employees on data risk and data management and have delivered global mandatory training on the importance of protecting data and managing data appropriately.

T

Third Party Risk Management

We use third parties to provide a range of services, in common with other financial service providers. Risks arising from the use of third-party service providers and their supply chain may be less transparent. It is critical that we ensure we have appropriate risk management policies, processes and practices over the selection, governance and oversight of third parties and their supply chain, particularly for key activities that could affect our operational resilience. Any deficiency in the management of risks associated with our third parties could affect our ability to support our strategic approach and meet our customer and regulatory expectations.

Mitigating actions

-- We have enhanced our control framework for external supplier arrangements to ensure the risks associated with third-party arrangements are understood and managed effectively by our businesses and functions across the group.

-- We have applied the same control standards to intra-group arrangements as we have for external third-party arrangements to ensure we are managing them effectively.

-- We are implementing the changes required by our new third-party risk policy to comply with new regulations as defined by our regulators.

--

 
Areas of special interest 
 

Risks related to Covid-19

Despite the successful roll-out of vaccines across the world, the Covid-19 pandemic and its effect on the global economy have continued to impact our customers and organisation. The global vaccination roll-out in 2021 helped reduce the social and economic impact of the Covid-19 pandemic and high vaccination rates are enabling many countries across Europe in 2022 to ease Covid-19-related restrictions on activity and constraints on travel. However, the emergence of the Omicron variant in late 2021, demonstrated the continued risk new variants pose.

The pandemic necessitated governments to respond at unprecedented levels to protect public health, and to support local economies and livelihoods. The resulting government support measures and restrictions have created additional challenges, given the rapid pace of change and significant operational demands. Renewed outbreaks, particularly those resulting from the emergence of variants of the virus, emphasise the ongoing threat of Covid-19 and could result in further tightening of government restrictions. There remains a divergence in approach taken by countries to the level of restrictions on activity and travel. Such diverging approaches to future pandemic waves could prolong or worsen supply chain and international travel disruptions.

We continue to support our personal and business customers through market-specific measures initiated during the Covid-19 pandemic, and by supporting government schemes that focus on the parts of the economy most impacted by the pandemic. For further details of our customer relief programmes, see page 60.

The rapid introduction and varying nature of the government support schemes introduced throughout the Covid-19 pandemic has led to increased operational risks, including complex conduct considerations, increased reputational risk and increased risk of fraud. These risks are likely to be heightened further as and when those government support schemes are unwound. We are focused upon avoiding and mitigating any conduct risks that may arise from the implementation decisions we have had to make and also those that may be created if our customers find themselves in financial difficulties as a result of the impact of the Covid-19 pandemic.

The impact of the pandemic on the long-term prospects of businesses in the most vulnerable sectors of the economy - such as retail, hospitality and commercial real estate - remains uncertain and may lead to significant credit losses on specific exposures, which may not be fully captured in ECL estimates. In addition, in times of stress, fraudulent activity is often more prevalent, leading to potentially significant credit or operational losses.

As economic conditions improve, and government support measures come to an end, there is a risk that the outputs of IFRS 9 models may have a tendency to underestimate loan losses. To help mitigate this risk, model outputs and management adjustments are closely monitored and independently reviewed for reliability and appropriateness prior to inclusion in the financial results.

Despite the ongoing economic recovery, significant uncertainties remain in assessing the duration and impact of the Covid-19 pandemic, including whether any subsequent outbreaks result in a reimposition of government restrictions. There is a risk that economic activity remains below pre-pandemic levels for a prolonged period, increasing inequality across markets, and it will likely be some time before societies return to pre-pandemic levels of social interactions. As a result, there may still be a requirement for additional mitigating actions including further use of adjustments, overlays and model redevelopment.

Governments and central banks in major economies have deployed extensive measures to support their local populations. This is expected to reverse partially in 2022. Central banks in major markets are expected to raise interest rates, but such increases are expected to be gradual and monetary policy is expected to remain accommodative overall. Governments are also expected to reduce the level of fiscal support they offer households and businesses as the appetite for broad lockdowns and public health restrictions decreases. Government debt has risen in most advanced economies, and is expected to remain high into the medium term. High government debt burdens have raised fiscal vulnerabilities, increasing the sensitivity of debt service costs to interest rate increases and potentially reducing the fiscal space available to address future economic downturns. HSBC's Central scenario used to calculate impairment assumes that economic activity will continue to recover through 2022, surpassing peak pre-pandemic levels of GDP in our key markets. It is assumed that private sector growth accelerates, ensuring a strong recovery is sustained even as pandemic-related fiscal support is withdrawn. However, there is a high degree of uncertainty associated with economic forecasts in the current environment and there are significant risks to our Central scenario. The degree of uncertainty varies by our key markets, driven by country specific trends in the evolution of the pandemic, associated policy responses and ongoing impacts felt from the Trade and Cooperation Agreement in place between the UK and the EU from 1 January 2021. For further details of our Central and other scenarios, see 'Measurement uncertainty and sensitivity analysis of ECL estimates' on page 41.

We continue to monitor the situation closely, and given the novel and prolonged nature of the pandemic, additional mitigating actions may be required.

Climate-related risks

Climate change can have an impact across HSBC's risk taxonomy through both transition and physical channels.

Transition risk can arise from the move to a low-carbon economy, such as through policy, regulatory and technological changes.

Physical risk can arise through increasing frequency and severity of weather or other climatic events, such as flooding, or chronic changes in precipitation patterns, temperatures or sea levels.

These have the potential to cause both idiosyncratic and systemic risks, resulting in potential financial and non-financial impacts for the group. Financial impacts could materialise if transition and physical risks impact the ability of our customers to repay their loans. Non-financial impacts could materialise if our own assets or operations are impacted by extreme weather or chronic changes in weather patterns, or as a result of business decisions to achieve our climate ambition.

How climate risk can impact our customers

Climate change could impact our customers in two main ways. Firstly, customer business models may fail to align to a low-carbon economy, which could mean that new climate-related regulation, policy or technological changes would have a material impact on their business. Secondly, extreme weather events or chronic changes in weather patterns may damage our customers' assets and supply chain leaving them unable to operate their business or perhaps even live in their home.

One of the most valuable ways we can help our customers navigate the transition challenges and to become more resilient to the physical impacts of climate change is through financing and investment. To do this effectively, we must understand the risks they are facing.

The table below summarises the key categories of transition and physical risk, with examples of how our customers might be affected financially by climate change and the shift to a low-carbon economy.

 
 
Transition  Policy        Mandates on, and regulation 
             and legal     of, existing products 
                           and services 
                           Litigation from parties 
                           who have suffered from 
                           the effects of climate 
                           change 
----------  ------------  --------------------------- 
            Technology    Replacement of existing 
                           products with lower 
                           emission options 
----------  ------------  --------------------------- 
            End-demand    Changing consumer behaviour 
             (market) 
----------  ------------  --------------------------- 
            Reputational  Increased scrutiny 
                           following a change 
                           in stakeholder perceptions 
                           of climate-related 
                           action or inaction 
----------  ------------  --------------------------- 
Physical    Acute         Increased frequency 
                           and severity of weather 
                           events 
----------  ------------  --------------------------- 
            Chronic       Changes in precipitation 
                           patterns 
                           Rising temperatures 
----------  ------------  --------------------------- 
 

Integrating climate into enterprise-wide risk management

Our approach to climate risk management is aligned to HSBC Group's risk management framework and three line of defence model which sets out how we identify, assess and manage our risks. This approach ensures the Board and senior management have visibility and oversight of our key climate risks.

Climate Risk Appetite

Our developing climate risk appetite measures support the oversight and management of the financial and non-financial risks from climate change, meet regulatory expectations and support the business to deliver our climate ambition in a safe and sustainable way. Our initial measures are focused on the oversight and management of our key climate risks: wholesale credit risk, retail credit risk, reputational risk, resilience risk and regulatory compliance.

Our future ambition for our climate risk appetite is to:

-- Adapt the Risk Appetite Statement metrics to incorporate forward looking transition plans and net zero commitments.

   --    Expand to consider other financial and non-financial risks. 
   --    Use enhanced scenario analysis capabilities. 

-- Broaden the scope of risks to include climate considerations in Market Risk, Liquidity Risk, Legal Risk and Environmental Risk management.

Climate Risk Policies, Processes and Controls

We are integrating climate risk into the supporting policies, processes and controls for our key climate risks and we will continue to update these as our climate risk management capabilities mature over time. For example, we have updated our policy on product management and developed the first version of a climate risk scoring tool for our corporate portfolios. In addition, HSBC Group has published the new Thermal Coal Phase-Out Policy and we are implementing this in the region.

Climate Risk Governance and Reporting

Our key climate risks are reported and governed through our climate risk governance structure. Our Climate Risk Oversight Forums are responsible for the oversight, management and escalation of all climate related matters in the region. The regional Risk Management Meeting and the Risk Committee receive scheduled updates on climate risk, and regular updates on our climate risk appetite and top and emerging climate risks.

Our Chief Risk Officer is responsible for the manner by which financial risks from climate change should be identified and managed in line with the group's risk management framework.

We have assessed the impact of climate risk on our balance sheet and have concluded that there is no material impact on the financial statements for the year ended 31 December 2021.

Climate Risk Programme

Our dedicated Climate Risk Programme continues to accelerate the development of our climate risk management capabilities. The key achievements in 2021 include:

   --    We delivered tailored training sessions on climate risk to our legal entity board. 

-- We delivered training to colleagues across the three lines of defence to increase their understanding of how climate risk can impact their role, and we also included an introduction to our climate ambition in our global mandatory training.

-- We developed our climate risk scoring tool for corporate customers for use in priority regions, which builds on our corporate transition questionnaire.

-- We have continued to develop our climate stress testing and scenario analysis capabilities, including model development to deliver on the ECB climate stress testing exercise.

We will continue to enhance our climate risk management capabilities throughout 2022. This will include the further roll-out of training, refinement of our risk appetite, enhancement of our climate risk scoring tool and increasing the availability and quality of data so that new metrics can be developed.

How climate risk can impact the group

Below, we provide detail on how climate risk impacts to our customers might manifest across our key climate risks, and the potential time frames involved using four main drivers under transition risk; policy and legal, technology, end-demand (market) and reputational; and two main drivers under physical risk; acute and chronic.

 
 
                                                  Financial risks                      Non-financial 
                                                                                            risk 
                                   ---------------------------------------------  ------------------------ 
Risk type                          Wholesale                     Strategic                     Regulatory 
                                     credit      Retail      risk (reputational)  Resilience   compliance 
                                                  credit                             risk         risk 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
Timescale(1)                       Short-long  Medium-long       Short-long       Short-long 
                                      term         term             term             term     Short-medium 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
Transition risk drivers 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
- Policy and legal                     l            l                                              l 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
- Technology                           l 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
- End-demand (market)                  l            l 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
- Reputational                         l            l                l 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
Physical risk drivers 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
- Acute - increased frequency and 
 severity of weather event             l            l                                 l 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
- Chronic - changes in weather 
 pattern                               l            l                                 l 
---------------------------------  ----------  -----------  --------------------  ----------  ------------ 
 
   1   Short term: less than one year; medium term: period to 2030; long term: period to 2050. 

Our material banking and insurance risks

The material risk types associated with our banking and insurance manufacturing operations are described in the following tables.

 
Description of risks - banking operations (continued) 
 
Credit risk (see page 32) 
The risk of financial       Credit risk arises             Credit risk is: 
 loss if a customer         principally from direct          *    measured as the amount that could be lost if a 
 or counterparty            lending, trade finance                customer or counterparty fails to make repayments; 
 fails to meet an           and leasing business, 
 obligation under           but also from certain 
 a contract.                other products such              *    monitored using various internal risk management 
                            as guarantees and                     measures and within limits approved by individuals 
                            derivatives.                          within a framework of delegated authorities; and 
 
 
                                                             *    managed through a robust risk control framework that 
                                                                  outlines clear and consistent policies, principles 
                                                                  and guidance for risk managers. 
--------------------------  -----------------------------  ----------------------------------------------------------- 
Treasury risk (see page 70) 
The risk of having          Treasury risk arises           Treasury risk is: 
 insufficient capital,       from changes to the             *    measured through appetites set as target and minimum 
 liquidity or funding        respective resources                 ratios; 
 resources to meet           and risk profiles driven 
 financial obligations       by customer behaviour, 
 and satisfy regulatory      management decisions            *    monitored and projected against appetites and using 
 requirements, including     or the external environment.         stress and scenario testing; and 
 the risk of adverse 
 impact on earnings 
 or capital due to                                           *    managed through control of resources in conjunction 
 structural foreign                                               with risk profiles and cashflows. 
 exchange exposures 
 and changes in market 
 interest rates, 
 and including the 
 financial risks 
 arising from historic 
 and current provision 
 of pensions and 
 other post employment 
 benefits to staff 
 and their dependants. 
--------------------------  -----------------------------  ----------------------------------------------------------- 
Market risk (see page 77) 
The risk that movements     Exposure to market             Market risk is: 
 in market factors          risk is separated into           *    measured using sensitivities, value at risk ('VaR') 
 such as foreign            two portfolios:                       and stress testing, giving a detailed picture of 
 exchange rates,             *    trading portfolios; and         potential gains and losses for a range of market 
 interest rates,                                                  movements and scenarios, as well as tail risks over 
 credit spreads,                                                  specified time horizons; 
 equity prices and           *    non-trading portfolios. 
 commodity prices 
 will reduce our                                             *    monitored using VaR, stress testing and other 
 income or the value        Market risk exposures                 measures, including the sensitivity of net interest 
 of our portfolios.         arising from our insurance            income and the sensitivity of structural foreign 
                            operations are discussed              exchange; and 
                            on page 84. 
 
                                                             *    managed using risk limits approved by the risk 
                                                                  management meeting ('RMM') and the RMM in various 
                                                                  global businesses. 
--------------------------  -----------------------------  ----------------------------------------------------------- 
Resilience risk (see page 80) 
Resilience risk             Resilience risk arises         Resilience risk is: 
 is the risk that           from failures or inadequacies   *    measured through a range of metrics with defined 
 we are unable to           in processes, people,                maximum acceptable impact tolerances, and against our 
 provide critical           systems or external                  agreed risk appetite. 
 services to our            events. These may be 
 customers, affiliates,     driven by rapid technological 
 and counterparties         innovation, changing            *    monitored through oversight of enterprise processes, 
 as a result of sustained   behaviours of our consumers,         risks, controls and strategic change programmes; and 
 and significant            cyber-threats and attacks, 
 operational disruption.    crossborder dependencies, 
                            and third party                 *    managed by continuous monitoring and thematic 
                            relationships.                       reviews. 
Regulatory compliance risk (see page 
 81) 
---------------------------------------------------------  ----------------------------------------------------------- 
Regulatory compliance       Regulatory compliance          Regulatory compliance risk is: 
 risk is the risk            risk arises from the           *    measured by reference to risk appetite, identified 
 associated with             failure to observe                  metrics, incident assessments, regulatory feedback 
 breaching our duty          the letter and spirit               and the judgement and assessment of our regulatory 
 to clients and other        of relevant laws, codes,            compliance teams; 
 counterparties,             rules, regulations 
 inappropriate market        and standards of good 
 conduct and breaching       practice. This could           *    monitored against the first line of defence risk and 
 related financial           result in poor market               control assessments, the results of the monitoring 
 services regulatory         or customer outcomes                and control assurance activities of the second line 
 standards.                  leading to fines, penalties         of defence functions, and the results of internal and 
                             and reputational damage             external audits and regulatory inspections; and 
                             to our business. 
 
                                                            *    managed by establishing and communicating appropriate 
                                                                 policies and procedures, training employees in them 
                                                                 and monitoring activity to help ensure their 
                                                                 observance. Proactive risk control and/or remediation 
                                                                 work is undertaken where required. 
--------------------------  -----------------------------  ----------------------------------------------------------- 
Financial crime risk (see page 81) 
Financial crime             Financial crime risk           Financial crime risk is: 
 risk is the risk            arises from day-to-day         *    measured by reference to risk appetite, identified 
 of knowingly or             banking operations                  metrics, incident assessments, regulatory feedback 
 unknowingly helping         involving customers,                and the judgement of, and assessment by, our 
 parties to commit           third parties and employees.        regulatory compliance teams; 
 or to further potentially 
 illegal activity 
 through HSBC, including                                    *    monitored against the first line of defence risk and 
 money laundering,                                               control assessments, the results of the monitoring 
 fraud, bribery and                                              and control assurance activities of the second line 
 corruption, tax                                                 of defence functions, and the results of internal and 
 evasion, sanctions                                              external audits and regulatory inspections; and 
 breaches, and terrorist 
 and proliferation 
 financing.                                                 *    managed by establishing and communicating appropriate 
                                                                 policies and procedures, training employees in them 
                                                                 and monitoring activity to help ensure their 
                                                                 observance. Proactive risk control and/or remediation 
                                                                 work is undertaken where required. 
--------------------------  -----------------------------  ----------------------------------------------------------- 
Model risk (see page 83) 
Model risk is the           Model risk arises in           Model risk is: 
 potential for adverse       both financial and              *    measured by reference to model performance tracking 
 consequences from           non-financial contexts               and the output of detailed technical reviews, with 
 business decisions          whenever business decision           key metrics including model review statuses and 
 informed by models,         making includes reliance             findings; 
 which can be exacerbated    on models. 
 by errors in methodology, 
 design or the way                                           *    monitored against model risk appetite statements, 
 they are used.                                                   insight from the independent review function, 
                                                                  feedback from internal and external audits, and 
                                                                  regulatory reviews; and 
 
 
                                                             *    managed by creating and communicating appropriate 
                                                                  policies, procedures and guidance, training 
                                                                  colleagues in their application, and supervising 
                                                                  their adoption to ensure operational effectiveness. 
--------------------------  -----------------------------  ----------------------------------------------------------- 
 

Our insurance manufacturing subsidiaries are regulated separately from our banking operations. Risks in our insurance entities are managed using methodologies and processes that are subject to Group oversight. Our insurance operations are also subject to some of the same risks as our banking operations, and these, are covered by the Group's risk management processes. There are though specific risks inherent to the insurance operations as noted below.

 
Description of risks - insurance manufacturing operations 
 
Financial risk (see page 84) 
For insurance  Exposure to financial                                     Financial risk is: 
entities,      risks arises from:                                         *    measured (i) for credit risk, in terms of economic 
Financial       *    market risk affecting the fair values of financial        capital and the amount that could be lost if a 
risk includes        assets or their future cash flows;                        counterparty fails to make repayments; (ii) for 
the risk of                                                                    market risk, in terms of economic capital, internal 
not being                                                                      metrics and fluctuations in key financial variables; 
able            *    credit risk; and                                          and (iii) for liquidity risk, in terms of internal 
to                                                                             metrics, including stressed operational cash flow 
effectively                                                                    projections; 
match           *    liquidity risk of entities not being able to make 
liabilities          payments to policyholders as they fall due. 
arising under                                                             *    monitored through a framework of approved limits and 
insurance                                                                      delegated authorities; and 
contracts 
with 
appropriate                                                               *    managed through a robust risk control framework that 
investments                                                                    outlines clear and consistent policies, principles 
and that the                                                                   and guidance. This includes using product design and 
expected                                                                       asset liability matching and bonus rates. 
sharing 
of financial 
performance 
with 
policyholders 
under certain 
contracts is 
not possible. 
Insurance risk (see page 84) 
The risk       The cost of claims and                                    Insurance risk is: 
that,           benefits can be influenced                                *    measured in terms of life insurance liabilities and 
over time,      by many factors, including                                     economic capital allocated to insurance underwriting 
the             mortality and morbidity                                        risk; 
cost of the     experience, as well as 
contract,       lapse and surrender rates. 
including                                                                 *    monitored though a framework of approved limits and 
claims and                                                                     delegated authorities; and 
benefits 
may exceed 
the                                                                       *    managed through a robust risk control framework that 
total amount                                                                   outlines clear and consistent policies, principles 
of premiums                                                                    and guidance. This includes using product design, 
and                                                                            underwriting, reinsurance and claims-handling 
investment                                                                     procedures. 
income 
received. 
-------------  --------------------------------------------------------  ---------------------------------------------------------- 
 

Credit risk

Credit risk is the risk of financial loss if a customer or counterparty fails to meet an obligation under a contract. Credit risk arises principally from direct lending, trade finance and leasing business, but also from certain other products, such as guarantees and derivatives.

Credit risk management

Key developments in 2021

We continued to actively manage the risks resulting from the Covid-19 outbreak and its impacts on our customers and operations in 2021. For further details of market-specific measures to support our personal and business customers, see page 28. Outside these Covid-19 initiatives, there have been no material changes to credit risk policy and we continue to apply the requirements of IFRS 9 'Financial Instruments' within Credit risk.

Climate Risk

For our Global Banking and Commercial Banking wholesale clients operating in high transition risk sectors, a detailed Transition Risk Questionnaire is completed which assess both the climate risk the client faces and their plans to adapt to a Net Zero world. This information is taken into consideration as part of the broader client credit assessment. During 2022, we will broaden our assessments to include other high risk sectors which may be vulnerable to other climate considerations, including physical risk. This will also be embedded as part of the usual credit assessment process.

Governance and structure

We have established group-wide credit risk management and related IFRS 9 processes. We continue to actively assess the impact of economic developments in key markets on specific customers, customer segments or portfolios. As credit conditions change, we take mitigating action, including the revision of risk appetites or limits and tenors, as appropriate. In addition, we continue to evaluate the terms under which we provide credit facilities within the context of individual customer requirements, the quality of the relationship, local regulatory requirements, market practices and our local market position.

Credit risk sub-function

(Audited)

Credit approval authorities are delegated by the Board to the Chief Executive together with the authority to sub-delegate them. The Credit risk sub-function in Risk is responsible for the key policies and processes for managing credit risk, which include formulating credit policies and risk rating frameworks, guiding the appetite for credit risk exposures, undertaking independent reviews and objective assessment of credit risk, and monitoring performance and management of portfolios.

The principal objectives of our credit risk management are:

-- to maintain across the group a strong culture of responsible lending and a robust risk policy and control framework;

-- to both partner and challenge global businesses in defining, implementing and continually re-evaluating our risk appetite under actual and scenario conditions; and

   --    to ensure there is independent, expert scrutiny of credit risks, their costs and mitigation. 

--

Key risk management process

IFRS 9 'Financial Instruments' process

The IFRS 9 process comprises three main areas: modelling and data; implementation; and governance.

Modelling and data

The Group has established IFRS 9 modelling and data processes in various geographies, which are subject to internal model risk governance including independent review of significant model developments.

Implementation

A centralised impairment engine performs the ECL calculation using data, which is subject to a number of validation checks and enhancements, from a variety of client, finance and risk systems. Where possible, these checks and processes are performed in a globally consistent and centralised manner.

Governance

Management review forums are established in order to review and approve the impairment results. Management review forums have representatives from Credit Risk and Finance. Required members of the committee are the heads of Wholesale Credit, Market Risk, and Wealth and Personal Banking Risk, as well as the global business Chief Financial Officers and the Chief Accounting Officer.

Concentration of exposure

(Audited)

Concentrations of credit risk arise when a number of counterparties or exposures have comparable economic characteristics, or are engaged in similar activities, or operate in the same geographical areas/industry sectors, so that their collective ability to meet contractual obligations is uniformly affected by changes in economic, political or other conditions. The group uses a number of controls and measures to minimise undue concentration of exposure in the group's portfolios across industry, country and customer groups. These include portfolio and counterparty limits, approval and review controls, and stress testing.

Credit quality of financial instruments

(Audited)

Our risk rating system facilitates the internal ratings-based approach under the Basel framework adopted by the Group to support the calculation of our minimum credit regulatory capital requirement. The five credit quality classifications each encompass a range of granular internal credit rating grades assigned to wholesale and retail lending businesses, and the external ratings attributed by external agencies to debt securities.

For debt securities and certain other financial instruments, external ratings have been aligned to the five quality classifications based upon the mapping of related Customer Risk Rating ('CRR') to external credit rating.

Wholesale lending

The CRR 10-grade scale summarises a more granular underlying 23-grade scale of obligor probability of default ('PD'). All corporate customers are rated using the 10- or 23-grade scale, depending on the degree of sophistication of the Basel approach adopted for the exposure.

Each CRR band is associated with an external rating grade by reference to long-run default rates for that grade, represented by the average of issuer-weighted historical default rates. This mapping between internal and external ratings is indicative and may vary over time.

Retail lending

Retail lending credit quality is based on a 12-month point-in-time probability-weighted PD.

 
Credit quality classification 
                                  Sovereign     Other debt 
                            debt securities     securities     Wholesale lending 
                                  and bills      and bills      and derivatives               Retail lending 
                          -----------------  -------------  -----------------------  --------------------------------- 
                                                                           12-month 
                                                                        probability 
                                   External       External   Internal            of    Internal               12 month 
                                     credit         credit     credit       default      credit   probability-weighted 
                                     rating         rating     rating             %      rating                   PD % 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
Quality 
classification(1,2) 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
Strong                              BBB and   A- and above    CRR1 to     0 - 0.169  Band 1 and                0.000 - 
                                      above                   CRR2(1)                         2                  0.500 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
Good                                BBB- to        BBB+ to       CRR3       0.170 -      Band 3                0.501 - 
                                         BB           BBB-                    0.740                              1.500 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
                                   BB- to B       BB+ to B    CRR4 to       0.741 -  Band 4 and                1.501 - 
Satisfactory                    and unrated    and unrated       CRR5         4.914           5                 20.000 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
Sub-standard                        B- to C        B- to C    CRR6 to       4.915 -      Band 6               20.001 - 
                                                                 CRR8        99.999                             99.999 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
                                                              CRR9 to 
Credit impaired                     Default        Default      CRR10           100      Band 7                    100 
------------------------  -----------------  -------------  ---------  ------------  ----------  --------------------- 
 
   1   Customer risk rating ('CRR'). 
   2   12-month point-in-time probability-weighted PD. 
 
Quality classification definitions 
  *    'Strong' exposures demonstrate a strong capacity to 
       meet financial commitments, with negligible or low 
       probability of default and/or low levels of expected 
       loss. 
 
 
  *    'Good' exposures require closer monitoring and 
       demonstrate a good capacity to meet financial 
       commitments, with low default risk. 
 
 
  *    'Satisfactory' exposures require closer monitoring 
       and demonstrate an average to fair capacity to meet 
       financial commitments, with moderate default risk. 
 
 
  *    'Sub-standard' exposures require varying degrees of 
       special attention and default risk is of greater 
       concern. 
 
 
  *    'Credit-impaired' exposures have been assessed as 
       described in Note 1.2(i) on the Financial Statements. 
============================================================ 
 

Renegotiated loans and forbearance

'Forbearance' describes concessions made on the contractual terms of a loan in response to an obligor's financial difficulties.

A loan is classed as 'renegotiated' when we modify the contractual payment terms on concessionary terms because we have significant concerns about the borrowers' ability to meet contractual payments when due. Non-payment-related concessions (e.g. covenant waivers), while potential indicators of impairment, do not trigger identification as renegotiated loans.

Loans that have been identified as renegotiated retain this designation until maturity or derecognition.

For details of our policy on derecognised renegotiated loans, see Note 1.2(i) on the financial statements.

Credit quality of renegotiated loans

On execution of a renegotiation, the loan will also be classified as credit impaired if it is not already so classified. In wholesale lending, all facilities with a customer, including loans that have not been modified, are considered credit impaired following the identification of a renegotiated loan.

Wholesale renegotiated loans are classified as credit impaired until there is sufficient evidence to demonstrate a significant reduction in the risk of non-payment of future cash flows, observed over a minimum one-year period, and there are no other indicators of impairment. Personal renegotiated loans generally remain credit impaired until repayment, write-off or derecognition.

Renegotiated loans and recognition of expected credit losses

(Audited)

For retail lending, unsecured renegotiated loans are generally segmented from other parts of the loan portfolio. Renegotiated expected credit loss assessments reflect the higher rates of losses typically encountered with renegotiated loans. For wholesale lending, renegotiated loans are typically assessed individually. Credit risk ratings are intrinsic to the impairment assessments. The individual impairment assessment takes into account the higher risk of the future non-payment inherent in renegotiated loans.

Impairment assessment

(Audited)

For details of our impairment policies on loans and advances and financial investments see Note 1.2(i) on the financial statements.

Write-off of loans and advances

(Audited)

For details of our accounting policy on the write-off of loans and advances, see Note 1.2(i) on the financial statements.

Unsecured personal facilities, including credit cards, are generally written off at between 150 and 210 days past due. The standard period runs until the end of the month in which the account becomes 180 days contractually delinquent. Write-off periods may be extended, generally to no more than 360 days past due. However, in exceptional circumstances, they may be extended further.

For secured facilities, write-off should occur upon repossession of collateral, receipt of proceeds via settlement, or determination that recovery of the collateral will not be pursued.

Any secured assets maintained on the balance sheet beyond 60 months of consecutive delinquency-driven default require additional monitoring and review to assess the prospect of recovery.

There are exceptions in a few countries where local regulation or legislation constrain earlier write-off, or where the realisation of collateral for secured real estate lending takes more time. In the event of bankruptcy or analogous proceedings, write-off may occur earlier than the maximum periods stated above. Collection procedures may continue after write-off.

Credit risk in 2021

At 31 December 2021, gross loans and advances to customers and banks of GBP103.1bn decreased by GBP12.5bn, compared with

31 December 2020. This included adverse foreign exchange movements of GBP4.3bn. Excluding foreign exchange movements, the decline was driven by a GBP7.1bn decrease in wholesale loans and advances to customers and a GBP1.5bn decrease in loans and advances to banks. This was partly offset by a GBP0.4bn increase in personal loans and advances .

During the first half of 2021, the group experienced a release in allowances for ECL, reflecting an improvement of the economic outlook. This trend continued during the second half of the year following better than expected levels of credit performance and lower levels of stage 3 charges. However, in the later part of the year the trend slowed down due to the emergence of the new Covid-19 Omicron variant. Excluding foreign exchange movements, the allowance for ECL in relation to loans and advances to customers decreased by GBP258m from 31 December 2020.

This was attributable to:

-- a GBP225m decrease in wholesale loans and advances to customers, of which GBP156m was driven by stages 1 and 2; and

-- a GBP33m increase in personal loans and advances to customers, of which GBP14m was driven by stages 1 and 2.

During the first six months of the year, the group experienced significant migrations from stage 2 to stage 1, reflecting an improvement of the economic outlook. This trend continued during the second half of 2021 as forward economic guidance ('FEG') remained broadly stable in comparison with 30 June 2021.

Stage 3 balances at 31 December 2021 remained broadly stable compared with 31 December 2020.

The ECL release for 2021 was GBP174m, inclusive of recoveries, Uncertainty remains as some countries emerge from the pandemic at different speeds of recovery, government support measures unwind and the emergence of new strains of the virus test the efficacy of vaccination programmes.

During 2021, we continued to provide Covid-19-related support to customers under the current policy framework. For further details of market-specific measures to support our personal and business customers, see page 60.

Summary of credit risk

The following disclosure presents the gross carrying/nominal amount of financial instruments to which the impairment requirements in IFRS9 are applied and the associated allowance for ECL. The allowance for ECL decreased from GBP1,632m at

31 December 2020 to GBP1,240m at 31 December 2021.

The allowance for ECL at 31 December 2021 comprised of GBP1,168m (2020: GBP1,497m) in respect of assets held at amortised cost, GBP72m (2020: GBP135m) in respect of loans and other credit related commitments, and financial guarantees, and GBP19m (2020: GBP22m) in respect of debt instruments measured at FVOCI.

 
Summary of financial instruments to which the impairment requirements 
 in IFRS 9 are applied 
(Audited) 
                ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
                                                31 Dec 2021                                                                31 Dec 2020 
                ---------------------------------------------------------------------------  ---------------------------------------------------------------------- 
                            Gross carrying/nominal                                Allowance              Gross carrying/nominal                           Allowance 
                                            amount                               for ECL(1)                              amount                          for ECL(1) 
The group                                     GBPm                                     GBPm                                GBPm                                GBPm 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
Loans and 
 advances to 
 customers at 
 amortised 
 cost                                       92,331                                  (1,154)                             102,960                             (1,469) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
- personal                                  25,394                                    (163)                              26,499                               (208) 
-------------- 
- corporate 
 and 
 commercial                                 56,087                                    (964)                              62,987                             (1,168) 
-------------- 
- non-bank 
 financial 
 institutions                               10,850                                     (27)                              13,474                                (93) 
--------------  ----------------------------------  ---------------------------------------  ---------------------------------- 
Loans and 
 advances to 
 banks at 
 amortised 
 cost                                       10,789                                      (5)                              12,662                                (16) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
Other 
 financial 
 assets 
 measured at 
 amortised 
 cost                                      202,137                                      (9)                             202,763                                (12) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
- cash and 
 balances at 
 central banks                             108,482                                        -                              85,093                                 (1) 
-------------- 
- items in the 
 course of 
 collection 
 from other 
 banks                                         346                                        -                                 243                                   - 
-------------- 
- reverse 
 repurchase 
 agreements - 
 non trading                                54,448                                        -                              67,577                                   - 
-------------- 
- financial 
 investments                                    10                                        -                                  15                                   - 
-------------- 
- prepayments, 
 accrued 
 income and 
 other 
 assets(2)                                  38,851                                      (9)                              49,835                                (11) 
--------------  ----------------------------------  ---------------------------------------  ---------------------------------- 
Total gross 
 carrying 
 amount on 
 balance 
 sheet                                     305,257                                  (1,168)                             318,385                             (1,497) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
Loans and 
 other credit 
 related 
 commitments                               115,695                                     (55)                             143,036                               (112) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
- personal                                   2,269                                      (1)                               2,211                                 (1) 
-------------- 
- corporate 
 and 
 commercial                                 63,352                                     (48)                              75,863                                (89) 
-------------- 
- financial                                 50,074                                      (6)                              64,962                                (22) 
--------------  ----------------------------------  ---------------------------------------  ---------------------------------- 
Financial 
 guarantees(3)                              11,054                                     (17)                               3,969                                (23) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
- personal                                      26                                        -                                  32                                   - 
-------------- 
- corporate 
 and 
 commercial                                  9,894                                     (16)                               2,735                                (19) 
-------------- 
- financial                                  1,134                                      (1)                               1,202                                 (4) 
--------------  ----------------------------------  ---------------------------------------  ---------------------------------- 
Total nominal 
 amount off 
 balance 
 sheet(4)                                  126,749                                     (72)                             147,005                               (135) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
                                           432,006                                  (1,240)                             465,390                             (1,632) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
 
                                                                                 Memorandum                                                              Memorandum 
                                                                                  allowance                                                               allowance 
                                        Fair value                               for ECL(5)                          Fair value                          for ECL(5) 
                                              GBPm                                     GBPm                                GBPm                                GBPm 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
Debt 
 instruments 
 measured at 
 fair 
 value through 
 other 
 comprehensive 
 income 
 ('FVOCI')                                  41,188                                     (19)                              51,713                                (22) 
--------------  ----------------------------------  ---------------------------------------  ----------------------------------  ---------------------------------- 
 

1 The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial asset, in which case the ECL is recognised as a provision.

2 Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. 'Prepayments, accrued income and other assets' as presented within the consolidated balance sheet on page 110 includes both financial and non-financial assets.

3 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

4 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

5 Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is recognised in 'Change in expected credit losses and other credit impairment charges' in the income statement.

 
Summary of financial instruments to which the impairment 
 requirements in IFRS 9 are applied 
(Audited) 
                 -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
                                                  31 Dec 2021                                                                  31 Dec 2020 
                 -----------------------------------------------------------------------------  ------------------------------------------------------------------------ 
                                Gross carrying/nominal                               Allowance                Gross carrying/nominal                           Allowance 
                                                amount                              for ECL(1)                                amount                          for ECL(1) 
The bank                                          GBPm                                    GBPm                                  GBPm                                GBPm 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
Loans and 
 advances to 
 customers at 
 amortised cost                                 34,286                                   (350)                                43,831                               (590) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
- personal                                       3,680                                     (6)                                 3,582                                (13) 
--------------- 
- corporate and 
 commercial                                     21,182                                   (308)                                26,014                               (494) 
--------------- 
- non-bank 
 financial 
 institutions                                    9,424                                    (36)                                14,235                                (83) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------ 
Loans and 
 advances to 
 banks at 
 amortised 
 cost                                            6,782                                     (4)                                 8,078                                (15) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
Other financial 
 assets 
 measured at 
 amortised cost                                135,033                                     (1)                               135,900                                 (1) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
- cash and 
 balances at 
 central banks                                  63,008                                       -                                48,777                                   - 
--------------- 
- items in the 
 course of 
 collection 
 from other 
 banks                                             211                                       -                                    37                                   - 
--------------- 
- reverse 
 repurchase 
 agreements-non 
 trading                                        39,708                                       -                                50,137                                   - 
--------------- 
- financial 
 investments                                     3,337                                       -                                 2,214                                   - 
--------------- 
- prepayments, 
 accrued income 
 and 
 other 
 assets(2)                                      28,769                                     (1)                                34,735                                 (1) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------ 
Total gross 
 carrying 
 amount on 
 balance 
 sheet                                         176,101                                   (355)                               187,809                               (606) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
Loans and other 
 credit related 
 commitments                                    31,255                                    (29)                                45,308                                (81) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
- personal                                         589                                       -                                   352                                   - 
--------------- 
- corporate and 
 commercial                                     19,175                                    (26)                                25,444                                (66) 
--------------- 
- financial                                     11,491                                     (3)                                19,512                                (15) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------ 
Financial 
 guarantees(3)                                   1,270                                     (7)                                 1,510                                (13) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
- personal                                           3                                       -                                     3                                   - 
--------------- 
- corporate and 
 commercial                                        527                                     (6)                                   457                                 (9) 
--------------- 
- financial                                        740                                     (1)                                 1,050                                 (4) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------ 
Total nominal 
 amount off 
 balance 
 sheet(4)                                       32,525                                    (36)                                46,818                                (94) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
                                               208,626                                   (391)                               234,627                               (700) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
 
                                                                                    Memorandum                                                                Memorandum 
                                                                                     allowance                                                                 allowance 
                                            Fair value                              for ECL(5)                            Fair value                          for ECL(5) 
                                                  GBPm                                    GBPm                                  GBPm                                GBPm 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
Debt 
 instruments 
 measured at 
 FVOCI                                          23,152                                     (4)                                28,699                                 (9) 
---------------  -------------------------------------  --------------------------------------  ------------------------------------  ---------------------------------- 
 

1 The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial asset, in which case the ECL is recognised as a provision.

2 Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. 'Prepayments, accrued income and other assets' as presented within the consolidated balance sheet on page 110 includes both financial and non-financial assets.

3 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

4 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

5 Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is recognised in 'Change in expected credit losses and other credit impairment charges' in the income statement.

The following table provides an overview of the group's and bank's credit risk by stage and industry, and the associated ECL coverage. The financial assets recorded in each stage have the following characteristics:

-- Stage 1: These financial assets are unimpaired and without significant increase in credit risk on which a 12-month allowance for ECL is recognised.

-- Stage 2: A significant increase in credit risk has been experienced since initial recognition on which a lifetime ECL is recognised.

--

Stage 3: There is objective evidence of impairment, and are therefore considered to be in default or otherwise credit-impaired on which a lifetime ECL is recognised.

-- Purchased or originated credit-impaired ('POCI'): Financial assets that are purchased or originated at a deep discount that reflects the incurred credit losses on which a lifetime ECL is recognised.

 
Summary of credit risk (excluding debt instruments measured at FVOCI) 
 by stage distribution and ECL coverage by industry sector at 
 31 December 2021 
(Audited) 
                                                             Gross carrying/nominal                                                                 Allowance for 
                                                                    amount(2)                                                                             ECL                                                                     ECL coverage % 
                                        -----------------------------------------------------------------  ----------------  ------------------------------------------------------------  ------------------------------  ----------------------------  ----- 
                                                  Stage             Stage             Stage                                           Stage           Stage           Stage                                                Stage  Stage  Stage 
                                                      1                 2                 3       POCI(3)             Total               1               2               3       POCI(3)                           Total      1      2      3  POCI(3)  Total 
The group                                          GBPm              GBPm              GBPm          GBPm              GBPm            GBPm            GBPm            GBPm          GBPm                            GBPm      %      %      %        %      % 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost                                            80,730             9,121             2,478             2            92,331            (86)           (158)           (908)           (2)                         (1,154)    0.1    1.7   36.6    100.0    1.2 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
- personal                                       24,255               686               453             -            25,394            (22)            (16)           (125)             -                           (163)    0.1    2.3   27.6        -    0.6 
-------------------------------------- 
 
  *    corporate and commercial                  46,237             8,066             1,782             2            56,087            (58)           (137)           (767)           (2)                           (964)    0.1    1.7   43.0    100.0    1.7 
-------------------------------------- 
 
  *    non-bank financial institutions           10,238               369               243             -            10,850             (6)             (5)            (16)             -                            (27)    0.1    1.4    6.6        -    0.2 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  ------- 
Loans and 
 advances 
 to banks 
 at amortised 
 cost                                            10,750                39                 -             -            10,789             (4)             (1)               -             -                             (5)      -    2.6      -        -      - 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
Other financial 
 assets measured 
 at amortised 
 cost                                           202,048                47                42             -           202,137               -               -             (9)             -                             (9)      -      -   21.4        -      - 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
Loan and 
 other credit-related 
 commitments                                    107,922             7,571               202             -           115,695            (25)            (22)             (8)             -                            (55)      -    0.3    4.0        -      - 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
- personal                                        2,152               114                 3             -             2,269             (1)               -               -             -                             (1)      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                  56,325             6,829               198             -            63,352            (20)            (20)             (8)             -                            (48)      -    0.3    4.0        -    0.1 
-------------------------------------- 
- financial                                      49,445               628                 1             -            50,074             (4)             (2)               -             -                             (6)      -    0.3      -        -      - 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  ------- 
Financial 
 guarantees(1)                                   10,215               740                99             -            11,054             (3)             (7)             (7)             -                            (17)      -    0.9    7.1        -    0.2 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
- personal                                           23                 2                 1             -                26               -               -               -             -                               -      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                   9,257               540                97             -             9,894             (2)             (7)             (7)             -                            (16)      -    1.3    7.2        -    0.2 
-------------------------------------- 
- financial                                         935               198                 1             -             1,134             (1)               -               -             -                             (1)    0.1      -      -        -    0.1 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  ------- 
At 31 Dec 
 2021                                           411,665            17,518             2,821             2           432,006           (118)           (188)           (932)           (2)                         (1,240)      -    1.1   33.0    100.0    0.3 
--------------------------------------  ---------------  ----------------  ----------------  ------------  ----------------  --------------  --------------  --------------  ------------  ------------------------------  -----  -----  -----  -------  ----- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   3   Purchased or originated credit-impaired ('POCI'). 

Unless identified at an earlier stage, all financial assets are deemed to have suffered a significant increase in credit risk when they are 30 days past due ('DPD') and are transferred from stage 1 to stage 2. The following disclosure presents the ageing of stage 2

financial assets by those less than 30 days and greater than 30 DPD and therefore presents those financial assets classified as stage 2 due to ageing (30 DPD) and those identified at an earlier stage (less than 30 DPD).

 
Stage 2 days past due analysis at 31 December 2021 
(Audited)                             Gross carrying amount                                                    Allowance for ECL                                  ECL coverage % 
               --------------------------------------------------------------------  ----------------------------------------------------------------------  ------------------------- 
                                                                                                                                                                       Of        Of 
                                           Of which:               Of which:                                       Of which:               Of which:                 which:    which: 
                                                                                                                                                                        1 to    30 and 
                              Stage                    1 to                  30 and                   Stage                    1 to                  30 and  Stage        29         > 
                                  2             29 DPD(1,2)              > DPD(1,2)                       2             29 DPD(1,2)              > DPD(1,2)      2  DPD(1,2)  DPD(1,2) 
The group                      GBPm                    GBPm                    GBPm                    GBPm                    GBPm                    GBPm      %         %         % 
-------------  --------------------  ----------------------  ----------------------  ----------------------  ----------------------  ----------------------  -----  --------  -------- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost:                        9,121                      56                     237                   (158)                     (1)                     (1)    1.7       1.8       0.4 
-------------  --------------------  ----------------------  ----------------------  ----------------------  ----------------------  ----------------------  -----  --------  -------- 
- personal                      686                      49                      29                    (16)                     (1)                     (1)    2.3       2.0       3.4 
------------- 
- corporate 
 and 
 commercial                   8,066                       7                     199                   (137)                       -                       -    1.7         -         - 
------------- 
- non-bank 
 financial 
 institutions                   369                       -                       9                     (5)                       -                       -    1.4         -         - 
-------------  --------------------  ----------------------  ----------------------  ----------------------  ----------------------  ----------------------  -----  -------- 
Loans and 
 advances 
 to banks at 
 amortised 
 cost                            39                       -                       -                     (1)                       -                       -    2.6         -         - 
-------------  --------------------  ----------------------  ----------------------  ----------------------  ----------------------  ----------------------  -----  --------  -------- 
Other 
 financial 
 assets 
 measured at 
 amortised 
 cost                            47                       -                       -                       -                       -                       -      -         -         - 
-------------  --------------------  ----------------------  ----------------------  ----------------------  ----------------------  ----------------------  -----  --------  -------- 
 
   1   Days past due ('DPD'). Up-to-date accounts in stage 2 are not shown in amounts presented above. 

2 The days past due amounts presented above are on a contractual basis and include the benefit of any customer relief payment holidays granted.

 
Summary of credit risk (excluding debt instruments measured at FVOCI) 
 by stage distribution and ECL coverage by industry sector at 
 31 December 2020 (continued) 
(Audited) 
                                                                              Gross carrying/nominal 
                                                                                     amount(2)                                                                           Allowance for ECL                                          ECL coverage % 
                                        --------------------------------------------------------------------------------------------------  ----------------------------------------------------------------------------  ----------------------------------- 
                                                           Stage           Stage           Stage                                                     Stage          Stage           Stage                                 Stage  Stage  Stage 
                                                               1               2               3         POCI(3)                     Total               1              2               3        POCI(3)           Total      1      2      3  POCI(3)  Total 
The group                                                   GBPm            GBPm            GBPm            GBPm                      GBPm            GBPm           GBPm            GBPm           GBPm            GBPm      %      %      %        %      % 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost                                                     83,179          16,774           2,966              41                   102,960           (129)          (297)         (1,031)           (12)         (1,469)    0.2    1.8   34.8     29.3    1.4 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
- personal                                                24,991             974             534               -                    26,499            (18)           (37)           (153)              -           (208)    0.1    3.8   28.7        -    0.8 
-------------------------------------- 
 
  *    corporate and commercial                           46,773          14,052           2,121              41                    62,987           (100)          (225)           (831)           (12)         (1,168)    0.2    1.6   39.2     29.3    1.9 
-------------------------------------- 
 
  *    non-bank financial institutions                    11,415           1,748             311               -                    13,474            (11)           (35)            (47)              -            (93)    0.1    2.0   15.1        -    0.7 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  ------- 
Loans and 
 advances 
 to banks 
 at amortised 
 cost                                                     12,533             129               -               -                    12,662            (13)            (3)               -              -            (16)    0.1    2.3      -        -    0.1 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
Other financial 
 assets measured 
 at amortised 
 cost                                                    202,659              65              39               -                   202,763             (2)              -            (10)              -            (12)      -      -   25.6        -      - 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
Loan and 
 other credit-related 
 commitments                                             128,956          13,814             266               -                   143,036            (34)           (68)            (10)              -           (112)      -    0.5    3.8        -    0.1 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
- personal                                                 1,991             217               3               -                     2,211               -            (1)               -              -             (1)      -    0.5      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                           65,199          10,404             260               -                    75,863            (29)           (51)             (9)              -            (89)      -    0.5    3.5        -    0.1 
-------------------------------------- 
- financial                                               61,766           3,193               3               -                    64,962             (5)           (16)             (1)              -            (22)      -    0.5   33.3        -      - 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  ------- 
Financial 
 guarantees(1)                                             2,839           1,008             121               1                     3,969             (4)           (10)             (9)              -            (23)    0.1    1.0    7.4        -    0.6 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
- personal                                                    26               5               1               -                        32               -              -               -              -               -      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                            1,878             737             119               1                     2,735             (3)            (7)             (9)              -            (19)    0.2    0.9    7.6        -    0.7 
-------------------------------------- 
- financial                                                  935             266               1               -                     1,202             (1)            (3)               -              -             (4)    0.1    1.1      -        -    0.3 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  ------- 
At 31 Dec 
 2020                                                    430,166          31,790           3,392              42                   465,390           (182)          (378)         (1,060)           (12)         (1,632)      -    1.2   31.3     28.6    0.4 
--------------------------------------  ------------------------  --------------  --------------  --------------  ------------------------  --------------  -------------  --------------  -------------  --------------  -----  -----  -----  -------  ----- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   3   Purchased or originated credit-impaired ('POCI'). 
 
Stage 2 days past due analysis at 31 December 2020 (continued) 
(Audited)                             Gross carrying amount                                                     Allowance for ECL                                     ECL coverage % 
               -------------------------------------------------------------------  -------------------------------------------------------------------------  ---------------------------- 
                                                                                                                                                                            Of 
                                                   Of which:             Of which:                                         Of which:                Of which:           which:    Of which: 
                                                                                                                                                                          1 to 
                               Stage                    1 to                30 and                    Stage                     1 to                   30 and  Stage        29       30 and 
                                   2             29 DPD(1,2)            > DPD(1,2)                        2              29 DPD(1,2)               > DPD(1,2)      2  DPD(1,2)   > DPD(1,2) 
The group                       GBPm                    GBPm                  GBPm                     GBPm                     GBPm                     GBPm      %         %            % 
-------------  ---------------------  ----------------------  --------------------  -----------------------  -----------------------  -----------------------  -----  --------  ----------- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost                         16,774                      64                    50                    (297)                      (3)                      (2)    1.8       4.7          4.0 
-------------  ---------------------  ----------------------  --------------------  -----------------------  -----------------------  -----------------------  -----  --------  ----------- 
- personal                       974                      54                    39                     (37)                      (2)                      (2)    3.8       3.7          5.1 
------------- 
- corporate 
 and 
 commercial                   14,052                       9                    11                    (225)                      (1)                        -    1.6      11.1            - 
------------- 
- non-bank 
 financial 
 institutions                  1,748                       1                     -                     (35)                        -                        -    2.0         -            - 
-------------  ---------------------  ----------------------  --------------------  -----------------------  -----------------------  -----------------------  -----  -------- 
Loans and 
 advances 
 to banks at 
 amortised 
 cost                            129                       -                     -                      (3)                        -                        -    2.3         -            - 
-------------  ---------------------  ----------------------  --------------------  -----------------------  -----------------------  -----------------------  -----  --------  ----------- 
Other 
 financial 
 assets 
 measured at 
 amortised 
 cost                             65                       -                     -                        -                        -                        -      -         -            - 
-------------  ---------------------  ----------------------  --------------------  -----------------------  -----------------------  -----------------------  -----  --------  ----------- 
 
   1   Days past due ('DPD'). Up-to-date accounts in stage 2 are not shown in amounts presented above. 

2 The days past due amounts presented above are on a contractual basis and include the benefit of any customer relief payment holidays granted.

 
Summary of credit risk (excluding debt instruments measured at FVOCI) 
 by stage distribution and ECL coverage by industry sector at 
 31 December 2021 
(Audited) 
                                                             Gross carrying/nominal 
                                                                    amount(2)                                                                               Allowance for ECL                                             ECL coverage % 
                                        -----------------------------------------------------------------  --------------------------  -----------------------------------------------------------  -------------  ----------------------------  ----- 
                                                     Stage           Stage           Stage                                                      Stage            Stage           Stage                             Stage  Stage  Stage 
                                                         1               2               3        POCI(3)                       Total               1                2               3     POCI(3)          Total      1      2      3  POCI(3)  Total 
The bank                                              GBPm            GBPm            GBPm           GBPm                        GBPm            GBPm             GBPm            GBPm        GBPm           GBPm      %      %      %        %      % 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost                                               30,105           3,197             984              -                      34,286            (33)             (47)           (270)           -          (350)    0.1    1.5   27.4        -    1.0 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
- personal                                           3,544              88              48              -                       3,680             (1)              (2)             (3)           -            (6)      -    2.3    6.3        -    0.2 
-------------------------------------- 
 
  *    corporate and commercial                     17,608           2,893             681              -                      21,182            (28)             (45)           (235)           -          (308)    0.2    1.6   34.5        -    1.5 
-------------------------------------- 
 
  *    non-bank financial institutions               8,953             216             255              -                       9,424             (4)                -            (32)           -           (36)      -      -   12.5        -    0.4 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  ------- 
Loans and 
 advances 
 to banks 
 at amortised 
 cost                                                6,775               7               -              -                       6,782             (3)              (1)               -           -            (4)      -   14.3      -        -    0.1 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
Other financial 
 assets 
 measured 
 at amortised 
 cost                                              134,984              21              28              -                     135,033               -                -             (1)           -            (1)      -      -    3.6        -      - 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
Loan and 
 other credit-related 
 commitments                                        28,911           2,301              43              -                      31,255            (15)             (11)             (3)           -           (29)    0.1    0.5    7.0        -    0.1 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
- personal                                             585               2               2              -                         589               -                -               -           -              -      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                     17,010           2,124              41              -                      19,175            (12)             (11)             (3)           -           (26)    0.1    0.5    7.3        -    0.1 
-------------------------------------- 
- financial                                         11,316             175               -              -                      11,491             (3)                -               -           -            (3)      -      -      -        -      - 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  ------- 
Financial 
 guarantees(1)                                       1,060             150              60              -                       1,270             (1)                -             (6)           -            (7)    0.1      -   10.0        -    0.6 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
- personal                                               2               1               -              -                           3               -                -               -           -              -      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                        437              31              59              -                         527               -                -             (6)           -            (6)      -      -   10.2        -    1.1 
-------------------------------------- 
- financial                                            621             118               1              -                         740             (1)                -               -           -            (1)    0.2      -      -        -    0.1 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  ------- 
At 31 Dec 
 2021                                              201,835           5,676           1,115              -                     208,626            (52)             (59)           (280)           -          (391)      -    1.0   25.1        -    0.2 
--------------------------------------  ------------------  --------------  --------------  -------------  --------------------------  --------------  ---------------  --------------  ----------  -------------  -----  -----  -----  -------  ----- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   3   Purchased or originated credit-impaired ('POCI'). 
 
Stage 2 days past due analysis at 31 December 2021 
(Audited)                             Gross carrying amount                                                   Allowance for ECL                                ECL coverage % 
               --------------------------------------------------------------------  --------------------------------------------------------------------  ----------------------- 
                                                  Of which:               Of which:                                       Of which:             Of which:             Of        Of 
                                                                                                                                                                  which:    which: 
                                                                                                                                                                    1 to 
                                Stage                  1 to                  30 and                   Stage                    1 to                30 and  Stage      29    30 and 
                                    2             29 DPD(1)                > DPD(1)                       2               29 DPD(1)              > DPD(1)      2  DPD(1)  > DPD(1) 
The bank                         GBPm                  GBPm                    GBPm                    GBPm                    GBPm                  GBPm      %       %         % 
-------------  ----------------------  --------------------  ----------------------  ----------------------  ----------------------  --------------------  -----  ------  -------- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost:                          3,197                    19                       6                    (47)                     (1)                     -    1.5     5.3         - 
-------------  ----------------------  --------------------  ----------------------  ----------------------  ----------------------  --------------------  -----  ------  -------- 
- personal                         88                    19                       6                     (2)                     (1)                     -    2.3     5.3         - 
------------- 
- corporate 
 and 
 commercial                     2,893                     -                       -                    (45)                       -                     -    1.6       -         - 
------------- 
- non-bank 
 financial 
 institutions                     216                     -                       -                       -                       -                     -      -       -         - 
-------------  ----------------------  --------------------  ----------------------  ----------------------  ----------------------  --------------------  -----  ------ 
Loans and 
 advances 
 to banks at 
 amortised 
 cost                               7                     -                       -                     (1)                       -                     -   14.3       -         - 
-------------  ----------------------  --------------------  ----------------------  ----------------------  ----------------------  --------------------  -----  ------  -------- 
Other 
 financial 
 assets 
 measured at 
 amortised 
 cost                              21                     -                       -                       -                       -                     -      -       -         - 
-------------  ----------------------  --------------------  ----------------------  ----------------------  ----------------------  --------------------  -----  ------  -------- 
 
   1   Days past due ('DPD'). Up-to-date accounts in stage 2 are not shown in amounts presented above. 
 
Summary of credit risk (excluding debt instruments measured at FVOCI) 
 by stage distribution and ECL coverage by industry sector at 
 31 December 2020 (continued) 
(Audited) 
                                                                 Gross carrying/nominal                                                                         Allowance for 
                                                                        amount(2)                                                                                    ECL                                                   ECL coverage % 
                                        -------------------------------------------------------------------------  -------------------  -------------------------------------------------------------  -----------  ----------------------------  ----- 
                                                         Stage             Stage             Stage                                                Stage          Stage           Stage                              Stage  Stage  Stage 
                                                             1                 2                 3        POCI(3)                Total                1              2               3        POCI(3)        Total      1      2      3  POCI(3)  Total 
The bank                                                  GBPm              GBPm              GBPm           GBPm                 GBPm             GBPm           GBPm            GBPm           GBPm         GBPm      %      %      %        %      % 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost                                                   34,629             7,921             1,279              2               43,831             (79)          (158)           (351)            (2)        (590)    0.2    2.0   27.4    100.0    1.3 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
- personal                                               3,455                70                57              -                3,582              (1)            (8)             (4)              -         (13)      -   11.4    7.0        -    0.4 
-------------------------------------- 
 
  *    corporate and commercial                         18,670             6,424               918              2               26,014             (70)          (121)           (301)            (2)        (494)    0.4    1.9   32.8    100.0    1.9 
-------------------------------------- 
 
  *    non-bank financial institutions                  12,504             1,427               304              -               14,235              (8)           (29)            (46)              -         (83)    0.1    2.0   15.1        -    0.6 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  ------- 
Loans and 
 advances 
 to banks 
 at amortised 
 cost                                                    7,995                83                 -              -                8,078             (12)            (3)               -              -         (15)    0.2    3.6      -        -    0.2 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
Other financial 
 assets 
 measured 
 at amortised 
 cost                                                  135,843                35                22              -              135,900                -              -             (1)              -          (1)      -      -    4.5        -      - 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
Loan and 
 other credit-related 
 commitments                                            39,343             5,905                60              -               45,308             (28)           (48)             (5)              -         (81)    0.1    0.8    8.3        -    0.2 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
- personal                                                 338                14                 -              -                  352                -              -               -              -            -      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                         21,895             3,492                57              -               25,444             (23)           (39)             (4)              -         (66)    0.1    1.1    7.0        -    0.3 
-------------------------------------- 
- financial                                             17,110             2,399                 3              -               19,512              (5)            (9)             (1)              -         (15)      -    0.4   33.3        -    0.1 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  ------- 
Financial 
 guarantees(1)                                           1,203               253                54              -                1,510              (2)            (4)             (7)              -         (13)    0.2    1.6   13.0        -    0.9 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
- personal                                                   2                 1                 -              -                    3                -              -               -              -            -      -      -      -        -      - 
-------------------------------------- 
 
  *    corporate and commercial                            331                73                53              -                  457              (1)            (1)             (7)              -          (9)    0.3    1.4   13.2        -    2.0 
-------------------------------------- 
- financial                                                870               179                 1              -                1,050              (1)            (3)               -              -          (4)    0.1    1.7      -        -    0.4 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  ------- 
At 31 Dec 
 2020                                                  219,013            14,197             1,415              2              234,627            (121)          (213)           (364)            (2)        (700)    0.1    1.5   25.7    100.0    0.3 
--------------------------------------  ----------------------  ----------------  ----------------  -------------  -------------------  ---------------  -------------  --------------  -------------  -----------  -----  -----  -----  -------  ----- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   3   Purchased or originated credit-impaired ('POCI'). 
 
Stage 2 days past due analysis at 31 December 2020 (continued) 
(Audited)                              Gross carrying amount                                                      Allowance for ECL                                   ECL coverage % 
               ---------------------------------------------------------------------  -------------------------------------------------------------------------  ------------------------ 
                                                   Of which:               Of which:                                         Of which:                Of which:             Of  Of which: 
                                                                                                                                                                        which: 
                                                        1 to                                                                      1 to                                    1 to 
                               Stage                      29                  30 and                    Stage                       29                   30 and  Stage      29     30 and 
                                   2                  DPD(1)                > DPD(1)                        2                   DPD(1)                 > DPD(1)      2  DPD(1)   > DPD(1) 
The bank                        GBPm                    GBPm                    GBPm                     GBPm                     GBPm                     GBPm      %       %          % 
-------------  ---------------------  ----------------------  ----------------------  -----------------------  -----------------------  -----------------------  -----  ------  --------- 
Loans and 
 advances 
 to customers 
 at amortised 
 cost:                         7,921                      16                       8                    (158)                      (1)                      (1)    2.0     6.3       12.5 
-------------  ---------------------  ----------------------  ----------------------  -----------------------  -----------------------  -----------------------  -----  ------  --------- 
- Personal                        70                      15                       8                      (8)                      (1)                      (1)   11.4     6.7       12.5 
------------- 
- Corporate 
 and 
 commercial                    6,424                       1                       -                    (121)                        -                        -    1.9       -          - 
------------- 
- Non-bank 
 financial 
 institutions                  1,427                       -                       -                     (29)                        -                        -    2.0       -          - 
-------------  ---------------------  ----------------------  ----------------------  -----------------------  -----------------------  -----------------------  -----  ------ 
Loans and 
 advances 
 to banks at 
 amortised 
 cost                             83                       -                       -                      (3)                        -                        -    3.6       -          - 
-------------  ---------------------  ----------------------  ----------------------  -----------------------  -----------------------  -----------------------  -----  ------  --------- 
Other 
 financial 
 assets 
 measured at 
 amortised 
 cost                             35                       -                       -                        -                        -                        -      -       -          - 
-------------  ---------------------  ----------------------  ----------------------  -----------------------  -----------------------  -----------------------  -----  ------  --------- 
 
   1   Days past due ('DPD'). Up-to-date accounts in stage 2 are not shown in amounts presented above. 

Stage 2 decomposition as at 31 December 2021

The following disclosure presents the stage 2 decomposition of gross carrying amount and allowances for ECL for loans and advances to customers.

The table below discloses the reasons why an exposure moved into stage 2 originally, and is therefore presented as a significant increase in credit risk since origination.

The Quantitative classification is predominantly related to exposures where the adjusted 12-month PD is greater than the average 12-month PD; or accounts with a significant increase in credit risk when the origination PD has doubled.

The Qualitative classification primarily accounts for management judgemental adjustments, CRR deterioration, and other reasons.

For further details on our approach to the assessment of significant increase in credit risk, see 'Summary of significant accounting policies' on page 119.

.

 
Loans and advances to customers(1) 
                           Gross carrying amount                            Allowance for ECL 
               ---------------------------------------------  --------------------------------------------- 
                             Corporate       Non-bank                       Corporate       Non-bank               ECL 
                                   and      financial                             and      financial          Coverage 
               Personal     commercial   institutions  Total  Personal     commercial   institutions  Total    % Total 
The group          GBPm           GBPm           GBPm   GBPm      GBPm           GBPm           GBPm   GBPm          % 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
Quantitative        561          3,611            162  4,334      (13)           (41)            (1)   (55)        1.3 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
Qualitative         102          4,260            198  4,560       (2)           (96)            (4)  (102)        2.2 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
30 DPD 
 backstop(2)         23            195              9    227       (1)              -              -    (1)        0.4 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
Total Stage 
 2                  686          8,066            369  9,121      (16)          (137)            (5)  (158)        1.7 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
The bank 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
Quantitative         26          1,731             95  1,852       (2)            (9)              -   (11)        0.6 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
Qualitative          62          1,162            121  1,345         -           (36)              -   (36)        2.7 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
30 DPD                -              -              -      -         -              -              -      - 
backstop(2)                                                                                                          - 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
Total Stage 
 2                   88          2,893            216  3,197       (2)           (45)              -   (47)        1.5 
-------------  --------  -------------  -------------  -----  --------  -------------  -------------  -----  --------- 
 

1 Where balances satisfy more than one of the above three criteria for determining a significant increase in credit risk, the corresponding gross exposure and ECL have been assigned in order of categories presented.

   2   Days past due ('DPD'). 

Credit exposure

Maximum exposure to credit risk

(Audited)

This section provides information on balance sheet items and their offsets as well as loan and other credit-related commitments. The offset on derivatives remains in line with the movements in maximum exposure amounts.

 
'Maximum exposure to credit risk' 
 table 
 The following table presents our 
 maximum exposure before taking account 
 of any collateral held or other 
 credit enhancements (unless such 
 enhancements meet accounting offsetting 
 requirements). The table excludes 
 financial instruments whose carrying 
 amount best represents the net exposure 
 to credit risk and it excludes equity 
 securities as they are not subject 
 to credit risk. For the financial 
 assets recognised on the balance 
 sheet, the maximum exposure to credit 
 risk equals their carrying amount; 
 for financial guarantees and other 
 guarantees granted, it is the maximum 
 amount that we would have to pay 
 if the guarantees were called upon. 
 For loan commitments and other credit-related 
 commitments, it is generally the 
 full amount of the committed facilities. 
 The offset in the table relates 
 to amounts where there is a legally 
 enforceable right of offset in the 
 event of counterparty default and 
 where, 
 
 
as a result, there is a net exposure 
 for credit risk purposes. However, 
 as there is no intention to settle 
 these balances on a net basis under 
 normal circumstances, they do not 
 qualify for net presentation for 
 accounting purposes. No offset has 
 been applied to off-balance sheet 
 collateral. In the case of derivatives 
 the offset column also includes 
 collateral received in cash and 
 other financial assets. 
======================================= 
 

Other credit risk mitigants

While not disclosed as an offset in the following 'Maximum exposure to credit risk' table, other arrangements are in place which reduce our maximum exposure to credit risk. These include a charge over collateral on borrowers' specific assets such as residential properties, collateral held in the form of financial instruments that are not held on balance sheet and short positions in securities. In addition, for financial assets held as part of linked insurance/investment contracts the risk is predominantly borne by the policyholder. See Note 28 on the financial statements for further details of collateral in respect of certain loans and advances and derivatives.

Collateral available to mitigate credit risk is disclosed in the Collateral section on page 64.

 
Maximum exposure to credit risk 
                                                                                       ----------------------  -----------------------  ---------------------- 
(Audited)                                        2021                                                                   2020 
                 --------------------------------------------------------------------  ----------------------------------------------------------------------- 
                               Maximum                                                                Maximum 
                              exposure                  Offset                    Net                exposure                   Offset                     Net 
The group                         GBPm                    GBPm                   GBPm                    GBPm                     GBPm                    GBPm 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
Loans and 
 advances to 
 customers 
 held at 
 amortised cost                 91,177                 (7,057)                 84,120                 101,491                  (8,717)                  92,774 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
- personal                      25,231                       -                 25,231                  26,291                      (3)                  26,288 
--------------- 
- corporate and 
 commercial                     55,123                 (6,228)                 48,895                  61,819                  (7,662)                  54,157 
--------------- 
- non-bank 
 financial 
 institutions                   10,823                   (829)                  9,994                  13,381                  (1,052)                  12,329 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  ----------------------- 
Loans and 
 advances to 
 banks at 
 amortised 
 cost                           10,784                    (88)                 10,696                  12,646                    (137)                  12,509 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
Other financial 
 assets held at 
 amortised 
 cost                          202,455                (10,239)                192,216                 203,084                 (10,604)                 192,480 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
- cash and 
 balances at 
 central banks                 108,482                       -                108,482                  85,092                        -                  85,092 
--------------- 
- items in the 
 course of 
 collection 
 from other 
 banks                             346                       -                    346                     243                        -                     243 
- reverse 
 repurchase 
 agreements 
 - non trading                  54,448                (10,239)                 44,209                  67,577                 (10,604)                  56,973 
--------------- 
- financial 
 investments                        10                       -                     10                      15                        -                      15 
--------------- 
- prepayments, 
 accrued income 
 and 
 other assets                   39,169                       -                 39,169                  50,157                        -                  50,157 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  ----------------------- 
Derivatives                    141,221               (139,668)                  1,553                 201,210                (200,137)                   1,073 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
Total on 
 balance sheet 
 exposure 
 to credit risk                445,637               (157,052)                288,585                 518,431                (219,595)                 298,836 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
Total 
 off-balance 
 sheet                         146,261                       -                146,261                 165,368                        -                 165,368 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
- financial and 
 other 
 guarantees(1)                  26,840                       -                 26,840                  18,177                        -                  18,177 
--------------- 
- loan and 
 other 
 credit-related 
 commitments                   119,421                       -                119,421                 147,191                        -                 147,191 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  ----------------------- 
At 31 Dec                      591,898               (157,052)                434,846                 683,799                (219,595)                 464,204 
---------------  ---------------------  ----------------------  ---------------------  ----------------------  -----------------------  ---------------------- 
 

1 'Financial and other guarantees' represents 'Financial guarantees' and 'Performance and other guarantees' as disclosed in Note 30, net of ECL.

 
Maximum exposure to credit risk (continued) 
                                                2021                                                                  2020 
                 ------------------------------------------------------------------  ---------------------------------------------------------------------- 
                              Maximum                                                               Maximum 
                             exposure                  Offset                   Net                exposure                  Offset                     Net 
The bank                         GBPm                    GBPm                  GBPm                    GBPm                    GBPm                    GBPm 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
Loans and 
 advances to 
 customers 
 held at 
 amortised cost                33,936                 (7,047)                26,889                  43,241                 (8,711)                  34,530 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
- personal                      3,674                       -                 3,674                   3,569                       -                   3,569 
--------------- 
- corporate and 
 commercial                    20,874                 (6,224)                14,650                  25,520                 (7,661)                  17,859 
--------------- 
- non-bank 
 financial 
 institutions                   9,388                   (823)                 8,565                  14,152                 (1,050)                  13,102 
---------------  --------------------  ----------------------  --------------------  ----------------------  ---------------------- 
Loans and 
 advances to 
 banks at 
 amortised 
 cost                           6,778                       -                 6,778                   8,063                       -                   8,063 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
Other financial 
 assets held at 
 amortised 
 cost                         135,109                 (9,045)               126,064                 135,948                (10,003)                 125,945 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
- cash and 
 balances at 
 central banks                 63,008                       -                63,008                  48,777                       -                  48,777 
--------------- 
- items in the 
 course of 
 collection 
 from other 
 banks                            211                       -                   211                      37                       -                      37 
--------------- 
- reverse 
 repurchase 
 agreements 
 - non trading                 39,708                 (9,045)                30,663                  50,137                (10,003)                  40,134 
--------------- 
- financial 
 investments                    3,337                       -                 3,337                   2,214                       -                   2,214 
--------------- 
- prepayments, 
 accrued income 
 and 
 other assets                  28,845                       -                28,845                  34,783                       -                  34,783 
---------------  --------------------  ----------------------  --------------------  ----------------------  ---------------------- 
Derivatives                   125,787               (123,964)                 1,823                 182,066               (181,925)                     141 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
Total on 
 balance sheet 
 exposure 
 to credit risk               301,610               (140,056)               161,554                 369,318               (200,639)                 168,679 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
Total 
 off-balance 
 sheet                         41,034                       -                41,034                  54,899                       -                  54,899 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
- financial and 
 other 
 guarantees(1)                  8,592                       -                 8,592                   8,640                       -                   8,640 
--------------- 
- loan and 
 other 
 credit-related 
 commitments                   32,442                       -                32,442                  46,259                       -                  46,259 
---------------  --------------------  ----------------------  --------------------  ----------------------  ---------------------- 
At 31 Dec                     342,644               (140,056)               202,588                 424,217               (200,639)                 223,578 
---------------  --------------------  ----------------------  --------------------  ----------------------  ----------------------  ---------------------- 
 

1 'Financial and other guarantees' represents 'Financial guarantees' and 'Performance and other guarantees' as disclosed in Note 30, net of ECL.

Concentration of exposure

We have a number of businesses with a broad range of products. We operate in a number of markets with the majority of our exposures in UK and France.

For an analysis of:

   --    financial investments, see Note 15 on the financial statements; 
   --    trading assets, see Note 10 on the financial statements; 
   --    derivatives, see page 67 and Note 14 on the financial statements; and 

-- loans and advances by industry sector and by the location of the principal operations of the lending subsidiary or by the location of the lending branch, see page 62 for wholesale lending and page 67 for personal lending.

Credit deterioration of financial instruments

(Audited)

A summary of our current policies and practices regarding the identification, treatment and measurement of stage 1, stage 2 and stage 3 (credit impaired) and POCI financial instruments can be found in Note 1.2 on the financial statements.

 
Measurement uncertainty and sensitivity 
 analysis of ECL estimates 
 

(Audited)

Despite a broad recovery in economic conditions during 2021, ECL estimates continued to be subject to a high degree of uncertainty and management judgements and estimates continue to reflect a degree of caution, both in the selection of economic scenarios and their weightings, and through management judgemental adjustments. Releases of provisions were made progressively as economic conditions recovered and by 31 December 2021 the majority of the 2020 uplift in ECL provisions had been reversed.

The recognition and measurement of ECL involves the use of significant judgement and estimation. We form multiple economic scenarios based on economic forecasts, apply these assumptions to credit risk models to estimate future credit losses, and probability-weight the results to determine an unbiased ECL estimate. Management judgemental adjustments are used to address late-breaking events, data and model limitations, model deficiencies and expert credit judgements.

Methodology

Four economic scenarios are used to capture the current economic environment and to articulate management's view of the range of potential outcomes. Scenarios produced to calculate ECL are aligned to HSBC's top and emerging risks.

In the second quarter of 2020, to ensure that the severe risks associated with the pandemic were appropriately captured, management added a fourth, more severe, scenario to use in the measurement of ECL. Starting in the fourth quarter of 2021, HSBC's methodology has been adjusted so that the use of four scenarios, of which two are Downside scenarios, is the standard approach to ECL calculation.

Three of the scenarios are drawn from consensus forecasts and distributional estimates. The Central scenario is deemed the 'most likely' scenario, and usually attracts the largest probability weighting, while the outer scenarios represent the tails of the distribution, which are less likely to occur. The Central scenario is created using the average of a panel of external forecasters. Consensus Upside and Downside scenarios are created with reference to distributions for select markets that capture forecasters' views of the entire range of outcomes. In the later years of the scenarios, projections revert to long-term consensus trend expectations. In the consensus outer scenarios, reversion to trend expectations is done mechanically with reference to historically observed quarterly changes in the values of macroeconomic variables.

The fourth scenario, Downside 2, is designed to represent management's view of severe downside risks. It is a globally consistent narrative-driven scenario that explores more extreme economic outcomes than those captured by the consensus scenarios. In this scenario, variables do not, by design, revert to long-term trend expectations. They may instead explore alternative states of equilibrium, where economic activity moves permanently away from past trends.

Description of economic scenarios

The economic assumptions presented in this section have been formed by HSBC with reference to external forecasts specifically for the purpose of calculating ECL.

The global economy experienced a recovery in 2021, following an unprecedented contraction in 2020. Restrictions to mobility and travel eased across our key markets, aided by the successful roll-out of vaccination programmes. The emergence of new variants that potentially reduce the efficacy of vaccines remains a risk.

Economic forecasts remain subject to a high degree of uncertainty. Risks to the economic outlook are dominated by the progression of the pandemic, vaccine roll-out and the public policy response. Geopolitical risks also remain significant and include continued differences between the US and other countries with China over a range of economic and strategic defence issues. Continued uncertainty over the long-term economic relationship between the UK and EU also present downside risks.

The scenarios used to calculate ECL in the Annual Report and Accounts 2021 are described below.

The consensus Central scenario

HSBC's Central scenario features a continued recovery in economic growth in 2022 as activity and employment gradually return to the levels reached prior to the outbreak of Covid-19.

Our Central scenario assumes that the stringent restrictions on activity, imposed across several countries and territories in 2020 and early 2021 are not repeated. The new viral strain that emerged late in 2021, Omicron, has only a limited impact on the recovery, according to this scenario. Consumer spending and business investment, supported by elevated levels of private sector savings, are expected to drive the economic recovery as fiscal and monetary policy support recedes.

Regional differences in the speed of economic recovery in the Central scenario reflect differences in the progression of the pandemic, roll-out of vaccination programmes, national level restrictions imposed and scale of support measures. Global GDP is expected to grow by 4.2% in 2022 in the Central scenario and the average rate of global GDP growth is 3.1% over the five-year forecast period. This exceeds the average growth rate over the five-year period prior to the onset of the pandemic.

The key features of our Central scenario are:

-- Economic activity in our top markets continues to recover. GDP grows at a moderate rate and exceeds pre-pandemic levels across all our key markets in 2022.

-- Unemployment declines to levels only slightly higher than existed pre-pandemic, with the exception of France where the downward trend in unemployment, related to structural changes to the labour market, resumes.

-- Covid-19-related fiscal spending recedes in 2022 as fewer restrictions on activity allow fiscal support to be withdrawn. Deficits remain high in several countries as they embark on multi-year investment programmes to support recovery, productivity growth and climate transition.

-- Inflation across many of our key markets remains elevated through 2022. Supply driven price pressures persist through the first half of 2022 before gradually easing. In subsequent years, inflation quickly converges back towards central bank target rates.

-- Policy interest rates in key markets rise gradually over our projection period, in line with economic recovery.

-- The West Texas Intermediate oil price is forecast to average $62 per barrel over the projection period.

In the longer-term, growth reverts back towards similar rates that existed prior to the pandemic, suggesting that the damage to long-term economic prospects is expected to be minimal.

The Central scenario was first created with forecasts available in November, and subsequently updated in December.

The following table describes key macroeconomic variables and the probabilities assigned in the consensus Central scenario.

 
Central scenario 2022-2026 
                                           UK              France 
                              ---------------  ------------------ 
                                            %                   % 
----------------------------  ---------------  ------------------ 
GDP growth rate 
----------------------------  ---------------  ------------------ 
2022: Annual average growth 
 rate                                     5.0                 3.9 
----------------------------  ---------------  ------------------ 
2023: Annual average growth 
 rate                                     2.1                 2.1 
----------------------------  ---------------  ------------------ 
2024: Annual average growth 
 rate                                     1.9                 1.6 
----------------------------  ---------------  ------------------ 
5-year average                            2.5                 2.1 
----------------------------  ---------------  ------------------ 
Unemployment rate 
----------------------------  ---------------  ------------------ 
2022: Annual average rate                 4.5                 8.0 
----------------------------  ---------------  ------------------ 
2023: Annual average rate                 4.3                 7.7 
----------------------------  ---------------  ------------------ 
2024: Annual average rate                 4.2                 7.6 
----------------------------  ---------------  ------------------ 
5-year average                            4.3                 7.7 
----------------------------  ---------------  ------------------ 
House price growth 
----------------------------  ---------------  ------------------ 
2022: Annual average growth 
 rate                                     5.5                 4.9 
----------------------------  ---------------  ------------------ 
2023: Annual average growth 
 rate                                     3.3                 4.6 
----------------------------  ---------------  ------------------ 
2024: Annual average growth 
 rate                                     3.3                 4.0 
----------------------------  ---------------  ------------------ 
5-year average                            3.5                 3.9 
----------------------------  ---------------  ------------------ 
Short-term interest rate 
----------------------------  ---------------  ------------------ 
2022: Annual average rate                 1.0               (0.5) 
----------------------------  ---------------  ------------------ 
2023: Annual average rate                 1.3               (0.3) 
----------------------------  ---------------  ------------------ 
2024: Annual average rate                 1.2               (0.1) 
----------------------------  ---------------  ------------------ 
5-year average                            1.2               (0.2) 
----------------------------  ---------------  ------------------ 
Probability                                60                  60 
----------------------------  ---------------  ------------------ 
 

The graphs comparing the respective Central scenarios in the fourth quarters of 2020 and 2021 reveal the extent of economic dislocation that occurred in 2020 and compare current economic expectations with those held a year ago.

GDP growth: Comparison

UK

Note: Real GDP shown as year-on-year percentage change.

France

Note: Real GDP shown as year-on-year percentage change.

The consensus Upside scenario

Compared with the Central scenario, the consensus Upside scenario features a faster recovery in economic activity during the first two years, before converging to long-run trend expectations.

The scenario is consistent with a number of key upside risk themes. These include the orderly and rapid global abatement of Covid-19 via successful containment and ongoing vaccine efficacy; de-escalation of tensions between the US and China; continued fiscal and monetary support; and smooth relations between the UK and the EU.

The following table describes key macroeconomic variables and the probabilities assigned in the consensus Upside scenario.

 
Consensus Upside scenario best outcome 
                                UK                       France 
                                 %                         % 
--------------------  -----------------------  -------------------------- 
GDP growth rate                   9.9  (1Q22)                 7.0  (2Q22) 
--------------------  ---------------  ------  ------------------  ------ 
Unemployment rate                 3.0  (4Q23)                 6.6  (4Q23) 
--------------------  ---------------  ------  ------------------  ------ 
House price growth                7.4  (2Q23)                 6.8  (2Q22) 
--------------------  ---------------  ------  ------------------  ------ 
Short term interest 
 rate                             0.7  (1Q22)               (0.5)  (1Q22) 
--------------------  ---------------  ------  ------------------  ------ 
Probability                     10                         10 
--------------------  -----------------------  -------------------------- 
 

Note: Extreme point in the consensus Upside is 'best outcome' in the scenario, for example the highest GDP growth and the lowest unemployment rate, in the first two years of the scenario.

Downside scenarios

The progress of the pandemic and the ongoing public policy response continues to be a key source of risk. Downside scenarios assume that new strains of the virus result in an acceleration in infection rates and increased pressure on public health services, necessitating restrictions on activity. The reimposition of such restrictions could be assumed to have a damaging effect on consumer and business confidence.

Government fiscal programmes in advanced economies in 2020 and 2021 were supported by accommodative actions taken by central banks. These measures have provided households and firms with significant support. An inability or unwillingness to continue with such support or the untimely withdrawal of support present a downside risk to growth.

While Covid-19 and related risks dominate the economic outlook, geopolitical risks also present a threat. These risks include:

-- continued differences between the US and other countries with China, which could affect sentiment and restrict global economic activity; and

-- potential disagreements between the UK and the EU, which may hinder the ability to reach a more comprehensive agreement on trade and services, despite the Trade and Cooperation Agreement averting a disorderly UK departure.

The consensus Downside scenario

In the consensus Downside scenario, economic recovery is weaker compared with the Central scenario as key global risks, including Covid-19, escalate. Compared to the Central scenario GDP growth is expected to be lower, unemployment rates rise moderately and asset and commodity prices fall, before gradually recovering towards their long-run trend expectations.

The following table describes key macroeconomic variables and the probabilities assigned in the consensus Downside scenario.

 
Consensus Downside scenario worst 
 outcome 
                                  UK                        France 
                                       %                           % 
--------------------  ------------------  ------  ------------------  ------ 
GDP growth rate                    (0.5)  (3Q23)                 0.5  (4Q23) 
--------------------  ------------------  ------  ------------------  ------ 
Unemployment rate                    5.6  (4Q22)                 9.1  (3Q22) 
--------------------  ------------------  ------  ------------------  ------ 
House price growth                 (4.2)  (1Q23)                 2.0  (4Q22) 
--------------------  ------------------  ------  ------------------  ------ 
Short-term interest 
 rate                                0.2  (4Q23)               (0.5)  (1Q22) 
--------------------  ------------------  ------  ------------------  ------ 
Probability                       15                          15 
--------------------  --------------------------  -------------------------- 
 

Note: Extreme point in the consensus Downside is 'worst outcome' in the scenario, for example lowest GDP growth and the highest unemployment rate, in the first two years of the scenario.

Downside 2 scenario

The Downside 2 scenario features a deep global recession. In this scenario, new Covid-19 variants emerge that cause infections to rise sharply in 2022, resulting in setbacks to vaccination programmes and the rapid imposition of restrictions on mobility and travel across some countries. The scenario also assumes governments and central banks are unable to significantly increase fiscal and monetary support, which results in abrupt corrections in labour and asset markets.

The following table describes key macroeconomic variables and the probabilities assigned in the Downside 2 scenario.

 
Downside 2 scenario worst outcome 
                                    UK                          France 
                                           %                            % 
--------------------  ----------------------  ------  -------------------  ------ 
GDP growth rate                        (4.6)  (4Q22)                (4.6)  (4Q22) 
--------------------  ----------------------  ------  -------------------  ------ 
Unemployment rate                        7.5  (2Q23)                 10.0  (4Q23) 
--------------------  ----------------------  ------  -------------------  ------ 
House price growth                    (14.2)  (2Q23)                (6.0)  (2Q23) 
--------------------  ----------------------  ------  -------------------  ------ 
Short-term interest 
 rate                                    1.6  (2Q22)                  0.4  (2Q22) 
--------------------  ----------------------  ------  -------------------  ------ 
Probability                         15                            15 
--------------------  ------------------------------  --------------------------- 
 

Note: Extreme point in the Downside 2 is 'worst outcome' in the scenario, for example lowest GDP growth and the highest unemployment rate, in the first two years of the scenario.

Scenario weighting

In reviewing the economic conjuncture, the level of uncertainty and risk, management has considered both global and country-specific factors. This has led management to assign scenario probabilities that are tailored to its view of uncertainty in individual markets.

To inform its view, management has considered the progression of the virus in individual countries, the speed of vaccine roll-outs, the degree of current and expected future government support and connectivity with other countries. Management has also been guided by the policy response and economic performance through the pandemic, as well as the evidence that economies have adapted as the virus has progressed.

A key consideration in the fourth quarter was the emergence of the new variant, Omicron. The virulence and severity of the new strain, in addition to the continued efficacy of vaccines against it, was unknown when the variant first emerged. Management therefore determined that uncertainty attached to forecasts had increased and sought to reflect this in scenario weightings.

The UK and France faced the greatest economic uncertainties of our key markets. The emergence of Omicron exacerbated the rise in case rates and hospitalisations in both countries, necessitating the imposition of new restrictions. These increase uncertainties around economic growth and employment. Accordingly, the Central scenario was assigned a 60% weight in both countries. The two Downside scenarios were given a combined probability weighting of 30% for both the UK and France.

The following graphs show the historical and forecasted GDP growth rate for the various economic scenarios in UK and France.

.

UK

France

Critical accounting estimates and judgements

The calculation of ECL under IFRS 9 involves significant judgements, assumptions and estimates. Despite a general recovery in economic conditions during 2021, the level of estimation uncertainty and judgement has remained high during 2021 as a result of the ongoing economic effects of the Covid-19 pandemic and other sources of economic instability, including significant judgements relating to:

-- the selection and weighting of economic scenarios, given rapidly changing economic conditions in an unprecedented manner, uncertainty as to the effect of government and central bank support measures designed to alleviate adverse economic impacts, and a wider distribution of economic forecasts than before the pandemic. The key judgements are the length of time over which the economic effects of the pandemic will occur, and the speed and shape of recovery. The main factors include the effectiveness of pandemic containment measures, the pace of roll-out and effectiveness of vaccines, and the emergence of new variants of the virus, plus a range of geopolitical uncertainties, which together represent a high degree of estimation uncertainty, particularly in assessing Downside scenarios;

-- estimating the economic effects of those scenarios on ECL, where there is no observable historical trend that can be reflected in the models that will accurately represent the effects of the economic changes of the severity and speed brought about by the Covid-19 pandemic and the recovery from those conditions. Modelled assumptions and linkages between economic factors and credit losses may underestimate or overestimate ECL in these conditions, and there is significant uncertainty in the estimation of parameters such as collateral values and loss severity; and

-- the identification of customers experiencing significant increases in credit risk and credit impairment, particularly where those customers have accepted payment deferrals and other reliefs designed to address short-term liquidity issues given muted default experience to date. The use of segmentation techniques for indicators of significant increases in credit risk involves significant estimation uncertainty.

How economic scenarios are reflected in ECL calculations

Models are used to reflect economic scenarios on ECL estimates. As described above, modelled assumptions and linkages based on historical information could not alone produce relevant information under the conditions experienced in 2021, and judgemental adjustments were still required to support modelled outcomes.

We have developed globally consistent methodologies for the application of forward economic guidance into the calculation of ECL for wholesale and retail credit risk. These standard approaches are described below, followed by the management judgemental adjustments made, including those to reflect the circumstances experienced in 2021.

For our wholesale portfolios, a global methodology is used for the estimation of the term structure of probability of default ('PD') and loss given default ('LGD'). For PDs, we consider the correlation of forward economic guidance to default rates for a particular industry in a country. For LGD calculations, we consider the correlation of forward economic guidance to collateral values and realisation rates for a particular country and industry. PDs and LGDs are estimated for the entire term structure of each instrument.

For impaired loans, LGD estimates take into account independent recovery valuations provided by external consultants where available or internal forecasts corresponding to anticipated economic conditions and individual company conditions. In estimating the ECL on impaired loans that are individually considered not to be significant, we incorporate forward economic guidance proportionate to the probability-weighted outcome and the Central scenario outcome for non-stage 3 populations.

For our retail portfolios, the impact of economic scenarios on PD is modelled at a portfolio level. Historical relationships between observed default rates and macroeconomic variables are integrated into IFRS 9 ECL estimates by using economic response models. The impact of these scenarios on PD is modelled over a period equal to the remaining maturity of the underlying asset or assets. The impact on LGD is modelled for mortgage portfolios by forecasting future loan-to-value ('LTV') profiles for the remaining maturity of the asset by using national level forecasts of the house price index and applying the corresponding LGD expectation.

These models are based largely on historical observations and correlations with default rates. Management judgemental adjustments are described below.

Management judgemental adjustments

In the context of IFRS 9, management judgemental adjustments are short-term increases or decreases to the ECL at either a customer, segment or portfolio level to account for late-breaking events, model and data limitations and deficiencies, and expert credit judgement applied following management review and challenge.

At 31 December 2021, management judgements were applied to reflect credit risk dynamics not captured by our models. The drivers of the management judgemental adjustments reflect the changing economic outlook and evolving risks across our geographies.

Where the macroeconomic and portfolio risk outlook continues to improve, supported by low levels of observed defaults, adjustments initially taken to reflect increased risk expectations have been retired or reduced.

However, other adjustments have increased where modelled outcomes are overly sensitive and not aligned to observed changes in the risk of the underlying portfolios during the pandemic, or where sector-specific risks are not adequately captured.

The effect of management judgemental adjustments is considered for balances and ECL when determining whether or not a significant increase in credit risk has occurred and are attributed or allocated to a stage as appropriate. This is in accordance with the internal adjustments framework.

Management judgemental adjustments are reviewed under the governance process for IFRS 9 (as detailed in the section 'Credit risk management' on page 32). Review and challenge focuses on the rationale and quantum of the adjustments with a further review carried out by the second line of defence where significant. For some management judgemental adjustments, internal frameworks establish the conditions under which these adjustments should no longer be required and as such are considered as part of the governance process. This internal governance process allows management judgemental adjustments to be reviewed regularly and, where possible, to reduce the reliance on these through model recalibration or redevelopment, as appropriate.

Management judgemental adjustments made in estimating the scenario-weighted reported ECL at 31 December 2021 are set out in the following table.

The table includes adjustments in relation to data and model limitations, including those driven by late-breaking events and sector-specific risks and as a result of the regular process of model development and implementation.

 
Management judgemental adjustments 
 to ECL at 31 December 2021(1) 
                                           Retail              Wholesale                  Total 
                                             GBPm                   GBPm                   GBPm 
Low-risk counterparties 
 (banks, sovereigns 
 and government entities)                       -                    (4)                    (4) 
---------------------------  --------------------  ---------------------  --------------------- 
Corporate lending 
 adjustments                                    -                     31                     31 
---------------------------  --------------------  ---------------------  --------------------- 
Retail lending probability 
 of default adjustments                         -                      -                      - 
---------------------------  --------------------  ---------------------  --------------------- 
Retail model default 
 timing adjustments                             -                      -                      - 
---------------------------  --------------------  ---------------------  --------------------- 
Macroeconomic-related 
 adjustments                                   17                      -                     17 
---------------------------  --------------------  ---------------------  --------------------- 
Pandemic-related 
 economic recovery 
 adjustments                                    3                      -                      3 
---------------------------  --------------------  ---------------------  --------------------- 
Other retail lending                            -                      -                      - 
 adjustments 
---------------------------  --------------------  ---------------------  --------------------- 
Total                                          20                     27                     47 
---------------------------  --------------------  ---------------------  --------------------- 
 
 
Management judgemental adjustments 
 to ECL at 31 December 2020(1) 
                                            Retail             Wholesale                 Total 
                                              GBPm                  GBPm                  GBPm 
Low-risk counterparties 
 (banks, sovereigns 
 and government entities)                      (5)                     8                     3 
---------------------------  ---------------------  --------------------  -------------------- 
Corporate lending 
 adjustments                                     -                    56                    56 
---------------------------  ---------------------  --------------------  -------------------- 
Retail lending probability 
 of default adjustments                       (10)                     -                  (10) 
---------------------------  ---------------------  --------------------  -------------------- 
Retail model default 
 timing adjustments                              3                     -                     3 
---------------------------  ---------------------  --------------------  -------------------- 
Macroeconomic-related 
 adjustments                                    11                     -                    11 
---------------------------  ---------------------  --------------------  -------------------- 
Pandemic-related 
 economic recovery 
 adjustments                                     -                     -                     - 
---------------------------  ---------------------  --------------------  -------------------- 
Other retail lending 
 adjustments                                     4                     -                     4 
---------------------------  ---------------------  --------------------  -------------------- 
Total                                            3                    64                    67 
---------------------------  ---------------------  --------------------  -------------------- 
 

1 Management judgemental adjustments presented in the table reflect increases or (decreases) to ECL, respectively.

Management judgemental adjustments at 31 December 2021 were an increase to ECL of GBP27m for the wholesale portfolio and an increase to ECL of GBP20m for the retail portfolio.

During 2021, management judgemental adjustments reflected an evolving macroeconomic outlook and the relationship of the modelled ECL to this outlook and to late-breaking and sector-specific risks.

At 31 December 2021, wholesale management judgemental adjustments were an ECL increase of GBP27m (31 December 2020: GBP64m increase).

-- Adjustments relating to low credit-risk exposures decreased ECL by GBP4m at 31 December 2021 (31 December 2020: GBP8m increase). These were mainly to highly rated banks, sovereigns and US government-sponsored entities, where modelled credit factors did not fully reflect the underlying fundamentals of these entities or the effect of government support and economic programmes in the Covid-19 environment. The decrease in adjustment impact relative to 31 December 2020 was mostly driven by increased alignment of modelled outcomes to management expectations following changes in systems and data.

-- Adjustments to corporate exposures increased ECL by GBP31m at 31 December 2021 (31 December 2020: GBP56m increase). These principally reflected the outcome of management judgements for high-risk and vulnerable sectors in some of our key markets, supported by credit experts' input, portfolio risk metrics, quantitative analyses and benchmarks. Considerations include risk of individual exposures under different macroeconomic scenarios and comparison of key risk metrics to pre-pandemic levels, resulting in either releases or increases to ECL. The decrease in adjustment impact relative to 31 December 2020

was mostly driven by management judgements as a result of the effect of further improvement of macroeconomic scenarios on modelled outcomes and increased dislocation of modelled outcomes to management expectations for high-risk sectors and due to late-breaking events not fully reflected in the underlying data.

At 31 December 2021, retail management judgemental adjustments were an ECL increase of GBP20m (31 December 2020: GBP3m increase).

-- Pandemic-related economic recovery adjustments increased ECL by GBP3m (31 December 2020: GBP0) to adjust for the effects of the volatile pace of recovery from the pandemic. This is where in management's judgement, supported by quantitative analyses of portfolio and economic metrics, modelled outcomes are overly sensitive given the limited observed deterioration in the underlying portfolio during the pandemic.

-- Positive macroeconomic-related adjustments have remained broadly stable in comparison to 31 December 2020.

Economic scenarios sensitivity analysis of ECL estimates

Management considered the sensitivity of the ECL outcome against the economic forecasts as part of the ECL governance process by recalculating the ECL under each scenario described above for selected portfolios, applying a 100% weighting to each scenario in turn. The weighting is reflected in both the determination of a significant increase in credit risk and the measurement of the resulting ECL.

The ECL calculated for the Upside and Downside scenarios should not be taken to represent the upper and lower limits of possible ECL outcomes. The impact of defaults that might occur in the future under different economic scenarios is captured by recalculating ECL for loans at the balance sheet date.

There is a particularly high degree of estimation uncertainty in numbers representing more severe risk scenarios when assigned a 100% weighting.

For wholesale credit risk exposures, the sensitivity analysis excludes ECL and financial instruments related to defaulted (stage 3) obligors. It is generally impracticable to separate the effect of macroeconomic factors in individual assessments of obligors in default. The measurement of stage 3 ECL is relatively more sensitive to credit factors specific to the obligor than future economic scenarios, and loans to defaulted obligors are a small portion of the overall wholesale lending exposure, even if representing the majority of the allowance for ECL. Therefore, the sensitivity analysis to macroeconomic scenarios does not capture the residual estimation risk arising from wholesale stage 3 exposures.

For retail credit risk exposures, the sensitivity analysis includes ECL for loans and advances to customers related to defaulted obligors. This is because the retail ECL for secured mortgage portfolios including loans in all stages is sensitive to macroeconomic variables.

Wholesale and retail sensitivity

The wholesale and retail sensitivity analysis is stated inclusive of management judgemental adjustments, as appropriate to each scenario. The results tables exclude portfolios held by the insurance business and small portfolios, and as such cannot be directly compared to personal and wholesale lending presented in other credit risk tables. Additionally, in both the wholesale and retail analysis, the comparative period results for Downside 2 scenarios are also not directly comparable with the current period, because they reflect different risk profiles relative to the consensus scenarios for the period end.

Wholesale analysis

 
IFRS 9 ECL sensitivity to future 
 economic conditions(1,2) 
                                 UK   France 
                               GBPm     GBPm 
--------------------------  -------  ------- 
ECL of loans and advances 
 to customers at 
 31 December 2021 
--------------------------  -------  ------- 
Reported ECL                    104       98 
--------------------------  -------  ------- 
Consensus scenarios 
--------------------------  -------  ------- 
Central scenario                 90       89 
--------------------------  -------  ------- 
Upside scenario                  71       78 
--------------------------  -------  ------- 
Downside scenario               109      120 
--------------------------  -------  ------- 
Downside 2 scenario             189      138 
                                     ------- 
Gross carrying amount(2)    142,450  120,955 
--------------------------  -------  ------- 
 
 
ECL of loans and advances 
 to customers at 
 31 December 2020 
-----------------------------  -------  ------- 
Reported ECL                       317       88 
-----------------------------  -------  ------- 
Consensus scenarios 
-----------------------------  -------  ------- 
Central scenario                   219       82 
-----------------------------  -------  ------- 
Upside scenario                    156       73 
-----------------------------  -------  ------- 
Downside scenario                  339       98 
-----------------------------  -------  ------- 
Additional Downside scenario       657      178 
-----------------------------  -------  ------- 
Gross carrying amount(2)       137,825  123,444 
-----------------------------  -------  ------- 
 

1 ECL sensitivity includes off-balance sheet financial instruments that are subject to significant measurement uncertainty.

2 Includes low credit-risk financial instruments such as debt instruments at FVOCI, which have high carrying amounts but low ECL under all the above scenarios.

Retail analysis

 
IFRS 9 ECL sensitivity to future 
 economic conditions(1) 
                                                     UK                  France 
                                                   GBPm                    GBPm 
-----------------------------  ------------------------  ---------------------- 
ECL of loans and advances 
 to customers at 31 December 
 2021 
Reported ECL                                          5                      91 
                               ------------------------  ---------------------- 
Consensus scenarios 
Central scenario                                      4                      91 
                               ------------------------  ---------------------- 
Upside scenario                                       4                      91 
                               ------------------------  ---------------------- 
Downside scenario                                     5                      92 
                               ------------------------  ---------------------- 
Downside 2 scenario                                  10                      93 
                               ------------------------  ---------------------- 
Gross carrying amount                             2,007                  18,295 
                               ------------------------  ---------------------- 
 
 
IFRS 9 ECL sensitivity to future 
 economic conditions(1) 
                                                   UK               France 
ECL of loans and advances 
 to customers at 
 31 December 2020 
Reported ECL                                       12                  114 
                               ----------------------  ------------------- 
Consensus scenarios 
-----------------------------  ----------------------  ------------------- 
Central scenario                                   11                  113 
-----------------------------  ----------------------  ------------------- 
Upside scenario                                     8                  111 
-----------------------------  ----------------------  ------------------- 
Downside scenario                                  14                  115 
-----------------------------  ----------------------  ------------------- 
Additional Downside scenario                       17                  118 
----------------------------- 
Gross carrying amount                           1,980               19,254 
-----------------------------  ----------------------  ------------------- 
 
   1   ECL sensitivities exclude portfolios utilising less complex modelling approaches. 

Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including loan commitments and financial guarantees

The following disclosure provides a reconciliation by stage of the group's gross carrying/nominal amount and allowances for loans and advances to banks and customers, including loan commitments and financial guarantees. Movements are calculated on a quarterly basis and therefore fully capture stage movements between quarters. If movements were calculated on a year-to-date basis they would only reflect the opening and closing position of the financial instrument. The transfers of financial instruments represent the impact of stage transfers upon the gross carrying/nominal amount and associated allowance for ECL.

The net remeasurement of ECL arising from stage transfers represents the increase or decrease due to these transfers, for example, moving from a 12-month (stage 1) to a lifetime (stage 2) ECL measurement basis. Net remeasurement excludes the underlying customer risk rating ('CRR')/probability of default ('PD') movements of the financial instruments transferring stage. This is captured, along with other credit quality movements in the 'changes in risk parameters - credit quality' line item.

Changes in 'New financial assets originated or purchased', 'Assets derecognised (including final repayments)' and 'Changes to risk parameters - further lending/repayments' represent the impact from volume movements within the group's lending portfolio.

 
Reconciliation of changes in gross carrying/nominal amount and allowances 
 for loans and advances to banks and customers including 
 loan commitments and financial guarantees(1) 
(Audited) 
                                                   Non credit - impaired                                                                  Credit - impaired 
                                      Stage 1                                   Stage 2                                  Stage 3                                     POCI                                       Total 
                                                                            Gross                                   Gross                                        Gross 
                                    Gross             Allowance         carrying/             Allowance         carrying/              Allowance             carrying/              Allowance               Gross             Allowance 
                         carrying/nominal                   for           nominal                   for           nominal                    for               nominal                    for    carrying/nominal                   for 
                                   amount                   ECL            amount                   ECL            amount                    ECL                amount                    ECL              amount                   ECL 
The group                            GBPm                  GBPm              GBPm                  GBPm              GBPm                   GBPm                  GBPm                   GBPm                GBPm                  GBPm 
                     --------------------  --------------------  ----------------  --------------------  ----------------  ---------------------                        ---------------------                      -------------------- 
At 1 Jan 2021                     184,715                 (180)            31,726                 (378)             3,352                (1,050)                    40                   (12)             219,833               (1,620) 
                     --------------------                        ----------------                        ----------------  ---------------------                        --------------------- 
Transfers of 
 financial 
 instruments                        5,245                  (66)           (5,617)                    90               372                   (24)                     -                      -                   -                     - 
                     --------------------                        ----------------                        ----------------  ---------------------                        --------------------- 
- Transfers from 
 Stage 1 to Stage 
 2                                (8,431)                    14             8,431                  (14)                 -                      -                     -                      -                   -                     - 
- Transfers from 
 Stage 2 to Stage 
 1                                 13,714                  (78)          (13,714)                    78                 -                      -                     -                      -                   -                     - 
- Transfers to 
 Stage 
 3                                   (93)                     -             (401)                    28               494                   (28)                     -                      -                   -                     - 
- Transfers from 
 Stage 3                               55                   (2)                67                   (2)             (122)                      4                     -                      -                   -                     - 
                     --------------------                        ----------------                                          ---------------------                        --------------------- 
Net remeasurement 
 of ECL arising 
 from 
 transfer of stage                      -                    43                 -                  (22)                 -                    (5)                     -                      -                   -                    16 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
New financial 
 assets 
 originated or 
 purchased                         72,348                  (55)                 -                     -                 -                      -                     -                      -              72,348                  (55) 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
Asset derecognised 
 (including final 
 repayments)                     (57,098)                     6           (3,481)                    32             (454)                     95                   (3)                      2            (61,036)                   135 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
Changes to risk 
 parameters - 
 further 
 lending/repayments              (16,766)                    76           (3,927)                    62             (213)                     40                  (29)                      2            (20,935)                   180 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
Changes to risk 
 parameters - 
 credit 
 quality                                -                    54                 -                     7                 -                  (176)                     -                      -                   -                 (115) 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
Changes to model 
 used for ECL 
 calculation                            -                     2                 -                     9                 -                      -                     -                      -                   -                    11 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
Assets written off                      -                     -                 -                     -             (152)                    152                   (5)                      5               (157)                   157 
                                                                                                         ----------------  ---------------------                        --------------------- 
Credit related 
modifications 
that resulted in 
derecognition                           -                     -                 -                     -                 -                      -                     -                      -                   -                     - 
                                                                 ----------------                        ----------------  ---------------------                        --------------------- 
Foreign exchange                  (7,512)                     2           (1,060)                    10             (126)                     46                   (1)                      1             (8,699)                    59 
                                                                                                         ----------------  ---------------------                        --------------------- 
Others(2)                         (1,320)                     -             (170)                     2                 -                    (1)                     -                      -             (1,490)                     1 
                                                                                                         ----------------  ---------------------                        --------------------- 
At 31 Dec 2021                    179,612                 (118)            17,471                 (188)             2,779                  (923)                     2                    (2)             199,864               (1,231) 
                     --------------------                        ----------------                        ----------------  ---------------------                        --------------------- 
ECL income 
 statement 
 release/(charge) 
 for the period                                             126                                      88                                     (46)                                            4                                       172 
                                                                                                                           ---------------------                        --------------------- 
Recoveries                                                                                                                                                                                                                            3 
                     --------------------  --------------------  ----------------  --------------------                    ---------------------                        --------------------- 
Others                                                                                                                                                                                                                             (23) 
                     --------------------  --------------------  ----------------  --------------------                    ---------------------                        --------------------- 
Total ECL income 
 statement release 
 for the period                                                                                                                                                                                                                     152 
                                           --------------------                    --------------------  ---------------- 
 
 
                                                   At 31 Dec 2021                                                                                     12 months ended 
                                                                                                                                                          31 Dec 2021 
                                     Gross carrying/nominal                              Allowance 
                                                     amount                                for ECL                                               ECL release/(charge) 
                                                       GBPm                                   GBPm                                                               GBPm 
                                                             ------------------------------------- 
As above                                            199,864                                (1,231)                                                                152 
                                                             ------------------------------------- 
Other financial                                     202,137                                    (9)                                                                (1) 
assets measured 
at 
amortised cost 
                                                             ------------------------------------- 
Non-trading                                          30,005                                      -                                                                  - 
reverse purchase 
agreement 
commitments 
                                                             ------------------------------------- 
Performance and other guarantees not 
 considered for IFRS 9                                                                                                                                             18 
Summary of 
 financial 
 instruments to 
 which the 
 impairment 
 requirements 
 in IFRS 9 are 
 applied/Summary 
 consolidated 
 income 
 statement                                          432,006                                (1,240)                                                                169 
                                                             ------------------------------------- 
Debt instruments                                     41,188                                   (19)                                                                  5 
 measured at 
 FVOCI 
                                                             ------------------------------------- 
Total allowance                                         n/a                                (1,259)                                                                174 
 for ECL/total 
 income 
 statement ECL 
 release for the 
 period 
                                                             ------------------------------------- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2021, these amounted to GBP(1)bn and were classified as Stage 1 with no ECL.

 
Reconciliation of changes in gross carrying/nominal amount and allowances 
 for loans and advances to banks and customers including 
 loan commitments and financial guarantees(1) (continued) 
(Audited) 
                                                     Non credit - impaired                                                                     Credit - impaired 
                                                           Stage 1                                  Stage 2                                   Stage 3                                         POCI                                     Total 
                                                                               Gross                                     Gross                                        Gross 
                                      Gross              Allowance         carrying/              Allowance          carrying/              Allowance             carrying/              Allowance                Gross            Allowance 
                           carrying/nominal                    for           nominal                    for            nominal                    for               nominal                    for     carrying/nominal                  for 
                                     amount                    ECL            amount                    ECL             amount                    ECL                amount                    ECL               amount                  ECL 
The group                              GBPm                   GBPm              GBPm                   GBPm               GBPm                   GBPm                  GBPm                   GBPm                 GBPm                 GBPm 
                     ----------------------                                                                                                                                                                              ------------------- 
At 1 Jan 2020                       195,249                  (132)            11,103                  (143)              2,235                  (796)                    78                   (33)              208,665              (1,104) 
                     ----------------------                         ----------------                                            ---------------------                        ---------------------                       ------------------- 
Transfers of 
 financial 
 instruments:                      (19,123)                   (62)            16,792                     93              2,331                   (31)                     -                      -                    -                    - 
                     ----------------------                         ----------------                                            ---------------------                        ---------------------                       ------------------- 
- Transfers from 
 Stage 1 to Stage 
 2                                 (31,600)                     54            31,600                   (54)                  -                      -                     -                      -                    -                    - 
- Transfers from 
 Stage 2 to Stage 
 1                                   12,821                  (121)          (12,821)                    121                  -                      -                     -                      -                    -                    - 
- Transfers to 
 Stage 
 3                                    (351)                      7           (2,147)                     32              2,498                   (39)                     -                      -                    -                    - 
- Transfers from 
 Stage 3                                  7                    (2)               160                    (6)              (167)                      8                     -                      -                    -                    - 
                     ----------------------                         ----------------                                            ---------------------                        --------------------- 
Net remeasurement 
 of ECL arising 
 from 
 transfer of stage                        -                     60                 -                   (67)                  -                    (2)                     -                      -                    -                  (9) 
New financial 
 assets 
 originated or 
 purchased                           95,477                   (62)                 -                      -                  -                      -                    10                    (1)               95,487                 (63) 
Asset derecognised 
 (including final 
 repayments)                       (72,860)                      6           (2,553)                     21              (998)                    139                  (16)                      1             (76,427)                  167 
                     ----------------------                                                                                                                                                                              ------------------- 
Changes to risk 
 parameters - 
 further 
 lending/repayments                (21,912)                     48             5,666                      6               (41)                    101                  (11)                    (2)             (16,298)                  153 
                     ----------------------                                                                                                                                                                              ------------------- 
Changes to risk 
 parameters - 
 credit 
 quality                                  -                   (53)                 -                  (248)                  -                  (687)                     -                      -                    -                (988) 
                     ----------------------                                                                                                                                                                              ------------------- 
Changes to model 
 used for ECL 
 calculation                              -                     10                 -                   (36)                  -                      -                     -                      -                    -                 (26) 
                     ----------------------                                                                                                                                                                              ------------------- 
Assets written off                        -                      -                 -                      -              (252)                    252                  (23)                     23                (275)                  275 
                     ----------------------                         ----------------                                            ---------------------                        ---------------------                       ------------------- 
Credit related 
 modifications 
 that resulted in 
 derecognition                            -                      -                 -                      -               (18)                      5                     -                      -                 (18)                    5 
                     ----------------------                                                                                                                                                                              ------------------- 
Foreign exchange                      6,058                      5               498                    (3)                 95                   (33)                     2                      -                6,653                 (31) 
                     ----------------------                         ----------------                                            ---------------------                        ---------------------                       ------------------- 
Others(2)                             1,826                      -               220                    (1)                  -                      2                     -                      -                2,046                    1 
                     ----------------------                         ----------------                                            ---------------------                        ---------------------                       ------------------- 
At 31 Dec 2020                      184,715                  (180)            31,726                  (378)              3,352                (1,050)                    40                   (12)              219,833              (1,620) 
                     ----------------------                         ----------------                                            ---------------------                        ---------------------                       ------------------- 
ECL Income 
 statement 
 charge for the 
 period                                                          9                                    (324)                                     (449)                                          (2)                                     (766) 
                                                                                                                                                                                                                         ------------------- 
Recoveries                                                                                                                                                                                                                                 2 
                     ----------------------                                                                                                                                                                              ------------------- 
Others                                                                                                                                                                                                                                  (17) 
                     ----------------------                                                                                                                                                                              ------------------- 
Total ECL income 
 statement charge 
 for the period                                                                                                                                                                                                                        (781) 
                                                                                                                                                                                                                         ------------------- 
 
 
                                                   At 31 Dec 2020                                                                                     12 months ended 
                                                                                                                                                          31 Dec 2020 
                                      Gross carrying/nominal                             Allowance 
                                                      amount                               for ECL                                                         ECL charge 
                                                        GBPm                                  GBPm                                                               GBPm 
As above                                             219,833                               (1,620)                                                              (781) 
                                                              ------------------------------------ 
Other financial                                      202,763                                  (12)                                                                (2) 
assets measured 
at 
amortised cost 
                                                              ------------------------------------ 
Non-trading                                           42,794                                     -                                                                  - 
reverse purchase 
agreement 
commitments 
                                                              ------------------------------------ 
Performance and other guarantees not 
 considered for IFRS 9                                                                                                                                           (17) 
Summary of 
 financial 
 instruments to 
 which the 
 impairment 
 requirements 
 in IFRS 9 are 
 applied/Summary 
 consolidated 
 income 
 statement                                           465,390                               (1,632)                                                              (800) 
Debt instruments                                      51,713                                  (22)                                                                (8) 
 measured at 
 FVOCI 
                                                              ------------------------------------ 
Total allowance                                          n/a                               (1,654)                                                              (808) 
 for ECL/total 
 income 
 statement ECL 
 charge for the 
 period 
                                                              ------------------------------------ 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2020, these amounted to GBP2bn and were classified as Stage 1 with no ECL.

 
Reconciliation of changes in gross carrying/nominal amount and allowances 
 for loans and advances to banks and customers including 
 loan commitments and financial guarantees(1) 
(Audited) 
                                                    Non credit - impaired                                                                    Credit - impaired 
                                      Stage 1                                    Stage 2                                    Stage 3                                      POCI                                       Total 
                                                                              Gross                                     Gross                                        Gross 
                                    Gross             Allowance           carrying/             Allowance           carrying/              Allowance             carrying/              Allowance               Gross             Allowance 
                         carrying/nominal                   for             nominal                   for             nominal                    for               nominal                    for    carrying/nominal                   for 
                                   amount                   ECL              amount                   ECL              amount                    ECL                amount                    ECL              amount                   ECL 
The bank                             GBPm                  GBPm                GBPm                  GBPm                GBPm                   GBPm                  GBPm                   GBPm                GBPm                  GBPm 
                     --------------------  --------------------  ------------------  --------------------  ------------------  ---------------------                        ---------------------                      -------------------- 
At 1 Jan 2021                      78,422                 (121)              14,161                 (213)               1,395                  (363)                     2                    (2)              93,980                 (699) 
                     --------------------                        ------------------                        ------------------  ---------------------                        --------------------- 
Transfers of 
 financial 
 instruments                        4,795                  (27)             (4,840)                    39                  45                   (12)                     -                      -                   -                     - 
                     --------------------                        ------------------                        ------------------  ---------------------                        --------------------- 
- Transfers from 
 Stage 1 to Stage 
 2                                (2,261)                     3               2,261                   (3)                   -                      -                     -                      -                   -                     - 
- Transfers from 
 Stage 2 to Stage 
 1                                  7,043                  (29)             (7,043)                    29                   -                      -                     -                      -                   -                     - 
- Transfers to 
 Stage 
 3                                      -                     -                (59)                    13                  59                   (13)                     -                      -                   -                     - 
- Transfers from 
 Stage 3                               13                   (1)                   1                     -                (14)                      1                     -                      -                   -                     - 
                     --------------------                        ------------------                                            ---------------------                        --------------------- 
Net remeasurement 
 of ECL arising 
 from 
 transfer of stage                      -                    13                   -                   (1)                   -                    (1)                     -                      -                   -                    11 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
New financial 
 assets 
 originated or 
 purchased                         11,532                  (31)                   -                     -                   -                      -                     -                      -              11,532                  (31) 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
Asset derecognised 
 (including final 
 repayments)                     (11,861)                     2             (1,836)                    17                (80)                      4                   (2)                      1            (13,779)                    24 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
Changes to risk 
 parameters - 
 further 
 lending/repayments              (13,051)                    58             (1,813)                    32               (190)                      4                     -                      -            (15,054)                    94 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
Changes to risk 
 parameters - 
 credit 
 quality                                -                    48                   -                    59                   -                     13                     -                      -                   -                   120 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
Changes to model 
 used for ECL 
 calculation                            -                     2                   -                     9                   -                      -                     -                      -                   -                    11 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
Assets written off                      -                     -                   -                     -                (78)                     78                   (1)                      1                (79)                    79 
                     --------------------                        ------------------                        ------------------  ---------------------                        --------------------- 
Credit related 
modifications 
that resulted in 
derecognition                           -                     -                   -                     -                   -                      -                     -                      -                   -                     - 
                                                                 ------------------                        ------------------  ---------------------                        --------------------- 
Foreign exchange                     (76)                     -                (15)                     -                 (4)                      1                     -                      -                (95)                     1 
                     --------------------                        ------------------                        ------------------  ---------------------                        --------------------- 
Others(2)                         (4,051)                     -                   -                     -                   -                      -                     -                      -             (4,051)                     - 
                     --------------------                        ------------------                        ------------------  ---------------------                        --------------------- 
At 31 Dec 2021                     65,710                  (56)               5,657                  (58)               1,088                  (276)                   (1)                      -              72,454                 (390) 
                     --------------------                        ------------------                        ------------------  ---------------------                        --------------------- 
ECL income 
 statement 
 release for the 
 period                                                      92                                       116                                         20                                            1                                       229 
                                                                                                                               ---------------------                        --------------------- 
Recoveries                                                                                                                                                                                                                                1 
                     --------------------  --------------------  ------------------  --------------------                      ---------------------                        --------------------- 
Others                                                                                                                                                                                                                                 (23) 
                     --------------------  --------------------  ------------------  --------------------                      ---------------------                        --------------------- 
Total ECL income 
 release for the 
 period                                                                                                                                                                                                                                 207 
                                           --------------------                      --------------------  ------------------ 
 
 
                                                    At 31 Dec 2021                                                                                     12 months ended 
                                                                                                                                                           31 Dec 2021 
                                      Gross carrying/nominal                                Allowance 
                                                      amount                                  for ECL                                                      ECL release 
                                                        GBPm                                     GBPm                                                             GBPm 
As above                                              72,454                                    (390)                                                              207 
                                                              --------------------------------------- 
Other financial                                      135,033                                      (1)                                                                1 
assets measured 
at 
amortised cost 
                                                              --------------------------------------- 
Non-trading                                            1,139                                        -                                                                - 
reverse purchase 
agreement 
commitments 
                                                              --------------------------------------- 
Performance and other guarantees not 
 considered for IFRS 9                                                                                                                                               4 
Summary of 
 financial 
 instruments to 
 which the 
 impairment 
 requirements 
 in IFRS 9 are 
 applied/Summary 
 consolidated 
 income 
 statement                                           208,626                                    (391)                                                              212 
Debt instruments                                      23,152                                      (4)                                                                5 
 measured at 
 FVOCI 
                                                              --------------------------------------- 
Total allowance                                          n/a                                    (395)                                                              217 
 for ECL/total 
 income 
 statement ECL 
 release for the 
 period 
                                                              --------------------------------------- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2021, these amounted to GBP(4)bn and were classified as Stage 1 with no ECL.

 
Reconciliation of changes in gross carrying/nominal amount and allowances 
 for loans and advances to banks and customers including 
 loan commitments and financial guarantees(1) (continued) 
(Audited) 
                                                     Non-credit - impaired                                                                     Credit - impaired 
                                       Stage 1                                     Stage 2                                    Stage 3                                      POCI                                        Total 
                                                                   ----------------------------------------  ----------------------------------------- 
                                                                               Gross                                      Gross                                        Gross 
                                      Gross             Allowance          carrying/              Allowance           carrying/              Allowance             carrying/             Allowance/                Gross             Allowance/ 
                           carrying/nominal                   for            nominal                    for             nominal                    for               nominal                    for     carrying/nominal                    for 
                                     amount                   ECL             amount                    ECL              amount                    ECL                amount                    ECL               amount                    ECL 
The bank                               GBPm                  GBPm               GBPm                   GBPm                GBPm                   GBPm                  GBPm                   GBPm                 GBPm                   GBPm 
                     ---------------------- 
At 1 Jan 2020                        94,937                  (77)              4,582                   (77)                 753                  (242)                    38                   (24)              100,310                  (420) 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
Transfers of 
 financial 
 instruments:                      (12,397)                  (27)             11,422                     47                 975                   (20)                     -                      -                    -                      - 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
- Transfers from 
 Stage 1 to Stage 
 2                                 (17,892)                    36             17,892                   (36)                   -                      -                     -                      -                    -                      - 
- Transfers from 
 Stage 2 to Stage 
 1                                    5,676                  (68)            (5,676)                     68                   -                      -                     -                      -                    -                      - 
- Transfers to 
 Stage 
 3                                    (183)                     5              (845)                     17               1,028                   (22)                     -                      -                    -                      - 
- Transfers from 
 Stage 3                                  2                     -                 51                    (2)                (53)                      2                     -                      -                    -                      - 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
Net remeasurement 
 of ECL arising 
 from 
 transfer of stage                        -                    26                  -                   (34)                   -                      -                     -                      -                    -                    (8) 
New financial 
 assets 
 originated or 
 purchased                           14,911                  (43)                  -                      -                   -                      -                     -                      -               14,911                   (43) 
Asset derecognised 
 (including final 
 repayments)                        (7,687)                     2              (666)                      2               (167)                      9                  (15)                      1              (8,535)                     14 
                     ---------------------- 
Changes to risk 
 parameters - 
 further 
 lending/repayments                 (5,898)                    35            (1,201)                     13                (25)                    (9)                     2                    (3)              (7,122)                     36 
                     ---------------------- 
Changes to risk 
 parameters - 
 credit 
 quality                                  -                  (54)                  -                  (129)                   -                  (232)                     -                      1                    -                  (414) 
                     ---------------------- 
Changes to model 
 used for ECL 
 calculation                              -                    10                  -                   (36)                   -                      -                     -                      -                    -                   (26) 
                     ---------------------- 
Assets written off                        -                     -                  -                      -               (118)                    118                  (23)                     23                (141)                    141 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
Credit related 
 modifications 
 that resulted in 
 derecognition                            -                     -                  -                      -                (16)                      4                     -                      -                 (16)                      4 
                     ---------------------- 
Foreign exchange                       (60)                     7                 24                      1                 (2)                      4                     -                      -                 (38)                     12 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
Others(2)                           (5,384)                     -                  -                      -                 (5)                      5                     -                      -              (5,389)                      5 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
At 31 Dec 2020                       78,422                 (121)             14,161                  (213)               1,395                  (363)                     2                    (2)               93,980                  (699) 
                     ----------------------                        -----------------                                             ---------------------                        --------------------- 
ECL income 
 statement 
 charge for the 
 period                                                      (24)                                     (184)                                      (232)                                          (1)                                       (441) 
Recoveries                                                                                                                                                                                                                                    - 
Others                                                                                                                                                                                                                                     (12) 
Total ECL income 
 statement charge 
 for the period                                                                                                                                                                                                                           (453) 
 

.

 
                                                                                                                                                          12 months ended 
                                                     At 31 Dec 2020                                                                                           31 Dec 2020 
                                        Gross carrying/nominal                                Allowance 
                                                        amount                                  for ECL                                                        ECL charge 
                                                          GBPm                                     GBPm                                                              GBPm 
As above                                                93,980                                    (699)                                                             (453) 
Other financial                                        135,900                                      (1)                                                                 4 
assets measured 
at 
amortised cost 
Non-trading                                              4,747                                        -                                                                 - 
reverse purchase 
agreement 
commitments 
Performance and other guarantees not 
 considered for IFRS 9                                                                                                                                                (3) 
Summary of 
 financial 
 instruments to 
 which the 
 impairment 
 requirements 
 in IFRS 9 are 
 applied/Summary 
 consolidated 
 income 
 statement                                             234,627                                    (700)                                                             (452) 
Debt instruments                                        28,699                                      (9)                                                               (5) 
 measured at 
 FVOCI 
Total allowance                                            n/a                                    (709)                                                             (457) 
 for ECL/total 
 income 
 statement ECL 
 charge for the 
 period 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2020, these amounted to GBP(5)bn and were classified as Stage 1 with no ECL.

Credit quality

Credit quality of financial instruments

(Audited)

We assess the credit quality of all financial instruments that are subject to credit risk. The credit quality of financial instruments is a point-in-time assessment of the probability of default ('PD'), whereas stages 1 and 2 are determined based on relative deterioration of credit quality since initial recognition.

Accordingly, for non-credit-impaired financial instruments, there is no direct relationship between the credit quality assessment and stages 1 and 2, though typically the lower credit quality bands exhibit a higher proportion in stage 2.

The five credit quality classifications each encompass a range of granular internal credit rating grades assigned to wholesale and personal lending businesses and the external ratings attributed by external agencies to debt securities, as shown in the table on page 33.

 
Distribution of financial instruments by credit quality at 31 December 
 2021 
(Audited) 
                                                                             Gross carrying/notional amount 
                                                                                                                 Sub-                    Credit                                         Allowance 
                                   Strong                    Good              Satisfactory                  standard                  impaired                   Total                   for ECL                     Net 
The group                            GBPm                    GBPm                      GBPm                      GBPm                      GBPm                    GBPm                      GBPm                    GBPm 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
In-scope for 
IFRS 9 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Loans and 
 advances 
 to customers 
 held at 
 amortised cost                    41,339                  20,531                    23,469                     4,512                     2,480                  92,331                   (1,154)                  91,177 
- personal                         18,956                   4,136                     1,793                        56                       453                  25,394                     (163)                  25,231 
- corporate and 
 commercial                        16,533                  13,867                    19,597                     4,305                     1,785                  56,087                     (964)                  55,123 
- non-bank 
 financial 
 institutions                       5,850                   2,528                     2,079                       151                       242                  10,850                      (27)                  10,823 
Loans and 
 advances 
 to banks held 
 at amortised 
 cost                               8,649                     320                     1,815                         5                         -                  10,789                       (5)                  10,784 
Cash and 
 balances at 
 central banks                    108,133                     198                       151                         -                         -                 108,482                         -                 108,482 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Items in the 
 course 
 of collection 
 from 
 other banks                          343                       -                         3                         -                         -                     346                         -                     346 
Reverse 
 repurchase 
 agreements - 
 non-trading                       47,071                   6,355                     1,022                         -                         -                  54,448                         -                  54,448 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Financial 
 investments                            2                       -                         8                         -                         -                      10                         -                      10 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Prepayments, 
 accrued 
 income and 
 other assets                      36,558                     666                     1,574                        11                        42                  38,851                       (9)                  38,842 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
- endorsements 
 and 
 acceptances                          105                      61                        23                         -                         7                     196                         -                     196 
- accrued 
 income and 
 other                             36,453                     605                     1,551                        11                        35                  38,655                       (9)                  38,646 
Debt 
 instruments 
 measured 
 at fair value 
 through 
 other 
 comprehensive 
 income(1)                         36,410                   1,899                     1,406                       118                         -                  39,833                      (19)                  39,814 
Out-of-scope 
for IFRS 
9 
Trading assets                     28,110                   5,331                     8,985                       350                         -                  42,776                         -                  42,776 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Other financial 
 assets 
 designated and 
 otherwise 
 mandatorily 
 measured 
 at fair value 
 through 
 profit or loss                     2,246                     304                     2,644                         3                         -                   5,197                         -                   5,197 
Derivatives                       111,471                  25,487                     4,054                       207                         2                 141,221                         -                 141,221 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Total gross 
 carrying 
 amount on 
 balance sheet                    420,332                  61,091                    45,131                     5,206                     2,524                 534,284                   (1,187)                 533,097 
Percentage of 
 total 
 credit quality                     78.7%                   11.4%                      8.4%                      1.0%                      0.5%                  100.0% 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ---------------------- 
Loans and other 
 credit-related 
 commitments                       71,741                  21,860                    20,018                     1,874                       202                 115,695                      (55)                 115,640 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Financial 
 guarantees                         8,412                   1,088                     1,245                       210                        99                  11,054                      (17)                  11,037 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
In-scope: 
 Irrevocable 
 loan 
 commitments 
 and 
 financial 
 guarantees                        80,153                  22,948                    21,263                     2,084                       301                 126,749                      (72)                 126,677 
Loans and other 
 credit-related 
 commitments                        2,134                   1,114                       432                        94                         7                   3,781                         -                   3,781 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Performance and 
 other 
 guarantees                         7,738                   4,359                     3,130                       490                       116                  15,833                      (31)                  15,802 
                 ------------------------  ----------------------  ------------------------  ------------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Out-of-scope: 
 Revocable 
 loan 
 commitments 
 and 
 non-financial 
 guarantees                         9,872                   5,473                     3,562                       584                       123                  19,614                      (31)                  19,583 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments by credit quality at 31 December 
 2020 (continued) 
(Audited) 
                                                                              Gross carrying/notional amount 
                                                                                                                  Sub-                    Credit                                           Allowance 
                                   Strong                      Good              Satisfactory                 standard                  impaired                    Total                    for ECL                      Net 
The group                            GBPm                      GBPm                      GBPm                     GBPm                      GBPm                     GBPm                       GBPm                     GBPm 
                                                                                               ----------------------- 
In-scope for 
IFRS 9 
Loans and 
 advances 
 to customers 
 held at 
 amortised cost                    43,077                    24,780                    26,477                    5,619                     3,007                  102,960                    (1,469)                  101,491 
- personal                         19,232                     4,341                     2,251                      141                       534                   26,499                      (208)                   26,291 
- corporate and 
 commercial                        16,340                    17,132                    22,330                    5,023                     2,162                   62,987                    (1,168)                   61,819 
- non-bank 
 financial 
 institutions                       7,505                     3,307                     1,896                      455                       311                   13,474                       (93)                   13,381 
                                                                                               ----------------------- 
Loans and 
 advances 
 to banks held 
 at amortised 
 cost                              10,518                       721                     1,412                       11                         -                   12,662                       (16)                   12,646 
Cash and 
 balances at 
 central banks                     84,964                         -                       129                        -                         -                   85,093                        (1)                   85,092 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
Items in the 
 course 
 of collection 
 from 
 other banks                          240                         -                         3                        -                         -                      243                          -                      243 
Reverse 
 repurchase 
 agreements - 
 non-trading                       57,282                     8,370                     1,920                        5                         -                   67,577                          -                   67,577 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
Financial 
 investments                            2                         -                        13                        -                         -                       15                          -                       15 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
Prepayments, 
 accrued 
 income and 
 other assets                      47,928                       566                     1,285                       17                        39                   49,835                       (11)                   49,824 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
- endorsements 
 and 
 acceptances                           62                         2                        31                        2                         2                       99                        (1)                       98 
- accrued 
 income and 
 other                             47,866                       564                     1,254                       15                        37                   49,736                       (10)                   49,726 
                                                                                               ----------------------- 
Debt 
 instruments 
 measured 
 at fair value 
 through 
 other 
 comprehensive 
 income(1)                         46,029                     2,487                       405                      153                         -                   49,074                       (22)                   49,052 
Out-of-scope 
for IFRS 
9 
Trading assets                     34,302                     5,996                     9,493                      410                         -                   50,201                          -                   50,201 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
Other financial 
 assets 
 designated and 
 otherwise 
 mandatorily 
 measured 
 at fair value 
 through 
 profit or loss                     2,460                     1,152                       587                        4                         -                    4,203                          -                    4,203 
Derivatives                       165,868                    30,113                     4,299                      890                        40                  201,210                          -                  201,210 
Total gross 
 carrying 
 amount on 
 balance sheet                    492,670                    74,185                    46,023                    7,109                     3,086                  623,073                    (1,519)                  621,554 
                 ------------------------  ------------------------  ------------------------                           ------------------------  -----------------------  -------------------------  ----------------------- 
Percentage of 
 total 
 credit quality                       79%                       12%                        8%                       1%                         -                     100% 
                 ------------------------  ------------------------  ------------------------                           ------------------------  ----------------------- 
Loans and other 
 credit-related 
 commitments                       97,281                    26,361                    17,081                    2,047                       266                  143,036                      (112)                  142,924 
Financial 
 guarantees                         1,340                     1,153                     1,020                      334                       122                    3,969                       (23)                    3,946 
                 ------------------------  ------------------------  ------------------------                           ------------------------  -----------------------  -------------------------  ----------------------- 
In-scope: 
 Irrevocable 
 loan 
 commitments 
 and 
 financial 
 guarantees                        98,621                    27,514                    18,101                    2,381                       388                  147,005                      (135)                  146,870 
Loans and other 
 credit-related 
 commitments                        2,525                       986                       578                      177                         1                    4,267                          -                    4,267 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
Performance and 
 other 
 guarantees                         6,728                     3,808                     3,145                      422                       179                   14,282                       (51)                   14,231 
                 ------------------------  ------------------------  ------------------------  -----------------------  ------------------------  -----------------------  -------------------------  ----------------------- 
Out-of-scope: 
 Revocable 
 loan 
 commitments 
 and 
 non-financial 
 guarantees                         9,253                     4,794                     3,723                      599                       180                   18,549                       (51)                   18,498 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments by credit quality at 31 December 
 2021 
(Audited) 
                                                                          Gross carrying/notional amount 
                                                                                                             Sub-                    Credit                                       Allowance 
                                 Strong                    Good            Satisfactory                  standard                  impaired                 Total                   for ECL                   Net 
The bank                           GBPm                    GBPm                    GBPm                      GBPm                      GBPm                  GBPm                      GBPm                  GBPm 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
In-scope for 
IFRS 9 
Loans and 
 advances 
 to customers 
 held at 
 amortised cost                  16,993                   9,038                   6,467                       804                       984                34,286                     (350)                33,936 
- personal                        1,909                     850                     860                        13                        48                 3,680                       (6)                 3,674 
- corporate and 
 commercial                       8,120                   6,649                   5,003                       729                       681                21,182                     (308)                20,874 
- non-bank 
 financial 
 institutions                     6,964                   1,539                     604                        62                       255                 9,424                      (36)                 9,388 
Loans and 
 advances 
 to banks held 
 at amortised 
 cost                             6,427                     166                     187                         2                         -                 6,782                       (4)                 6,778 
Cash and 
 balances at 
 central banks                   63,008                       -                       -                         -                         -                63,008                         -                63,008 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Items in the 
 course 
 of collection 
 from 
 other banks                        211                       -                       -                         -                         -                   211                         -                   211 
Reverse 
 repurchase 
 agreements - 
 non-trading                     32,877                   5,916                     915                         -                         -                39,708                         -                39,708 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Financial 
 investments                      3,337                       -                       -                         -                         -                 3,337                         -                 3,337 
Prepayments, 
 accrued 
 income and 
 other assets                    28,524                     121                      94                         2                        28                28,769                       (1)                28,768 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
- endorsements 
 and 
 acceptances                         90                      61                      13                         -                         7                   171                         -                   171 
- accrued 
 income and 
 other                           28,434                      60                      81                         2                        21                28,598                       (1)                28,597 
Debt 
 instruments 
 measured 
 at fair value 
 through 
 other 
 comprehensive 
 income(1)                       21,748                      64                   1,039                         -                         -                22,851                       (4)                22,847 
Out-of-scope 
for IFRS 
9 
Trading assets                   18,318                   5,082                   8,470                       350                         -                32,220                         -                32,220 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Other financial 
 assets 
 designated and 
 otherwise 
 mandatorily 
 measured 
 at fair value 
 through 
 profit or loss                     138                       -                   2,504                         2                         -                 2,644                         -                 2,644 
Derivatives                      98,698                  24,160                   2,854                        75                         -               125,787                         -               125,787 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Total gross 
 carrying 
 amount on 
 balance sheet                  290,279                  44,547                  22,530                     1,235                     1,012               359,603                     (359)               359,244 
Percentage of 
 total 
 credit quality                   80.7%                   12.4%                    6.3%                      0.3%                      0.3%                100.0% 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  -------------------- 
Loans and other 
 credit-related 
 commitments                     20,446                   6,663                   3,651                       452                        43                31,255                      (29)                31,226 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Financial 
 guarantees                         630                      89                     471                        20                        60                 1,270                       (7)                 1,263 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
In-scope: 
 Irrevocable 
 loan 
 commitments 
 and 
 financial 
 guarantees                      21,076                   6,752                   4,122                       472                       103                32,525                      (36)                32,489 
Loans and other 
 credit-related 
 commitments                        620                     383                     126                        86                         1                 1,216                         -                 1,216 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Performance and 
 other 
 guarantees                       4,846                   1,939                     480                        56                        13                 7,334                       (7)                 7,327 
                 ----------------------  ----------------------  ----------------------  ------------------------  ------------------------  --------------------  ------------------------  -------------------- 
Out-of-scope: 
 Revocable 
 loan 
 commitments 
 and 
 non-financial 
 guarantees                       5,466                   2,322                     606                       142                        14                 8,550                       (7)                 8,543 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments by credit quality at 31 December 
 2020 (continued) 
(Audited) 
                                                                            Gross carrying/notional amount 
                                                                                                                                      Credit                                           Allowance 
                                  Strong                      Good              Satisfactory          Sub-standard                  impaired                    Total                    for ECL                      Net 
The bank                            GBPm                      GBPm                      GBPm                  GBPm                      GBPm                     GBPm                       GBPm                     GBPm 
In-scope for 
IFRS 9 
Loans and 
 advances to 
 customers held 
 at amortised 
 cost                             20,109                    12,752                     8,496                 1,193                     1,281                   43,831                      (590)                   43,241 
- personal                         1,804                       816                       880                    25                        57                    3,582                       (13)                    3,569 
- corporate and 
 commercial                        7,870                     9,401                     6,785                 1,038                       920                   26,014                      (494)                   25,520 
- non-bank 
 financial 
 institutions                     10,435                     2,535                       831                   130                       304                   14,235                       (83)                   14,152 
Loans and 
 advances to 
 banks held at 
 amortised 
 cost                              7,256                       412                       410                     -                         -                    8,078                       (15)                    8,063 
Cash and 
 balances at 
 central banks                    48,777                         -                         -                     -                         -                   48,777                          -                   48,777 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Items in the 
 course 
 of collection 
 from other 
 banks                                37                         -                         -                     -                         -                       37                          -                       37 
Reverse 
 repurchase 
 agreements 
 - non-trading                    41,057                     7,213                     1,862                     5                         -                   50,137                          -                   50,137 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Financial 
 investments                       2,214                         -                         -                     -                         -                    2,214                          -                    2,214 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Prepayments, 
 accrued 
 income and 
 other assets                     34,495                        94                       120                     4                        22                   34,735                        (1)                   34,734 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
- endorsements 
 and 
 acceptances                          44                         2                        22                     -                         2                       70                        (1)                       69 
- accrued 
 income and 
 other                            34,451                        92                        98                     4                        20                   34,665                          -                   34,665 
Debt 
 instruments 
 measured 
 at fair value 
 through 
 other 
 comprehensive 
 income(1)                        27,762                        62                         3                     -                         -                   27,827                        (9)                   27,818 
Out-of-scope 
for IFRS 
9 
Trading assets                    21,486                     5,922                     9,406                   410                         -                   37,224                          -                   37,224 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Other financial 
 assets 
 designated and 
 otherwise 
 mandatorily 
 measured 
 at fair value 
 through 
 profit or loss                       94                       788                       382                     4                         -                    1,268                          -                    1,268 
Derivatives                      150,837                    26,966                     3,625                   638                         -                  182,066                          -                  182,066 
Total gross 
 carrying 
 amount on 
 balance sheet                   354,124                    54,209                    24,304                 2,254                     1,303                  436,194                      (615)                  435,579 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Percentage of 
 total 
 credit quality                      81%                       13%                        6%                     -                         -                     100% 
                 -----------------------  ------------------------  ------------------------                        ------------------------  ----------------------- 
Loans and other 
 credit-related 
 commitments                      29,939                    10,375                     4,422                   512                        60                   45,308                       (81)                   45,227 
Financial 
 guarantees                          913                       134                       376                    33                        54                    1,510                       (13)                    1,497 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
In-scope: 
 Irrevocable 
 loan 
 commitments 
 and 
 financial 
 guarantees                       30,852                    10,509                     4,798                   545                       114                   46,818                       (94)                   46,724 
Loans and other 
 credit-related 
 commitments                         475                       235                       148                   173                         1                    1,032                          -                    1,032 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Performance and 
 other 
 guarantees                        4,670                     1,701                       623                   127                        35                    7,156                       (13)                    7,143 
                 -----------------------  ------------------------  ------------------------                        ------------------------  -----------------------  -------------------------  ----------------------- 
Out-of-scope: 
 Revocable 
 loan 
 commitments 
 and 
 non-financial 
 guarantees                        5,145                     1,936                       771                   300                        36                    8,188                       (13)                    8,175 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments to which the impairment requirements 
 in IFRS 9 are applied, by credit quality and stage distribution 
(Audited) 
                                                                          Gross carrying/notional amount 
                                                                                                              Sub-                  Credit                                        Allowance 
                                 Strong                    Good               Satisfactory                standard                impaired                   Total                  for ECL                    Net 
The group                          GBPm                    GBPm                       GBPm                    GBPm                    GBPm                    GBPm                     GBPm                   GBPm 
                 ----------------------                                                                                                     ---------------------- 
Loans and 
 advances to 
 customers at 
 amortised 
 cost                            41,339                  20,531                     23,469                   4,512                   2,480                  92,331                  (1,154)                 91,177 
                 ----------------------                                                                                                     ---------------------- 
- stage 1                        40,831                  19,376                     19,077                   1,446                       -                  80,730                     (86)                 80,644 
- stage 2                           508                   1,155                      4,392                   3,066                       -                   9,121                    (158)                  8,963 
- stage 3                             -                       -                          -                       -                   2,478                   2,478                    (908)                  1,570 
- POCI                                -                       -                          -                       -                       2                       2                      (2)                      - 
                 ----------------------                                                                                                     ---------------------- 
Loans and 
 advances to 
 banks at 
 amortised cost                   8,649                     320                      1,815                       5                       -                  10,789                      (5)                 10,784 
- stage 1                         8,620                     311                      1,814                       5                       -                  10,750                      (4)                 10,746 
- stage 2                            29                       9                          1                       -                       -                      39                      (1)                     38 
- stage 3                             -                       -                          -                       -                       -                       -                        -                      - 
- POCI                                -                       -                          -                       -                       -                       -                        -                      - 
                 ----------------------                                                                                                     ---------------------- 
Other financial 
 assets 
 measured at 
 amortised 
 cost                           192,107                   7,219                      2,758                      11                      42                 202,137                      (9)                202,128 
- stage 1                       192,105                   7,214                      2,727                       2                       -                 202,048                        -                202,048 
- stage 2                             2                       5                         31                       9                       -                      47                        -                     47 
- stage 3                             -                       -                          -                       -                      42                      42                      (9)                     33 
- POCI                                -                       -                          -                       -                       -                       -                        -                      - 
                 ----------------------                                                                                                     ---------------------- 
Loans and other 
 credit-related 
 commitments                     71,741                  21,860                     20,018                   1,874                     202                 115,695                     (55)                115,640 
- stage 1                        71,074                  19,960                     16,337                     551                       -                 107,922                     (25)                107,897 
- stage 2                           667                   1,900                      3,681                   1,323                       -                   7,571                     (22)                  7,549 
- stage 3                             -                       -                          -                       -                     202                     202                      (8)                    194 
- POCI                                -                       -                          -                       -                       -                       -                        -                      - 
                 ----------------------                                                                                                     ---------------------- 
Financial 
 guarantees                       8,412                   1,088                      1,245                     210                      99                  11,054                     (17)                 11,037 
- stage 1                         8,340                     951                        849                      75                       -                  10,215                      (3)                 10,212 
- stage 2                            72                     137                        396                     135                       -                     740                      (7)                    733 
- stage 3                             -                       -                          -                       -                      99                      99                      (7)                     92 
- POCI                                -                       -                          -                       -                       -                       -                        -                      - 
                 ----------------------                                                                                                     ---------------------- 
At 31 Dec 2021                  322,248                  51,018                     49,305                   6,612                   2,823                 432,006                  (1,240)                430,766 
Debt 
instruments at 
FVOCI(1) 
- stage 1                        36,005                   1,825                      1,292                       -                       -                  39,122                     (10)                 39,112 
- stage 2                           405                      74                        114                     118                       -                     711                      (9)                    702 
- stage 3                             -                       -                          -                       -                       -                       -                        -                      - 
- POCI                                -                       -                          -                       -                       -                       -                        -                      - 
                 ----------------------                                                                                                     ---------------------- 
At 31 Dec 2021                   36,410                   1,899                      1,406                     118                       -                  39,833                     (19)                 39,814 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments to which the impairment requirements 
 in IFRS 9 are applied, by credit quality and stage distribution 
 (continued) 
(Audited) 
                                                                         Gross carrying/notional amount 
                                                                                                           Sub-                   Credit                                        Allowance 
                                 Strong                   Good              Satisfactory               standard                 impaired                   Total                  for ECL                      Net 
The group                          GBPm                   GBPm                      GBPm                   GBPm                     GBPm                    GBPm                     GBPm                     GBPm 
Loans and 
 advances to 
 customers at 
 amortised 
 cost                            43,077                 24,780                    26,477                  5,619                    3,007                 102,960                  (1,469)                  101,491 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                        42,579                 21,351                    17,556                  1,693                        -                  83,179                    (129)                   83,050 
- stage 2                           498                  3,429                     8,921                  3,926                        -                  16,774                    (297)                   16,477 
- stage 3                             -                      -                         -                      -                    2,966                   2,966                  (1,031)                    1,935 
- POCI                                -                      -                         -                      -                       41                      41                     (12)                       29 
                 ----------------------  ---------------------                            ---------------------  -----------------------  ----------------------  ----------------------- 
Loans and 
 advances to 
 banks at 
 amortised cost                  10,518                    721                     1,412                     11                        -                  12,662                     (16)                   12,646 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                        10,479                    674                     1,372                      8                        -                  12,533                     (13)                   12,520 
- stage 2                            39                     47                        40                      3                        -                     129                      (3)                      126 
- stage 3                             -                      -                         -                      -                        -                       -                        -                        - 
- POCI                                -                      -                         -                      -                        -                       -                        -                        - 
                 ----------------------  ---------------------                            ---------------------  -----------------------  ----------------------  ----------------------- 
Other financial 
 assets 
 measured at 
 amortised 
 cost                           190,416                  8,936                     3,350                     22                       39                 202,763                     (12)                  202,751 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                       190,407                  8,924                     3,321                      7                        -                 202,659                      (2)                  202,657 
- stage 2                             9                     12                        29                     15                        -                      65                        -                       65 
- stage 3                             -                      -                         -                      -                       39                      39                     (10)                       29 
- POCI                                -                      -                         -                      -                        -                       -                        -                        - 
                 ----------------------  ---------------------                            ---------------------  -----------------------  ----------------------  ----------------------- 
Loans and other 
 credit-related 
 commitments                     97,281                 26,361                    17,081                  2,047                      266                 143,036                    (112)                  142,924 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                        95,270                 21,398                    11,758                    530                        -                 128,956                     (34)                  128,922 
- stage 2                         2,011                  4,963                     5,323                  1,517                        -                  13,814                     (68)                   13,746 
- stage 3                             -                      -                         -                      -                      266                     266                     (10)                      256 
- POCI                                -                      -                         -                      -                        -                       -                        -                        - 
                 ----------------------  ---------------------                            ---------------------  -----------------------  ----------------------  ----------------------- 
Financial 
 guarantees                       1,340                  1,153                     1,020                    334                      122                   3,969                     (23)                    3,946 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                         1,337                    883                       496                    123                        -                   2,839                      (4)                    2,835 
- stage 2                             3                    270                       524                    211                        -                   1,008                     (10)                      998 
- stage 3                             -                      -                         -                      -                      121                     121                      (9)                      112 
- POCI                                -                      -                         -                      -                        1                       1                        -                        1 
                 ----------------------  ---------------------                            ---------------------  -----------------------  ----------------------  ----------------------- 
At 31 Dec 2020                  342,632                 61,951                    49,340                  8,033                    3,434                 465,390                  (1,632)                  463,758 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
Debt 
instruments at 
FVOCI(1) 
- stage 1                        45,958                  2,424                       233                      -                        -                  48,615                     (12)                   48,603 
- stage 2                            71                     63                       172                    153                        -                     459                     (10)                      449 
- stage 3                             -                      -                         -                      -                        -                       -                        -                        - 
- POCI                                -                      -                         -                      -                        -                       -                        -                        - 
                 ----------------------  ---------------------                            ---------------------  -----------------------  ----------------------  ----------------------- 
At 31 Dec 2020                   46,029                  2,487                       405                    153                        -                  49,074                     (22)                   49,052 
                                         ---------------------                            ---------------------  -----------------------                          -----------------------  ----------------------- 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments to which the impairment requirements 
 in IFRS 9 are applied, by credit quality and stage distribution 
 (continued) 
(Audited) 
                                                                          Gross carrying/notional amount 
                                                                                                              Sub-                 Credit                                        Allowance 
                                 Strong                    Good               Satisfactory                standard               impaired                   Total                  for ECL                     Net 
The bank                           GBPm                    GBPm                       GBPm                    GBPm                   GBPm                    GBPm                     GBPm                    GBPm 
                 ----------------------                                                                                                    ---------------------- 
Loans and 
 advances to 
 customers at 
 amortised 
 cost                            16,993                   9,038                      6,467                     804                    984                  34,286                    (350)                  33,936 
                 ----------------------                                                                                                    ---------------------- 
- stage 1                        16,757                   8,305                      4,964                      79                      -                  30,105                     (33)                  30,072 
- stage 2                           236                     733                      1,503                     725                      -                   3,197                     (47)                   3,150 
- stage 3                             -                       -                          -                       -                    984                     984                    (270)                     714 
- POCI                                -                       -                          -                       -                      -                       -                        -                       - 
                 ----------------------                                                                                                    ---------------------- 
Loans and 
 advances to 
 banks at 
 amortised cost                   6,427                     166                        187                       2                      -                   6,782                      (4)                   6,778 
                 ----------------------                                                                                                    ---------------------- 
- stage 1                         6,427                     160                        186                       2                      -                   6,775                      (3)                   6,772 
- stage 2                             -                       6                          1                       -                      -                       7                      (1)                       6 
- stage 3                             -                       -                          -                       -                      -                       -                        -                       - 
- POCI                                -                       -                          -                       -                      -                       -                        -                       - 
                 ----------------------                                                                                                    ---------------------- 
Other financial 
 assets 
 measured at 
 amortised 
 cost                           127,957                   6,037                      1,009                       2                     28                 135,033                      (1)                 135,032 
                 ----------------------                                                                                                    ---------------------- 
- stage 1                       127,956                   6,037                        991                       -                      -                 134,984                        -                 134,984 
- stage 2                             1                       -                         18                       2                      -                      21                        -                      21 
- stage 3                             -                       -                          -                       -                     28                      28                      (1)                      27 
- POCI                                -                       -                          -                       -                      -                       -                        -                       - 
                 ----------------------                                                                                                    ---------------------- 
Loans and other 
 credit-related 
 commitments                     20,446                   6,663                      3,651                     452                     43                  31,255                     (29)                  31,226 
- stage 1                        20,307                   6,469                      2,135                       -                      -                  28,911                     (15)                  28,896 
- stage 2                           139                     194                      1,516                     452                      -                   2,301                     (11)                   2,290 
- stage 3                             -                       -                          -                       -                     43                      43                      (3)                      40 
- POCI                                -                       -                          -                       -                      -                       -                        -                       - 
                 ----------------------                                                                                                    ---------------------- 
Financial 
 guarantees                         630                      89                        471                      20                     60                   1,270                      (7)                   1,263 
- stage 1                           630                      89                        324                      17                      -                   1,060                      (1)                   1,059 
- stage 2                             -                       -                        147                       3                      -                     150                        -                     150 
- stage 3                             -                       -                          -                       -                     60                      60                      (6)                      54 
- POCI                                -                       -                          -                       -                      -                       -                        -                       - 
                 ----------------------                                                                                                    ---------------------- 
At 31 Dec 2021                  172,453                  21,993                     11,785                   1,280                  1,115                 208,626                    (391)                 208,235 
Debt 
instruments at 
FVOCI(1) 
- stage 1                        21,748                      64                      1,035                       -                      -                  22,847                      (2)                  22,845 
- stage 2                             -                       -                          4                       -                      -                       4                      (2)                       2 
- stage 3                             -                       -                          -                       -                      -                       -                        -                       - 
- POCI                                -                       -                          -                       -                      -                       -                        -                       - 
                 ----------------------                                                                                                    ---------------------- 
At 31 Dec 2021                   21,748                      64                      1,039                       -                      -                  22,851                      (4)                  22,847 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

 
Distribution of financial instruments to which the impairment requirements 
 in IFRS 9 are applied, by credit quality and stage distribution 
 (continued) 
(Audited) 
                                                                            Gross carrying/notional amount 
                                                                                                                Sub-                   Credit                                        Allowance 
                                 Strong                     Good                Satisfactory                standard                 impaired                   Total                  for ECL                      Net 
The bank                           GBPm                     GBPm                        GBPm                    GBPm                     GBPm                    GBPm                     GBPm                     GBPm 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  -----------------------  ----------------------- 
Loans and 
 advances to 
 customers at 
 amortised 
 cost                            20,109                   12,752                       8,496                   1,193                    1,281                  43,831                    (590)                   43,241 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                        19,650                   10,014                       4,918                      47                        -                  34,629                     (79)                   34,550 
- stage 2                           459                    2,738                       3,578                   1,146                        -                   7,921                    (158)                    7,763 
- stage 3                             -                        -                           -                       -                    1,279                   1,279                    (351)                      928 
- POCI                                -                        -                           -                       -                        2                       2                      (2)                        - 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  ----------------------- 
Loans and 
 advances to 
 banks at 
 amortised cost                   7,256                      412                         410                       -                        -                   8,078                     (15)                    8,063 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                         7,254                      366                         375                       -                        -                   7,995                     (12)                    7,983 
- stage 2                             2                       46                          35                       -                        -                      83                      (3)                       80 
- stage 3                             -                        -                           -                       -                        -                       -                        -                        - 
- POCI                                -                        -                           -                       -                        -                       -                        -                        - 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  ----------------------- 
Other financial 
 assets 
 measured at 
 amortised 
 cost                           126,580                    7,307                       1,982                       9                       22                 135,900                      (1)                  135,899 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                       126,579                    7,306                       1,953                       5                        -                 135,843                        -                  135,843 
- stage 2                             1                        1                          29                       4                        -                      35                        -                       35 
- stage 3                             -                        -                           -                       -                       22                      22                      (1)                       21 
- POCI                                -                        -                           -                       -                        -                       -                        -                        - 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  ----------------------- 
Loans and other 
 credit-related 
 commitments                     29,939                   10,375                       4,422                     512                       60                  45,308                     (81)                   45,227 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                        28,569                    8,176                       2,453                     145                        -                  39,343                     (28)                   39,315 
- stage 2                         1,370                    2,199                       1,969                     367                        -                   5,905                     (48)                    5,857 
- stage 3                             -                        -                           -                       -                       60                      60                      (5)                       55 
- POCI                                -                        -                           -                       -                        -                       -                        -                        - 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  ----------------------- 
Financial 
 guarantees                         913                      134                         376                      33                       54                   1,510                     (13)                    1,497 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
- stage 1                           910                      121                         170                       2                        -                   1,203                      (2)                    1,201 
- stage 2                             3                       13                         206                      31                        -                     253                      (4)                      249 
- stage 3                             -                        -                           -                       -                       54                      54                      (7)                       47 
- POCI                                -                        -                           -                       -                        -                       -                        -                        - 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  ----------------------- 
At 31 Dec 2020                  184,797                   30,980                      15,686                   1,747                    1,417                 234,627                    (700)                  233,927 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
Debt 
instruments at 
FVOCI(1) 
                                                                                              ---------------------- 
- stage 1                        25,570                       62                           -                       -                        -                  25,632                      (7)                   25,625 
- stage 2                             -                        -                           3                       -                        -                       3                      (2)                        1 
- stage 3                             -                        -                           -                       -                        -                       -                        -                        - 
- POCI                                -                        -                           -                       -                        -                       -                        -                        - 
                 ----------------------  -----------------------                              ----------------------  -----------------------  ----------------------  ----------------------- 
At 31 Dec 2020                   25,570                       62                           3                       -                        -                  25,635                      (9)                   25,626 
                                         -----------------------                              ----------------------  -----------------------                          -----------------------  ----------------------- 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

Credit--impaired loans

(Audited)

The group determines that a financial instrument is credit impaired and in stage 3 by considering relevant objective evidence, primarily whether:

   --    contractual payments of either principal or interest are past due for more than 90 days; 

-- there are other indications that the borrower is unlikely to pay such as that a concession has been granted to the borrower for economic or legal reasons relating to the borrower's financial condition; and

-- the loan is otherwise considered to be in default. If such unlikeliness to pay is not identified at an earlier stage, it is deemed to occur when an exposure is 90 days past due, even where regulatory rules permit default to be defined based on 180 days past due. Therefore, the definitions of credit-impaired and default are aligned as far as possible so that stage 3 represents all loans which are considered defaulted or otherwise credit-impaired.

--

Renegotiated loans and forbearance

The following table shows the gross carrying amounts of the group's holdings of renegotiated loans and advances to customers by industry sector and by stages. Mandatory and general offer loan modifications that are not borrower-specific, for example market-wide customer relief programmes, have not been classified as renegotiated loans. For details on customer relief schemes see page 60.

A summary of our current policies and practices for renegotiated loans and forbearance is set out in 'Credit risk management' on page 32.

 
Renegotiated loans and advances to customers at amortised costs by 
 stage allocation 
                                         Stage                            Stage                            Stage                             POCI                            Total 
                                             1                                2                                3 
The group                                 GBPm                             GBPm                             GBPm                             GBPm                             GBPm 
Gross 
carrying 
amount 
Personal                                     -                                -                              132                                -                              132 
- first lien 
 residential 
 mortgages                                   -                                -                               96                                -                               96 
- other 
 personal 
 lending                                     -                                -                               36                                -                               36 
Wholesale                                   49                              192                              706                                2                              949 
- corporate 
 and 
 commercial                                 49                              192                              702                                2                              945 
- non-bank 
 financial 
 institutions                                -                                -                                4                                -                                4 
At 31 Dec 
 2021                                       49                              192                              838                                2                            1,081 
Allowance for 
ECL 
Personal                                     -                                -                             (15)                                -                             (15) 
- first lien 
 residential 
 mortgages                                   -                                -                             (11)                                -                             (11) 
- other 
 personal 
 lending                                     -                                -                              (4)                                -                              (4) 
Wholesale                                  (1)                              (5)                            (218)                              (2)                            (226) 
- corporate 
 and 
 commercial                                (1)                              (5)                            (218)                              (2)                            (226) 
- non-bank                                   -                                -                                -                                -                                - 
financial 
institutions 
At 31 Dec 
 2021                                      (1)                              (5)                            (233)                              (2)                            (241) 
 
 
The group 
Gross 
carrying 
amount 
Personal                                     -                                -                              122                               -                              122 
- first lien 
 residential 
 mortgages                                   -                                -                               97                               -                               97 
- other 
 personal 
 lending                                     -                                -                               25                               -                               25 
Wholesale                                   43                              348                              773                              40                            1,204 
- corporate 
 and 
 commercial                                 43                              348                              773                              40                            1,204 
- non-bank                                   -                                -                                -                               -                                - 
financial 
institutions 
At 31 Dec 
 2020                                       43                              348                              895                              40                            1,326 
Allowance for 
ECL 
Personal                                     -                                -                             (18)                               -                             (18) 
- first lien 
 residential 
 mortgages                                   -                                -                             (14)                               -                             (14) 
- other 
 personal 
 lending                                     -                                -                              (4)                               -                              (4) 
Wholesale                                  (1)                              (9)                            (211)                            (12)                            (233) 
- corporate 
 and 
 commercial                                (1)                              (9)                            (211)                            (12)                            (233) 
- non-bank                                   -                                -                                -                               -                                - 
financial 
institutions 
At 31 Dec 
 2020                                      (1)                              (9)                            (229)                            (12)                            (251) 
 
 
                                        Stage                            Stage                           Stage                           POCI                           Total 
                                            1                                2                               3 
The bank                                 GBPm                             GBPm                            GBPm                           GBPm                            GBPm 
Gross 
carrying 
amount 
Personal                                    -                                -                               3                              -                               3 
- first lien 
 residential 
 mortgages                                  -                                -                               2                              -                               2 
- other 
 personal 
 lending                                    -                                -                               1                              -                               1 
Wholesale                                  40                              158                             431                              -                             629 
- corporate 
 and 
 commercial                                40                              158                             431                              -                             629 
At 31 Dec 
 2021                                      40                              158                             434                              -                             632 
Allowance 
for ECL 
Personal                                    -                                -                               -                              -                               - 
- first lien                                -                                -                               -                              -                               - 
residential 
mortgages 
- other                                     -                                -                               -                              -                               - 
personal 
lending 
Wholesale                                 (1)                              (2)                           (124)                              -                           (127) 
- corporate 
 and 
 commercial                               (1)                              (2)                           (124)                              -                           (127) 
At 31 Dec 
 2021                                     (1)                              (2)                           (124)                              -                           (127) 
 
 
Renegotiated loans and advances to customers at amortised costs by 
 stage allocation (continued) 
                                        Stage                            Stage                            Stage                             POCI                            Total 
                                            1                                2                                3 
The bank                                 GBPm                             GBPm                             GBPm                             GBPm                             GBPm 
Gross 
carrying 
amount 
Personal                                    -                                -                                7                                -                                7 
- first lien 
 residential 
 mortgages                                  -                                -                                6                                -                                6 
- other 
 personal 
 lending                                    -                                -                                1                                -                                1 
Wholesale                                  39                              181                              520                                2                              742 
- corporate 
 and 
 commercial                                39                              181                              520                                2                              742 
At 31 Dec 
 2020                                      39                              181                              527                                2                              749 
Allowance 
for ECL 
Personal                                    -                                -                                -                                -                                - 
- first lien                                -                                -                                -                                -                                - 
residential 
mortgages 
- other                                     -                                -                                -                                -                                - 
personal 
lending 
Wholesale                                 (1)                              (4)                            (124)                              (2)                            (131) 
- corporate 
 and 
 commercial                               (1)                              (4)                            (124)                              (2)                            (131) 
At 31 Dec 
 2020                                     (1)                              (4)                            (124)                              (2)                            (131) 
 

Customer relief programmes

In response to the Covid-19 pandemic, governments and regulators around the world introduced a number of support measures for both personal and wholesale customers in market-wide schemes. The following table presents the number of personal accounts/wholesale customers and the associated drawn loan values of customers under these schemes and HSBC-specific measures for major markets at 31 December 2021. When schemes expire, accounts and customers and their associated drawn balances are no longer reported under relief regardless of their repayment status. In relation to personal lending, the majority of relief measures, including payment holidays, relate to existing

lending, while in wholesale lending the relief measures comprise payment holidays, refinancing of existing facilities and new lending under government-backed schemes. .

At 31 December 2021, the gross carrying value of loans to personal customers under relief was GBP36m and wholesale customers under relief was GBP3,428m. We continue to monitor the recoverability of loans granted under customer relief programmes, including loans to a small number of customers that were subsequently found to be ineligible for such relief. The ongoing performance of such loans remains an area of uncertainty at

31 December 2021.

 
Personal lending 
                                                                          HSBC 
Extant at 31 December                                              Continental                            Other 
2021                                                UK               Europe(1)  Germany              markets(2)  Total 
Market-wide schemes 
Number of accounts 
 granted mortgage 
 customer relief          00s                        -                       -        -                       -      - 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of       GBPm 
accounts granted 
mortgage customer relief                             -                       -        -                       -      - 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Number of accounts 
 granted other 
 personal lending 
 customer relief          00s                        -                       5        -                       -      5 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of 
 accounts granted 
 other personal lending 
 customer relief          GBPm                       -                      32        -                       -     32 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
HSBC-specific measures 
                                ----------------------  ----------------------           ----------------------  ----- 
Number of accounts 
 granted mortgage 
 customer relief          00s                        -                       -        -                       -      - 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of       GBPm 
accounts granted 
mortgage customer relief                             -                       -        -                       -      - 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Number of accounts 
 granted other 
 personal lending 
 customer relief          00s                        -                      <1        -                       -     <1 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of 
 accounts granted 
 other personal lending 
 customer relief          GBPm                       -                       4        -                       -      4 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Total personal lending 
to major markets 
under market-wide 
schemes and 
HSBC-specific 
measures 
Number of accounts 
 granted mortgage 
 customer relief          00s                        -                       -        -                       -      - 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of       GBPm 
accounts granted 
mortgage customer relief                             -                       -        -                       -      - 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Number of accounts 
 granted other 
 personal lending 
 customer relief          00s                        -                       5        -                       -      5 
                                                        ----------------------  -------  ----------------------  ----- 
Drawn loan value of 
 accounts granted 
 other personal lending 
 customer relief          GBPm                       -                      36        -                       -     36 
Market-wide schemes and 
HSBC-specific 
measures - mortgage 
relief as a proportion 
of total mortgages        %                          -                       -        -                       -      - 
Market-wide schemes and 
 HSBC-specific 
 measures - other 
 personal lending 
 relief as a proportion 
 of total other 
 personal lending loans 
 and advances             %                          -                     0.2        -                       -    0.2 
Wholesale lending 
                                                                          HSBC 
Extant at 31 December                                              Continental                            Other 
2021                                                UK               Europe(1)  Germany              markets(2)  Total 
Market-wide schemes 
Number of customers 
 under market-wide 
 schemes                  00s                       <1                      49       <1                       1     50 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of 
 customers under 
 market-wide schemes      GBPm                       1                   2,918       63                      39  3,021 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
HSBC-specific measures 
                                ----------------------  ----------------------           ----------------------  ----- 
Number of customers 
 under HSBC-specific 
 measures                 00s                        -                      <1        -                       -     <1 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value of 
 customers under 
 HSBC-specific measures   GBPm                       -                     407        -                       -    407 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Total wholesale lending 
to major 
markets under 
market-wide schemes 
and HSBC-specific 
measures 
Number of customers       00s                       <1                      49       <1                       1     50 
                                ----------------------  ----------------------  -------  ----------------------  ----- 
Drawn loan value          GBPm                       1                   3,325       63                      39  3,428 
Market-wide schemes and 
 HSBC-specific 
 measures as a 
 proportion of total 
 wholesale lending loans 
 and advances             %                          -                    12.3      1.1                     4.0    5.9 
 
   1   HSBC Continental Europe includes France and branches in Spain, Poland and Greece. 
   2   Other markets include Malta and Armenia. 
 
Personal lending (continued) 
                                                                  HSBC 
                                                           Continental                 Other 
Extant at 31 December 2020                            UK     Europe(1)  Germany   markets(2)  Total 
Market-wide schemes 
Number of accounts granted mortgage 
 customer relief                               00s     1             -        -            -      1 
Drawn loan value of accounts granted 
 mortgage customer relief                      GBPm    9             -        -            -      9 
Number of accounts granted other 
 personal lending customer relief              00s    <1             5        -            -      5 
Drawn loan value of accounts granted 
 other personal lending customer relief        GBPm    -            38        -            -     38 
HSBC-specific measures 
Number of accounts granted mortgage 
 customer relief                               00s     -            <1        -            3      3 
Drawn loan value of accounts granted 
 mortgage customer relief                      GBPm    -             2        -           58     60 
Number of accounts granted other 
 personal lending customer relief              00s     -             3        -            2      5 
Drawn loan value of accounts granted 
 other personal lending customer relief        GBPm    -            85        -            5     90 
Total personal lending to major markets 
 under market-wide schemes and HSBC-specific 
 measures 
Number of accounts granted mortgage 
 customer relief                               00s     1            <1        -            3      4 
Drawn loan value of accounts granted 
 mortgage customer relief                      GBPm    9             2        -           58     69 
Number of accounts granted other 
 personal lending customer relief              00s    <1             8        -            2     10 
Drawn loan value of accounts granted 
 other personal lending customer relief        GBPm    -           123        -            5    128 
Market-wide schemes and HSBC-specific 
 measures - mortgage relief as a proportion 
 of total mortgages                            %     0.5           0.1        -          2.2    0.9 
Market-wide schemes and HSBC-specific 
 measures - other personal lending 
 relief as a proportion of total other 
 personal lending loans and advances           %       -           0.7        -          2.3    0.7 
Wholesale lending (continued) 
                                                                  HSBC 
                                                           Continental                 Other 
Extant at 31 December 2020                            UK     Europe(1)  Germany   markets(2)  Total 
Market-wide schemes 
Number of customers under market-wide 
 schemes                                       00s    <1            49       <1            1     50 
Drawn loan value of customers under 
 market-wide schemes                           GBPm    1         3,997       47           24  4,069 
HSBC-specific measures 
Number of customers under HSBC-specific 
 measures                                      00s    <1             3        -           <1      4 
Drawn loan value of customers under 
 HSBC-specific measures                        GBPm    1         1,103        -          295  1,399 
Total wholesale lending to major 
 markets under market-wide schemes 
 and HSBC-specific measures 
Number of customers                            00s    <1            52       <1            1     54 
Drawn loan value                               GBPm    2         5,100       47          319  5,468 
Market-wide schemes and HSBC-specific 
 measures as a proportion of total 
 wholesale lending loans and advances          %       -          20.7      0.7         22.7    8.5 
 
   1   HSBC Continental Europe includes France and branches in Spain, Poland and Greece. 
   2   Other markets include Malta, Jersey, Armenia and Middle East leasing partnership. 

The initial granting of customer relief does not automatically trigger a migration to stage 2 or 3. However, information provided by payment deferrals is considered in the context of other reasonable and supportable information. This forms part of the overall assessment for whether there has been a significant increase in credit risk and credit impairment to identify loans for which lifetime ECL is appropriate. An extension in payment deferral does not automatically result in a migration to stage 2 or stage 3. The key accounting and credit risk judgement to ascertain whether a significant increase in credit risk has occurred is whether the economic effects of the Covid-19 outbreak on the customer are likely to be temporary over the lifetime of the loan, and whether they indicate that a concession is being made in respect of financial difficulty that would be

consistent with     stage 3. 

Market-wide schemes The following narrative provides further details on the major government and regulatory schemes offered in France and Germany.

Personal lending

France - Other personal lending

The Prêt garanti par l'Etat ('PGE') government scheme provides term lending to professionals, firms, business owners, craftsmen and micro-entrepreneurs for a maximum duration of six years including a first year deferral. The maximum relief value is at 25% of baseline turnover with the maximum amount of EUR2.25m

granted. Borrowers need to confirm that Covid-19 has placed them under temporary financial hardship and that they didn't experience financial difficulties before the crisis.

Wholesale lending

France

The PGE government scheme provides term lending to all registered French companies, excluding real estate special purpose vehicles ('SPVs'), banks, and companies subject to insolvency proceedings, for a maximum duration of one year (with the option to amortise up to five years). The maximum loan value is linked to turnover.

Germany - wholesale lending

Kreditanstalt für Wiederaufbau ('KfW') Coronavirus Aid provides lending to corporates for a maximum tenor of ten years.

HSBC-specific measures

France business banking lending

Payment holidays offered to professionals, firms, business owners, craftsmen and micro-entrepreneurs.

France wholesale lending

Payment holidays offered to commercial banking customers focused largely on business banking or lower end micro and medium enterprises. The duration is between 3 and 18 months and there is no specific maximum loan value.

Wholesale lending

This section provides further details on the countries and industries comprising wholesale loans and advances to customers

and banks. Industry granularity is also provided by stage with geographical data presented for loans and advances to customers and banks, loans and other credit-related commitments and financial guarantees.

 
Total wholesale lending for loans and advances to banks and customers 
 by stage distribution 
                                                                         Gross carrying amount                                                                                       Allowance for ECL 
                                                        Stage                Stage                Stage                 POCI                Total                 Stage                 Stage                 Stage                  POCI                 Total 
                                                            1                    2                    3                                                               1                     2                     3 
The group                                                GBPm                 GBPm                 GBPm                 GBPm                 GBPm                  GBPm                  GBPm                  GBPm                  GBPm                  GBPm 
Corporate and commercial                               46,237                8,066                1,782                    2               56,087                  (58)                 (137)                 (767)                   (2)                 (964) 
- agriculture, forestry 
 and fishing                                              157                    7                    7                    -                  171                     -                     -                   (5)                     -                   (5) 
- mining and quarrying                                  1,207                   86                   58                    -                1,351                   (1)                   (1)                   (5)                     -                   (7) 
- manufacture                                           7,327                1,624                  281                    2                9,234                   (8)                  (14)                  (72)                   (2)                  (96) 
 
  *    electricity, gas, steam and air-co 
 nditioning supply                                      2,891                   49                   30                    -                2,970                   (3)                   (1)                   (4)                     -                   (8) 
 
  *    water supply, sewerage, waste mana 
 gement and 
       remediation                                        215                    -                    4                    -                  219                     -                     -                   (4)                     -                   (4) 
- construction                                            641                  116                   97                    -                  854                   (2)                   (2)                  (40)                     -                  (44) 
 
  *    wholesale and retail trade, repair 
  of motor vehicles 
       and motorcycles                                  7,743                  889                  192                    -                8,824                   (4)                   (8)                 (132)                     -                 (144) 
- transportation 
 and storage                                            3,254                1,570                  205                    -                5,029                   (9)                  (20)                  (56)                     -                  (85) 
- accommodation and 
 food                                                     831                  409                   80                    -                1,320                   (4)                  (10)                  (20)                     -                  (34) 
 
  *    publishing, audiovisual and broadc 
 asting                                                 2,390                   81                   50                    -                2,521                   (2)                   (2)                  (12)                     -                  (16) 
- real estate                                           4,849                  891                  280                    -                6,020                   (9)                  (32)                 (159)                     -                 (200) 
 
  *    professional, scientific and techn 
 ical activities                                        2,522                  669                  221                    -                3,412                   (3)                   (8)                  (60)                     -                  (71) 
- administrative 
 and support services                                   8,765                1,204                  178                    -               10,147                   (9)                  (21)                 (161)                     -                 (191) 
 
  *    public administration and defence, 
  compulsory social 
       security                                           376                  180                    -                    -                  556                     -                     -                     -                     -                     - 
- education                                                22                    5                    3                    -                   30                     -                   (1)                   (1)                     -                   (2) 
- health and care                                         473                   47                    6                    -                  526                   (1)                   (4)                   (5)                     -                  (10) 
- arts, entertainment 
 and recreation                                           104                  116                    5                    -                  225                     -                   (3)                   (3)                     -                   (6) 
- other services                                        1,427                   66                   85                    -                1,578                   (3)                   (2)                  (28)                     -                  (33) 
- activities of households                                  -                    2                    -                    -                    2                     -                     -                     -                     -                     - 
- government                                            1,027                   45                    -                    -                1,072                     -                     -                     -                     -                     - 
----------------------------------------- 
- asset-backed securities                                  16                   10                    -                    -                   26                     -                   (8)                     -                     -                   (8) 
Non-bank financial 
 institutions                                          10,238                  369                  243                    -               10,850                   (6)                   (5)                  (16)                     -                  (27) 
Loans and advances 
 to banks                                              10,750                   39                    -                    -               10,789                   (4)                   (1)                     -                     -                   (5) 
At 31 Dec 2021                                         67,225                8,474                2,025                    2               77,726                  (68)                 (143)                 (783)                   (2)                 (996) 
By country 
UK                                                     27,765                3,001                  832                    -               31,598                  (34)                  (43)                 (233)                     -                 (310) 
France                                                 29,287                3,492                  572                    1               33,352                  (27)                  (62)                 (396)                   (1)                 (486) 
Germany                                                 4,628                1,175                  328                    -                6,131                     -                  (17)                  (73)                     -                  (90) 
Other countries                                         5,545                  806                  293                    1                6,645                   (7)                  (21)                  (81)                   (1)                 (110) 
At 31 Dec 2021                                         67,225                8,474                2,025                    2               77,726                  (68)                 (143)                 (783)                   (2)                 (996) 
 
 
Total wholesale lending for loans and other credit-related commitments 
 and financial guarantees(1) by stage distribution 
                                                Nominal amount                                                                                  Allowance for ECL 
                    Stage             Stage                Stage                POCI         Total                 Stage                 Stage                 Stage                POCI                 Total 
                        1                 2                    3                                                       1                     2                     3 
The group            GBPm              GBPm                 GBPm                GBPm          GBPm                  GBPm                  GBPm                  GBPm                GBPm                  GBPm 
                           ----------------                       ------------------                --------------------                        -------------------- 
Corporate 
 and 
 commercial        65,582             7,369                  295                   -        73,246                  (22)                  (27)                  (15)                   -                  (64) 
Financial          50,380               826                    2                   -        51,208                   (5)                   (2)                     -                   -                   (7) 
At 31 Dec 
 2021             115,962             8,195                  297                   -       124,454                  (27)                  (29)                  (15)                   -                  (71) 
By 
geography 
                           ----------------                       ------------------                --------------------                        -------------------- 
Europe            115,962             8,195                  297                   -       124,454                  (27)                  (29)                  (15)                   -                  (71) 
- of which: 
 UK                25,662             2,910                   87                   -        28,659                  (16)                  (11)                   (3)                   -                  (30) 
- of which: 
 France            77,664             1,273                   37                   -        78,974                   (3)                   (3)                   (4)                   -                  (10) 
- of which: 
 Germany           10,113             3,693                  127                   -        13,933                   (4)                   (8)                   (1)                   -                  (13) 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

 
Total wholesale lending for loans and advances to banks and customers 
 by stage distribution (continued) 
                                                                            Gross carrying amount                                                                                           Allowance for ECL 
                                                           Stage                 Stage                 Stage                                                             Stage                 Stage                 Stage 
                                                               1                     2                     3                  POCI                 Total                     1                     2                     3                  POCI                 Total 
The group                                                   GBPm                  GBPm                  GBPm                  GBPm                  GBPm                  GBPm                  GBPm                  GBPm                  GBPm                  GBPm 
------------------------------------------ 
Corporate and commercial                                  46,773                14,052                 2,121                    41                62,987                 (100)                 (225)                 (831)                  (12)               (1,168) 
------------------------------------------ 
 
  *    agriculture, forestry and fishing                     108                     8                     9                     -                   125                     -                     -                   (5)                     -                   (5) 
------------------------------------------ 
- mining and quarrying                                     1,110                   215                   108                     -                 1,433                   (1)                   (3)                   (2)                     -                   (6) 
------------------------------------------ 
 
  *    manufacture                                         8,598                 2,900                   286                    13                11,797                  (11)                  (34)                  (93)                   (3)                 (141) 
------------------------------------------ 
 
  *    electricity, gas, steam and air-con 
 ditioning supply                                          2,532                   299                    29                     -                 2,860                   (3)                   (3)                   (5)                     -                  (11) 
 
  *    water supply, sewerage, waste manag 
 ement and 
       remediation                                           260                    44                     4                     -                   308                     -                   (2)                   (3)                     -                   (5) 
------------------------------------------ 
- construction                                               589                   265                   131                     2                   987                   (7)                  (17)                  (46)                   (2)                  (72) 
------------------------------------------ 
 
  *    wholesale and retail trade, repair 
 of motor vehicles 
       and motorcycles                                     7,074                 1,779                   283                     1                 9,137                  (10)                  (22)                 (171)                   (1)                 (204) 
------------------------------------------ 
 
  *    transportation and storage                          3,506                 2,175                   253                     -                 5,934                  (31)                  (30)                  (81)                     -                 (142) 
------------------------------------------ 
 
  *    accommodation and food                                964                   408                    23                     -                 1,395                   (2)                   (8)                  (12)                     -                  (22) 
------------------------------------------ 
 
  *    publishing, audiovisual and broadca 
 sting                                                     2,381                   424                    50                     -                 2,855                   (2)                  (16)                  (11)                     -                  (29) 
- real estate                                              5,256                 1,266                   393                     -                 6,915                  (17)                  (28)                 (194)                     -                 (239) 
------------------------------------------ 
 
  *    professional, scientific and techni 
 cal activities                                            3,219                 1,409                   179                    25                 4,832                   (3)                  (14)                  (53)                   (6)                  (76) 
 
  *    administrative and support services                 6,470                 2,336                   259                     -                 9,065                   (8)                  (19)                 (125)                     -                 (152) 
------------------------------------------ 
 
  *    public administration and defence, 
 compulsory social 
       security                                              449                   147                     -                     -                   596                   (1)                   (1)                     -                     -                   (2) 
------------------------------------------ 
- education                                                   26                    76                     1                     -                   103                     -                   (3)                   (1)                     -                   (4) 
------------------------------------------ 
- health and care                                            490                   127                     9                     -                   626                   (1)                  (10)                   (6)                     -                  (17) 
------------------------------------------ 
- arts, entertainment 
 and recreation                                              127                    85                     4                     -                   216                     -                   (3)                   (3)                     -                   (6) 
------------------------------------------ 
- other services                                           2,443                    25                   100                     -                 2,568                   (2)                   (2)                  (20)                     -                  (24) 
------------------------------------------ 
- activities of 
 households                                                    2                     -                     -                     -                     2                     -                     -                     -                     -                     - 
------------------------------------------ 
- government                                               1,153                    53                     -                     -                 1,206                   (1)                     -                     -                     -                   (1) 
------------------------------------------ 
- asset-backed securities                                     16                    11                     -                     -                    27                     -                  (10)                     -                     -                  (10) 
------------------------------------------ 
Non-bank financial 
 institutions                                             11,415                 1,748                   311                     -                13,474                  (11)                  (35)                  (47)                     -                  (93) 
------------------------------------------ 
Loans and advances 
 to banks                                                 12,533                   129                     -                     -                12,662                  (13)                   (3)                     -                     -                  (16) 
------------------------------------------ 
At 31 Dec 2020                                            70,721                15,929                 2,432                    41                89,123                 (124)                 (263)                 (878)                  (12)               (1,277) 
------------------------------------------ 
By country 
------------------------------------------ 
UK                                                        32,869                 7,695                 1,097                     2                41,663                  (87)                 (147)                 (310)                   (2)                 (546) 
------------------------------------------ 
France                                                    25,378                 4,514                   739                     2                30,633                  (16)                  (55)                 (417)                   (2)                 (490) 
------------------------------------------ 
Germany                                                    5,460                 1,692                   334                     -                 7,486                   (4)                  (20)                  (68)                     -                  (92) 
------------------------------------------ 
Other countries                                            7,014                 2,028                   262                    37                 9,341                  (17)                  (41)                  (83)                   (8)                 (149) 
------------------------------------------ 
At 31 Dec 2020                                            70,721                15,929                 2,432                    41                89,123                 (124)                 (263)                 (878)                  (12)               (1,277) 
------------------------------------------ 
 

.

 
Total wholesale lending for loans and other credit-related commitments 
 and financial guarantees(1) by stage distribution (continued) 
                                                  Nominal amount                                                                                       Allowance for ECL 
                     Stage            Stage                 Stage                                                       Stage                 Stage                  Stage 
                         1                2                     3                  POCI          Total                      1                     2                      3                POCI                     Total 
The group             GBPm             GBPm                  GBPm                  GBPm           GBPm                   GBPm                  GBPm                   GBPm                GBPm                      GBPm 
Corporate 
 and 
 commercial         67,077           11,141                   379                     1         78,598                   (32)                  (58)                   (18)                   -                     (108) 
Financial           62,701            3,459                     4                     -         66,164                    (6)                  (19)                    (1)                   -                      (26) 
At 31 Dec 
 2020              129,778           14,600                   383                     1        144,762                   (38)                  (77)                   (19)                   -                     (134) 
By 
geography 
Europe             129,778           14,600                   383                     1        144,762                   (38)                  (77)                   (19)                   -                     (134) 
- of which: 
 UK                 34,908            6,066                   109                     -         41,083                   (29)                  (51)                   (12)                   -                      (92) 
- of which: 
 France             80,356            1,992                    49                     -         82,397                    (3)                   (9)                    (3)                   -                      (15) 
- of which: 
 Germany            11,208            5,711                   193                     -         17,112                    (2)                   (9)                    (1)                   -                      (12) 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

Collateral and other credit enhancement

(Audited)

Although collateral can be an important mitigant of credit risk, it is the group's practice to lend on the basis of the customer's ability to meet their obligations out of cash flow resources rather than placing primary reliance on collateral and other credit risk enhancements. Depending on the customer's standing and the type of product, facilities may be provided without any collateral or other credit enhancements. For other lending, a charge over collateral is obtained and considered in determining the credit decision and pricing. In the event of default, the group may utilise the collateral as a source of repayment.

Depending on its form, collateral can have a significant financial effect in mitigating our exposure to credit risk. Where there is sufficient collateral, an expected credit loss is not recognised. This is the case for reverse repurchase agreements and for certain loans and advances to customers where the loan to value ('LTV') is very low.

Mitigants may include a charge on borrowers' specific assets, such as real estate or financial instruments. Other credit risk mitigants include short positions in securities and financial assets held as part of linked insurance/investment contracts where the risk is predominantly borne by the policyholder. Additionally, risk may be managed by employing other types of collateral and credit risk enhancements, such as second charges, other liens and unsupported guarantees. Guarantees are normally taken from corporates and export credit agencies. Corporates would normally provide guarantees as part of a parent/subsidiary relationship and span a number of credit grades. The export credit agencies will normally be investment grade.

Certain credit mitigants are used strategically in portfolio management activities. While single name concentrations arise in portfolios managed by Global Banking and Commercial Banking, it is only in Global Banking that their size requires the use of portfolio level credit mitigants. Across Global Banking, risk limits and utilisations, maturity profiles and risk quality are monitored and managed proactively. This process is key to the setting of risk appetite for these larger, more complex, geographically distributed customer groups. While the principal form of risk management continues to be at the point of exposure origination, through the lending decision-making process, Global Banking also utilises loan sales and credit default swap ('CDS') hedges to manage concentrations and reduce risk. These transactions are the responsibility of a dedicated Global Banking portfolio management team. Hedging activity is carried out within agreed credit parameters, and is subject to market risk limits and a robust governance structure. Where applicable, CDSs are entered into directly with a central clearing house counterparty. Otherwise our

exposure to CDS protection providers is diversified among mainly banking counterparties with strong credit ratings.

CDS mitigants are held at portfolio level and are not included in the expected loss calculations. CDS mitigants are not reported in the following tables.

Collateral on loans and advances

The following tables include off-balance sheet loan commitments, primarily undrawn credit lines.

The collateral measured in the following tables consists of charges over cash and marketable financial instruments. The values in the tables represent the expected market value on an open market basis. No adjustment has been made to the collateral for any expected costs of recovery. Marketable securities are measured at their fair value.

Other types of collateral such as unsupported guarantees and floating charges over the assets of a customer's business are not measured in the following tables. While such mitigants have value, often providing rights in insolvency, their assignable value is not sufficiently certain and they are therefore assigned no value for disclosure purposes.

The LTV ratios presented are calculated by directly associating loans and advances with the collateral that individually and uniquely supports each facility. When collateral assets are shared by multiple loans and advances, whether specifically or, more generally, by way of an all monies charge, the collateral value is pro-rated across the loans and advances protected by the collateral.

For credit-impaired loans, the collateral values cannot be directly compared with impairment allowances recognised. The LTV figures use open market values with no adjustments. Impairment allowances are calculated on a different basis, by considering other cash flows and adjusting collateral values for costs of realising collateral as explained further on page 122.

Other corporate, commercial and financial (non-bank) loans and advances

Other corporate, commercial and financial (non-bank) loans are analysed separately in the following table, which focuses on the countries containing the majority of our loans and advances balances. For financing activities in other corporate and commercial lending, collateral value is not strongly correlated to principal repayment performance.

Collateral values are generally refreshed when an obligor's general credit performance deteriorates and we have to assess the likely performance of secondary sources of repayment should it prove necessary to rely on them.

 
Wholesale lending - corporate, commercial and financial (non-bank) 
 loans and advances including loan commitments by level of 
 collateral for key countries by stage (excluding commercial real estate) 
(Audited) 
                                                                                                                                  Of which: 
                                    Total                                              UK                                             France                                        Germany 
                                   Gross                                           Gross                                             Gross                                         Gross 
                        carrying/nominal                                carrying/nominal                                  carrying/nominal                              carrying/nominal 
                                  amount          ECL coverage                    amount            ECL coverage                    amount          ECL coverage                  amount          ECL coverage 
The group                           GBPm                     %                      GBPm                       %                      GBPm                     %                    GBPm                     % 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Stage 1 
Not 
collateralised                   109,435                   0.1                    40,298                     0.1                    52,583                     -                  11,479                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Fully 
collateralised                    10,399                   0.1                     6,133                     0.1                     2,221                   0.1                     708                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
LTV ratio: 
- less than 
50%                                2,450                   0.2                     1,649                     0.1                       587                     -                       -                     - 
- 51% to 75%                       3,543                   0.1                     2,124                       -                       989                   0.1                       -                     - 
- 76% to 90%                         801                   0.1                       446                       -                       349                     -                       -                     - 
- 91% to 100%                      3,605                     -                     1,914                       -                       296                     -                     708                     - 
Partially 
collateralised 
(A):                               3,424                   0.1                        85                       -                     3,248                   0.1                       -                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
- collateral 
value 
on A                               2,661                                              51                                             2,555                                             - 
                ------------------------                        ------------------------                          ------------------------                        ---------------------- 
Total Stage 1                    123,258                   0.1                    46,516                     0.1                    58,052                     -                  12,187                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Stage 2 
Not 
collateralised                    11,024                   0.9                     4,365                     0.9                     1,890                   1.5                   3,942                   0.6 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Fully 
collateralised                     1,675                   1.1                       608                     0.8                       639                   1.1                     243                   0.4 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
LTV ratio: 
- less than 
50%                                  689                   1.7                       217                     1.4                       350                   1.1                       -                     - 
- 51% to 75%                         253                   0.8                       217                     0.9                        34                   2.9                       -                     - 
- 76% to 90%                         271                   0.4                       165                       -                       106                   0.9                       -                     - 
- 91% to 100%                        462                   0.9                         9                       -                       149                   1.3                     243                   0.4 
Partially 
collateralised 
(B):                               1,573                   0.9                         4                       -                     1,567                   0.9                       -                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
- collateral 
value 
on B                               1,408                                               3                                             1,404                                             - 
                ------------------------                        ------------------------                          ------------------------                        ---------------------- 
Total Stage 2                     14,272                   0.9                     4,977                     0.9                     4,096                   1.2                   4,185                   0.5 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Stage 3 
Not 
collateralised                     1,598                  37.2                       669                    25.1                       378                  86.0                     393                  17.8 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Fully 
collateralised                       148                  16.2                        77                     7.8                        10                  50.0                      24                  16.7 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
LTV ratio: 
- less than 
50%                                   76                  18.4                        41                     7.3                         6                  50.0                       -                     - 
- 51% to 75%                          22                  13.6                        19                    10.5                         2                  50.0                       -                     - 
- 76% to 90%                          18                   5.6                        17                       -                         1                     -                       -                     - 
- 91% to 100%                         32                  15.6                         -                       -                         1                 100.0                      24                  16.7 
Partially 
collateralised 
(C):                                 216                  27.3                        35                    17.1                       165                  27.3                       -                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
- collateral 
value 
on C                                 152                                              22                                               123                                             - 
                ------------------------                        ------------------------                          ------------------------                        ---------------------- 
Total Stage 3                      1,962                  34.6                       781                    23.0                       553                  67.8                     417                  17.7 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
POCI 
Not                                    -                     -                         -                       -                         -                     -                       -                     - 
collateralised 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
Fully                                  -                     -                         -                       -                         -                     -                       -                     - 
collateralised 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
LTV ratio: 
- less than                            -                     -                         -                       -                         -                     -                       -                     - 
50% 
- 51% to 75%                           -                     -                         -                       -                         -                     -                       -                     - 
- 76% to 90%                           -                     -                         -                       -                         -                     -                       -                     - 
- 91% to 100%                          -                     -                         -                       -                         -                     -                       -                     - 
Partially 
collateralised 
(D):                                   2                 100.0                         -                       -                         2                 100.0                       -                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
- collateral 
value 
on D                                   2                                               -                                                 2                                             - 
                ------------------------                        ------------------------                          ------------------------                        ---------------------- 
Total POCI                             2                 100.0                         -                       -                         2                 100.0                       -                     - 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
At 31 Dec 2021                   139,494                   0.6                    52,274                     0.5                    62,703                   0.7                  16,789                   0.6 
                ------------------------  --------------------  ------------------------  ----------------------  ------------------------  --------------------  ----------------------  -------------------- 
 
 
Wholesale lending - corporate, commercial and financial (non-bank) 
 loans and advances including loan commitments by level of 
 collateral for key countries by stage (excluding commercial real estate) 
 (continued) 
(Audited) 
                                                                                                      Of which: 
                              Total                                 UK                                France                               Germany 
                                   Gross                               Gross                               Gross                              Gross 
                        carrying/nominal       ECL          carrying/nominal       ECL          carrying/nominal       ECL         carrying/nominal 
                                  amount  coverage                    amount  coverage                    amount  coverage                   amount  ECL coverage 
The group                           GBPm         %                      GBPm         %                      GBPm         %                     GBPm             % 
Stage 1 
                                          --------                            --------                            -------- 
Not 
collateralised                   117,820       0.1                    49,970       0.1                    47,647         -                   13,685             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
Fully 
collateralised                    12,232       0.1                     8,241       0.2                     2,163         -                      638             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
LTV ratio: 
- less than 
50%                                1,886       0.3                     1,019       0.3                       543         -                        -             - 
- 51% to 75%                       4,403       0.2                     3,489       0.2                       901         -                        -             - 
- 76% to 90%                         751       0.1                       267       0.4                       360         -                        -             - 
- 91% to 100%                      5,192         -                     3,466         -                       359         -                      638             - 
Partially 
collateralised 
(A):                               3,476       0.1                        59         -                     3,167       0.1                        -             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
- collateral 
value on 
A                                  2,855                                  32                               2,621                                  - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  ----------------------- 
Total Stage 1                    133,528       0.1                    58,270       0.1                    52,977         -                   14,323             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
Stage 2 
                                          --------                            --------                            -------- 
Not 
collateralised                    23,132       1.0                    12,398       1.2                     2,447       1.1                    6,220           0.4 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
Fully 
collateralised                     1,838       1.2                       630       1.0                       649       1.1                      290           0.3 
LTV ratio: 
- less than 
50%                                  824       1.5                       326       1.2                       348       0.6                        -             - 
- 51% to 75%                         334       1.2                       269       0.4                        45       2.2                        -             - 
- 76% to 90%                          47       2.1                        26       3.8                        17         -                        -             - 
- 91% to 100%                        633       0.8                         9         -                       239       1.3                      290           0.3 
Partially 
collateralised 
(B):                               2,629       0.7                        87       2.3                     2,528       0.6                        -             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
- collateral 
value on 
B                                  2,223                                  14                               2,200                                  - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  ----------------------- 
Total Stage 2                     27,599       1.0                    13,115       1.2                     5,624       0.9                    6,510           0.4 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
Stage 3 
                                          --------                            --------                            -------- 
Not 
collateralised                     1,803      36.3                       740      29.7                       529      63.9                      441          15.2 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
Fully 
collateralised                       210       9.5                       152       1.3                        12      66.7                       21          14.3 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
LTV ratio: 
- less than 
50%                                   25      28.0                         2         -                         7      57.1                        -             - 
- 51% to 75%                          27      29.6                        17       5.9                         3      66.7                        -             - 
- 76% to 90%                         120       0.8                       118       0.8                         1     100.0                        -             - 
- 91% to 100%                         38      10.5                        15         -                         1     100.0                       21          14.3 
Partially 
collateralised 
(C):                                 275      24.0                        71      11.3                       191      26.2                        -             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
- collateral 
value on 
C                                    182                                  40                                 136                                  - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  ----------------------- 
Total Stage 3                      2,288      32.4                       963      23.9                       732      54.1                      462          15.2 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
POCI 
                                          --------                            --------                            -------- 
Not 
collateralised                        37      27.0                         2     100.0                         -         -                        -             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
Fully                                  -         -                         -         -                         -         -                        -             - 
collateralised 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
LTV ratio: 
- less than                            -         -                         -         -                         -         -                        -             - 
50% 
- 51% to 75%                           -         -                         -         -                         -         -                        -             - 
- 76% to 90%                           -         -                         -         -                         -         -                        -             - 
- 91% to 100%                          -         -                         -         -                         -         -                        -             - 
Partially 
collateralised 
(D):                                   3     100.0                         -         -                         3     100.0                        -             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
- collateral 
value on 
D                                      3                                   -                                   3                                  - 
                ------------------------  --------  ------------------------  --------  ------------------------            ----------------------- 
Total POCI                            40      32.5                         2     100.0                         3     100.0                        -             - 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
At 31 Dec 2020                   163,455       0.7                    72,350       0.7                    59,336       0.8                   21,295           0.5 
                ------------------------  --------  ------------------------  --------  ------------------------  --------  -----------------------  ------------ 
 

.

Other credit risk exposures

In addition to collateralised lending, other credit enhancements are employed and methods used to mitigate credit risk arising from financial assets. These are described in more detail below:

-- Some securities issued by governments, banks and other financial institutions benefit from additional credit enhancement provided by government guarantees that cover the assets;

-- Debt securities issued by banks and financial institutions include asset-backed securities ('ABSs') and similar instruments which are supported by underlying pools of financial assets. Credit risk associated with ABSs is reduced through the purchase of credit default swap ('CDS') protection;

-- Trading loan and advances mainly pledged against cash collaterals are posted to satisfy margin requirements. There is

--

limited credit risk on trading loans and advances since in the event of default of the counterparty these would be set off against the related liability. Reverse repos and stock borrowings are by their nature collateralised.

Collateral accepted as security that the group is permitted to sell or repledge under these arrangements is described on page 155 of the financial statements.

-- The group's maximum exposure to credit risk includes financial guarantees and similar contracts granted; as well as loan and other credit-related commitments. Depending on the terms of the arrangement, we may use additional credit mitigation if a guarantee is called upon or a loan commitment is drawn and subsequently defaults.

For further information on these arrangements, see Note 30 on the financial statements.

Derivatives

We participate in transactions exposing us to counterparty credit risk. Counterparty credit risk is the risk of financial loss if the counterparty to a transaction defaults before satisfactorily settling it. It arises principally from over-the-counter ('OTC') derivatives and securities financing transactions and is calculated in both the trading and non-trading books. Transactions vary in value by reference to market factors such as interest rates, exchange rates or asset prices.

The counterparty risk from derivative transactions is taken into account when reporting the fair value of derivative positions. The adjustment to the fair value is known as the credit value adjustment ('CVA').

The International Swaps and Derivatives Association ('ISDA') master agreement is our preferred agreement for documenting derivatives activity. It is common, and our preferred practice, for the parties involved in a derivative transaction to execute a credit support annex ('CSA') in conjunction with the ISDA master agreement. Under a CSA, collateral is passed between the parties to mitigate the counterparty risk inherent in outstanding positions. The majority of our CSAs are with financial institutional clients. We manage the counterparty exposure on our OTC derivative contracts by using collateral agreements with counterparties and

netting agreements. Currently, we do not actively manage our general OTC derivative counterparty exposure in the credit markets, although we may manage individual exposures in certain circumstances.

We place strict policy restrictions on collateral types and as a consequence the types of collateral received and pledged are, by value, highly liquid and of a strong quality, being predominantly USD, EUR and GBP cash and G7 Government Bonds.

Where a collateral type is required to be approved outside the collateral policy, approval is required from a committee of senior representatives from Markets, Legal and Risk.

See Note 28 on the financial statements for details regarding legally enforceable right of offset in the event of counterparty default and collateral received in respect of derivatives

Personal lending

This section provides further details on the countries and products comprising personal loans and advances to customers.

Further product granularity is also provided by stage, with geographical data presented for loans and advances to customers, loan and other credit-related commitments, and financial guarantees.

 
Total personal lending for loans and advances to customers at amortised 
 costs by stage distribution 
                                                                                Gross carrying amount                                                                    Allowance for ECL 
                                                               Stage                 Stage                 Stage              Total                  Stage                  Stage                  Stage                  Total 
                                                                   1                     2                     3                                         1                      2                      3 
The group                                                       GBPm                  GBPm                  GBPm               GBPm                   GBPm                   GBPm                   GBPm                   GBPm 
By portfolio 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
First lien residential mortgages                               6,723                   173                   234              7,130                   (11)                    (5)                   (65)                   (81) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
  *    of which: interest only (including offset)              3,134                   115                    94              3,343                    (1)                    (2)                   (27)                   (30) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
  *    affordability including ARMs                              451                     2                     6                459                    (3)                      -                    (1)                    (4) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
Other personal lending                                        17,532                   513                   219             18,264                   (11)                   (11)                   (60)                   (82) 
- guaranteed loans in respect 
 of residential property                                      14,387                   332                    38             14,757                    (5)                    (2)                    (1)                    (8) 
- Other personal lending 
 which is secured                                              2,535                   136                   100              2,771                    (3)                    (4)                   (24)                   (31) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
- credit cards                                                   318                    22                    11                351                    (1)                    (2)                    (1)                    (4) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
- Other personal lending 
 which is unsecured                                              292                    23                    70                385                    (2)                    (3)                   (34)                   (39) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
At 31 Dec 2021                                                24,255                   686                   453             25,394                   (22)                   (16)                  (125)                  (163) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
By geography 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
UK(1)                                                          3,543                    88                    49              3,680                    (1)                    (3)                    (3)                    (7) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
France                                                        18,500                   497                   239             19,236                   (10)                   (10)                   (75)                   (95) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
Germany                                                          161                    47                     -                208                      -                      -                      -                      - 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
Other countries                                                2,051                    54                   165              2,270                   (11)                    (3)                   (47)                   (61) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
At 31 Dec 2021                                                24,255                   686                   453             25,394                   (22)                   (16)                  (125)                  (163) 
                                                   -----------------  --------------------  --------------------  -----------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
 
Total personal lending for loans and other credit-related commitments 
 and financial guarantees(2) by stage distribution 
                                             Nominal amount                                                                     Allowance for ECL 
                        Stage                 Stage                 Stage              Total                  Stage                Stage                Stage                  Total 
                            1                     2                     3                                         1                    2                    3 
The group                GBPm                  GBPm                  GBPm               GBPm                   GBPm                 GBPm                 GBPm                   GBPm 
UK                        586                     3                     2                591                      -                    -                    -                      - 
France                  1,076                    20                     2              1,098                      -                    -                    -                      - 
Germany                   136                    85                     -                221                      -                    -                    -                      - 
            -----------------  --------------------  --------------------  -----------------  ---------------------  -------------------  -------------------  --------------------- 
Other 
 countries                377                     8                     -                385                    (1)                    -                    -                    (1) 
At 31 Dec 
 2021                   2,175                   116                     4              2,295                    (1)                    -                    -                    (1) 
            -----------------  --------------------  --------------------  -----------------  ---------------------  -------------------  -------------------  --------------------- 
 
   1   Includes primarily first lien residential mortgages in Channel Islands and Isle of Man. 

2 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

 
Total personal lending for loans and advances to customers at amortised 
 costs by stage distribution (continued) 
                                                                                  Gross carrying amount                                                                      Allowance for ECL 
                                                                Stage                  Stage                  Stage                                      Stage                  Stage                  Stage 
                                                                    1                      2                      3               Total                      1                      2                      3                  Total 
The group                                                        GBPm                   GBPm                   GBPm                GBPm                   GBPm                   GBPm                   GBPm                   GBPm 
By portfolio 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
First lien residential mortgages                                7,087                    211                    265               7,563                    (9)                   (10)                   (77)                   (96) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
  *    of which: interest only (including offset)               3,454                    151                    115               3,720                    (1)                    (3)                   (30)                   (34) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
- affordability including 
 ARMs                                                             394                      2                      4                 400                    (2)                      -                    (1)                    (3) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
Other personal lending                                         17,904                    763                    269              18,936                    (9)                   (27)                   (76)                  (112) 
- guaranteed loans in respect 
 of residential property                                       14,625                    434                     45              15,104                    (2)                    (4)                    (3)                    (9) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
- Other personal lending 
 which is secured                                               2,521                     94                    141               2,756                    (3)                    (7)                   (27)                   (37) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
- credit cards                                                    288                     37                     14                 339                    (2)                    (6)                    (1)                    (9) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
- Other personal lending 
 which is unsecured                                               470                    198                     68                 736                    (2)                   (10)                   (45)                   (57) 
At 31 Dec 2020                                                 24,991                    974                    534              26,499                   (18)                   (37)                  (153)                  (208) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
By geography 
UK(1)                                                           3,455                     70                     57               3,582                    (2)                    (9)                    (5)                   (16) 
France                                                         19,230                    689                    296              20,215                    (7)                   (20)                   (92)                  (119) 
Germany                                                           124                    145                      -                 269                      -                      -                      -                      - 
Other countries                                                 2,182                     70                    181               2,433                    (9)                    (8)                   (56)                   (73) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
At 31 Dec 2020                                                 24,991                    974                    534              26,499                   (18)                   (37)                  (153)                  (208) 
                                                   ------------------  ---------------------  ---------------------  ------------------  ---------------------  ---------------------  ---------------------  --------------------- 
 
 
Total personal lending for loans and other credit-related commitments 
 and financial guarantees(2) by stage distribution (continued) 
                                                      Nominal amount                                                                                     Allowance for ECL 
                              Stage                     Stage                     Stage                                          Stage                      Stage                   Stage 
                                  1                         2                         3                  Total                       1                          2                       3                      Total 
The group                      GBPm                      GBPm                      GBPm                   GBPm                    GBPm                       GBPm                    GBPm                       GBPm 
UK                              340                        15                         -                    355                       -                          -                       -                          - 
France                        1,170                        29                         3                  1,202                       -                          -                       -                          - 
Germany                          65                       170                         -                    235                       -                          -                       -                          - 
            -----------------------  ------------------------  ------------------------  ---------------------  ----------------------  -------------------------  ----------------------  ------------------------- 
Other 
 countries                      442                         8                         1                    451                       -                        (1)                       -                        (1) 
At 31 Dec 
 2020                         2,017                       222                         4                  2,243                       -                        (1)                       -                        (1) 
            -----------------------  ------------------------  ------------------------  ---------------------  ----------------------  -------------------------  ----------------------  ------------------------- 
 
   1   Includes primarily first lien residential mortgages in Channel Islands and Isle of Man. 

2 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

Collateral on loans and advances

The following table provides a quantification of the value of fixed charges we hold over specific assets where we have a history of enforcing, and are able to enforce, collateral in satisfying a debt in the event of the borrower failing to meet its contractual

obligations, and where the collateral is cash or can be realised by sale in an established market.

The collateral valuation excludes any adjustment for obtaining and selling the collateral and in particular loans shown as collateralised or partially collateralised may also benefit from other forms of credit mitigants.

 
Personal lending: residential mortgage loans including loan commitments 
 by level of collateral for key countries 
(Audited) 
                                                                                Of which: 
                            Total                                  UK                                  France 
                               Gross       ECL                 Gross                  ECL                 Gross        ECL 
                            exposure  coverage              exposure             coverage              exposure   coverage 
The group                       GBPm         %                  GBPm                    %                  GBPm          % 
Stage 1 
Fully 
collateralised                 6,915       0.2                 2,789                    -                 2,088          - 
                --------------------            --------------------                       -------------------- 
LTV ratio: 
- less than 
50%                            3,400       0.1                 1,308                    -                 1,110        0.1 
- 51% to 60%                   1,274       0.2                   540                    -                   431          - 
- 61% to 70%                   1,074       0.2                   452                    -                   296          - 
- 71% to 80%                     776       0.3                   358                    -                   177          - 
- 81% to 90%                     345       0.3                   113                    -                    48          - 
- 91% to 100%                     46         -                    18                    -                    26          - 
                --------------------            --------------------                       -------------------- 
Partially 
collateralised 
(A):                              90         -                    11                    -                    50          - 
                --------------------            --------------------                       -------------------- 
LTV ratio: 
- 101% to 110%                    18         -                     2                    -                    12          - 
- 111% to 120%                     9         -                     1                    -                     5          - 
- greater than 
120%                              63         -                     8                    -                    33          - 
                --------------------            --------------------                       -------------------- 
- collateral 
value on A                        63                               4                                         50 
                --------------------            --------------------                       -------------------- 
Total                          7,005       0.2                 2,800                    -                 2,138          - 
                --------------------            --------------------                       -------------------- 
Stage 2 
Fully 
collateralised                   169       3.0                    46                    -                    83        1.2 
                --------------------            --------------------                       -------------------- 
LTV ratio: 
- less than 
50%                               91       2.2                    18                    -                    48        2.1 
- 51% to 60%                      25       4.0                     6                    -                    13          - 
- 61% to 70%                      34       2.9                    17                    -                    12          - 
- 71% to 80%                      15       6.7                     5                    -                     7          - 
- 81% to 90%                       3         -                     -                    -                     2          - 
- 91% to 100%                      1         -                     -                    -                     1          - 
                --------------------            --------------------                       -------------------- 
Partially 
collateralised 
(B):                               5         -                     -                    -                     2          - 
                --------------------            --------------------  -------------------  -------------------- 
LTV ratio: 
- 101% to 110%                     1         -                     -                    -                     -          - 
- 111% to 120%                     1         -                     -                    -                     -          - 
- greater than 
120%                               3         -                     -                    -                     2          - 
                --------------------            --------------------                       -------------------- 
- collateral 
value on B                         4                               -                                          3 
                --------------------            --------------------                       -------------------- 
Total                            174       2.9                    46                    -                    85        1.2 
                --------------------            --------------------  -------------------  -------------------- 
Stage 3 
Fully 
collateralised                   204      24.5                     9                 11.1                    62       21.0 
                --------------------            --------------------                       -------------------- 
LTV ratio: 
- less than 
50%                               94      12.8                     6                 16.7                    24       20.8 
- 51% to 60%                      31      19.4                     3                    -                     8       25.0 
- 61% to 70%                      34      23.5                     -                    -                    19       10.5 
- 71% to 80%                      13      38.5                     -                    -                     3       33.3 
- 81% to 90%                      14      42.9                     -                    -                     4       25.0 
- 91% to 100%                     18      72.2                     -                    -                     4       50.0 
                --------------------            --------------------                       -------------------- 
Partially 
collateralised 
(C):                              30      53.3                     -                    -                    24       58.3 
                --------------------            --------------------                       -------------------- 
LTV ratio: 
- 101% to 110%                     2      50.0                     -                    -                     2       50.0 
- 111% to 120%                     2      50.0                     -                    -                     2       50.0 
- greater than 
120%                              26      53.8                     -                    -                    20       60.0 
                --------------------            --------------------                       -------------------- 
- collateral 
value on C                         6                               -                                          6 
                --------------------            --------------------                       -------------------- 
Total                            234      28.2                     9                 11.1                    86       31.4 
                --------------------            --------------------                       -------------------- 
At 31 Dec 2021                 7,413       1.1                 2,855                    -                 2,309        1.3 
                --------------------            --------------------                       -------------------- 
 
 
Personal lending: residential mortgage loans including loan commitments 
 by level of collateral for key countries (continued) 
(Audited) 
                                                                                  Of which: 
                             Total                                   UK                                   France 
                                Gross       ECL                  Gross                  ECL                  Gross        ECL 
                             exposure  coverage               exposure             coverage               exposure   coverage 
The group                        GBPm         %                   GBPm                    %                   GBPm          % 
Stage 1 
                ---------------------  --------  ---------------------  -------------------  ---------------------  --------- 
Fully 
collateralised                  7,308       0.1                  2,751                    -                  2,364          - 
                ---------------------            ---------------------                       --------------------- 
LTV ratio: 
- less than 
50%                             3,110       0.1                  1,018                    -                  1,147          - 
- 51% to 60%                    1,074       0.1                    293                    -                    513          - 
- 61% to 70%                      991       0.1                    316                    -                    378          - 
- 71% to 80%                      789       0.3                    214                    -                    225          - 
- 81% to 90%                      505       0.4                    109                    -                     70          - 
- 91% to 100%                     839       0.1                    801                    -                     31          - 
                ---------------------            ---------------------                       --------------------- 
Partially 
collateralised 
(A):                               90         -                      9                    -                     63          - 
                ---------------------            ---------------------                       --------------------- 
LTV ratio: 
- 101% to 110%                     21         -                      -                    -                     13          - 
- 111% to 120%                     14         -                      2                    -                     10          - 
- greater than 
120%                               55         -                      7                    -                     40          - 
                ---------------------            ---------------------                       --------------------- 
- collateral 
value on A                         81                                5                                          63 
                ---------------------            ---------------------                       --------------------- 
Total                           7,398       0.1                  2,760                    -                  2,427          - 
                ---------------------            ---------------------                       --------------------- 
Stage 2 
Fully 
collateralised                    202       4.0                     34                  2.9                    116        0.9 
                ---------------------            ---------------------                       --------------------- 
LTV ratio: 
- less than 
50%                               114       1.8                     17                    -                     64        1.6 
- 51% to 60%                       31       3.2                      4                    -                     21          - 
- 61% to 70%                       22       4.5                      -                    -                     17          - 
- 71% to 80%                       15      13.3                      -                    -                     10          - 
- 81% to 90%                        6      16.7                      -                    -                      3          - 
- 91% to 100%                      14       7.1                     13                  7.7                      1          - 
                ---------------------            ---------------------                       --------------------- 
Partially 
collateralised 
(B):                               10      20.0                      -                    -                      5          - 
                ---------------------            ---------------------                       --------------------- 
LTV ratio: 
- 101% to 110%                      4      25.0                      -                    -                      2          - 
- 111% to 120%                      2      50.0                      -                    -                      -          - 
- greater than 
120%                                4         -                      -                    -                      3          - 
                ---------------------            ---------------------                       --------------------- 
- collateral 
value on B                         10                                -                                           5 
                ---------------------            ---------------------                       --------------------- 
Total                             212       4.7                     34                  2.9                    121        0.8 
                ---------------------            ---------------------  -------------------  --------------------- 
Stage 3 
Fully 
collateralised                    200      22.0                     12                  8.3                     69       23.2 
                ---------------------            ---------------------                       --------------------- 
LTV ratio: 
- less than 
50%                                95      13.7                      8                 12.5                     30       23.3 
- 51% to 60%                       34      23.5                      3                    -                     10       30.0 
- 61% to 70%                       34      26.5                      -                    -                     16       12.5 
- 71% to 80%                       23      34.8                      1                    -                      7       28.6 
- 81% to 90%                        9      44.4                      -                    -                      2       50.0 
- 91% to 100%                       5      40.0                      -                    -                      4       25.0 
                ---------------------            ---------------------                       --------------------- 
Partially 
collateralised 
(C):                               65      50.8                      -                    -                     36       38.9 
                ---------------------            ---------------------                       --------------------- 
LTV ratio: 
- 101% to 110%                     10      60.0                      -                    -                      3       33.3 
- 111% to 120%                      8      62.5                      -                    -                      1          - 
- greater than 
120%                               47      46.8                      -                    -                     32       40.6 
                ---------------------            ---------------------                       --------------------- 
- collateral 
value on C                         35                                -                                          17 
                ---------------------            ---------------------                       --------------------- 
Total                             265      29.1                     12                  8.3                    105       28.6 
                ---------------------            ---------------------                       --------------------- 
At 31 Dec 2020                  7,875       1.2                  2,806                  0.1                  2,653        1.2 
                ---------------------            ---------------------                       --------------------- 
 
 
Treasury risk 
 

Overview

Treasury risk is the risk of having insufficient capital, liquidity or funding resources to meet financial obligations and satisfy regulatory requirements, together with the financial risks arising from the provision of pensions and other post-employment benefits to staff and their dependants. Treasury risk also includes the risk to our earnings or capital due to non-trading book foreign exchange exposures and changes in market interest rates.

Treasury risk arises from changes to the respective resources and risk profiles driven by customer behaviour, management decisions or the external environment.

Approach and policy

(Audited)

Our objective in the management of treasury risk is to maintain appropriate levels of capital, liquidity, funding, foreign exchange and market risk to support our business strategy, and meet our regulatory and stress testing-related requirements.

Our approach to treasury management is driven by our strategic and organisational requirements, taking into account the regulatory, economic and commercial environment. We aim to maintain a strong capital and liquidity base to support the risks inherent in our business and invest in accordance with our strategy, meeting regulatory requirements at all times.

Our policy is underpinned by our risk management framework, our internal capital adequacy assessment process ('ICAAP') and our internal liquidity adequacy assessment process ('ILAAP'). The risk framework incorporates a number of measures aligned to our assessment of risks for both internal and regulatory purposes. These risks include credit, market, operational, pensions, non-trading book foreign exchange risk, and interest rate risk in the banking book.

Treasury risk management

Key developments in 2021

-- Global Treasury initiated a new flagship programme to deliver a more resilient, effective and efficient Treasury function over the next 3 years with a focus on optimising and safeguarding financial resources. The programme will deliver modernised infrastructure and upgraded modelling capabilities alongside a broad re-organisation of the Treasury function.

-- We continued to build our recovery and resolution capabilities, including in relation to the Bank of England ('BoE') Resolvability Assessment Framework, which had an overall compliance deadline of 1 January 2022. The HSBC Group submitted a self-assessment report on its resolvability to the Prudential Regulation Authority ('PRA') and the BoE on 1 October 2021. This included an assessment of how we addressed resolvability outcomes that impact treasury risk, including valuations, and capital, liquidity and funding capabilities in resolution. The HSBC Group will publish a summary of its self-assessment report in June 2022. The BoE will similarly publish a statement relating to the resolvability of the HSBC Group at the same time.

-- The BoE's Financial Policy Committee ('FPC') confirmed its guidance on the path for the UK countercyclical capital buffer rate. It has announced that it is increasing the rate from 0% to 1%, effective December 2022 in line with the usual 12--month implementation lag. Absent a material change in the outlook for the UK's financial stability, the FPC would expect to further increase the rate to 2% in the second quarter of 2022, which would take effect 12 months later. As part of our ongoing focus on enhancing the quality of our regulatory reporting, we are progressing with a comprehensive programme to strengthen our global processes, improve consistency and enhance control standards on various aspects of regulatory reporting. Further details can be found in the subsequent sub-section 'Regulatory reporting processes and controls'.

-- We worked with the fiduciaries of all our pension plans to ensure the measures taken in response to the Covid-19 pandemic, including remote working for plan providers and dealing appropriately with affected plan members, were properly maintained and supported. Our de-risking programmes continued to provide protection against the volatility in financial markets that resulted from the pandemic's economic impact.

-- A new team was created within the Global Treasury function to be accountable for monitoring and managing the financial risk and capital implications of the HSBC Group's employee defined benefit pension plans. This change creates clearer delineation of the roles and responsibilities of the first and second lines of defence.

The group's CET1 ratio was 17.3% at 31 December 2021 and the leverage ratio was 4.1%. The group continues to maintain and plan for the appropriate resources required to manage its risk and deliver its strategic objectives, including the sale of the retail banking business in France.

Governance and structure

The Chief Risk Officer is the accountable risk steward for all treasury risks. The Chief Financial Officer is the risk owner for treasury risks with the exception of pension risk which is co-owned together with the regional heads of Performance & Reward.

Capital, liquidity, interest rate risk in the banking book and non-trading book foreign exchange risk are the responsibility of the Executive Committee and the Risk Committee. The Treasury function actively manages these risks on an on-going basis,

supported by the Asset and Liability Management Committee ('ALCO'), overseen by Treasury Risk Management and the Risk Management Meeting ('RMM').

Pension risk is overseen by the Pension Risk Management Meeting.

Capital, liquidity and funding risk management processes

Assessment and risk appetite

Our capital management policy is underpinned by a global capital management framework and our ICAAP. The framework incorporates key capital risk appetites for CET1, total capital, minimum requirements for own funds and eligible liabilities ('MREL'), and leverage. The ICAAP is an assessment of the Group's capital position, outlining both regulatory and internal capital resources and requirements resulting from our business model, strategy, risk profile and management, performance and planning, risks to capital, and the implications of stress testing. Our assessment of capital adequacy is driven by an assessment of risks. These risks include credit, market, operational, pensions, insurance, structural foreign exchange, and interest rate risk in the banking book. Climate risk is also considered as part of the ICAAP, and we are continuing to develop our approach. The Group's ICAAP supports the determination of the capital risk appetite and target ratios, as well as enables the assessment and determination of capital requirements by regulators. Subsidiaries prepare ICAAPs in line with global guidance, while considering their local regulatory regimes to determine their own risk appetites and ratios.

We aim to ensure that management have oversight of our liquidity and funding risks by maintaining comprehensive policies, metrics and controls. We manage liquidity and funding risk at an operating entity level to make sure that obligations can be met in the jurisdiction where they fall due, generally without reliance on other parts of the Group. Operating entities are required to meet internal minimum requirements and any applicable regulatory requirements at all times. These requirements are assessed through the ILAAP, which ensures that operating entities have robust strategies, policies, processes and systems for the identification, measurement, management and monitoring of liquidity risk over an appropriate set of time horizons, including intra-day. The ILAAP informs the validation of risk tolerance and the setting of risk appetite. It also assesses the capability to manage liquidity and funding effectively in each major entity. These metrics are set and managed locally but are subject to robust review and challenge by the HSBC Group to ensure consistency of approach and application of the Group's policies and controls.

Planning and performance

Capital and risk-weighted asset ('RWA') plans form part of the annual financial resource plan that is approved by the Board. Capital and RWA forecasts are submitted to the ALCO on a monthly basis, and capital and RWAs are monitored and managed against the plan.

Through our internal governance processes, we seek to strengthen discipline over our investment and capital allocation decisions, and to ensure that returns on investment meet management's objectives. The Group's strategy is to allocate capital to businesses and entities to support growth objectives where returns above internal hurdle levels have been identified and in order to meet their regulatory and economic capital needs. We evaluate and manage business returns by using a return on average tangible equity measure.

Funding and liquidity plans form part of the financial resource plan that is approved by the Board. The Board-level appetite measures are the LCR and NSFR, together with an internal liquidity metric which was introduced in January 2021 to supplement the LCR and NSFR. In addition, we use a wider set of measures to manage an appropriate funding and liquidity profile, including legal entity depositor concentration limits, intra-day liquidity, forward-looking funding assessments and other key measures.

Risks to capital and liquidity

Outside the stress testing framework, other risks may be identified that have the potential to affect our RWAs, capital and/or liquidity position. We closely monitor future regulatory changes and continue to evaluate the impact of these upon our capital and liquidity requirements. These include the UK's implementation of amendments to the Capital Requirements Regulation, the Basel III Reforms, and the regulatory impact from the UK's withdrawal from the EU, as well as other regulatory statements including changes to IRB modelling requirements.

Regulatory developments

The PRA has confirmed that software assets will be deducted in full from CET1 capital starting 1 January 2022. This will reverse the beneficial changes to the treatment of software assets that were implemented as part of the EU's response to the Covid-19 pandemic. This will have an immaterial impact on our CET1 ratio.

Overall we expect RWAs to increase by up to 5% as a result of new regulations during 2022. These include the changes to the UK's version of the Capital Requirements Regulation, as well as other regulatory statements including changes to IRB modelling requirements. Following the implementation of the UK's amendments to the Capital Requirements Regulation ('CRR II'), we have adopted the PRA's new rules on net stable funding ratio ('NSFR'), counterparty risk, equity investment in funds, and leverage ratio, which will be reflected in disclosures starting in the first quarter of 2022.

Further changes will occur with the introduction of the remaining Basel III reforms on which the PRA is expected to consult in the second half of 2022.

Regulatory reporting processes and controls

The quality of regulatory reporting remains a key priority for management and regulators. Notably, the PRA published a Dear CEO letter addressed to UK regulated banks, which highlighted areas of concern over the processes firms use to deliver regulatory returns. Recent sanctions issued by the PRA demonstrate their intent in this respect. We are progressing with a comprehensive programme to strengthen our processes, improve consistency, and enhance controls on various aspects of regulatory reporting. We have commissioned a number of independent external reviews, some at the request of our regulators, including one of our credit risk RWA reporting process which is currently ongoing. As a result of these initiatives, there may be an impact on some of our regulatory ratios, such as the CET1 and LCR.

Stress testing and recovery planning

The Group uses stress testing to evaluate the robustness of plans and risk portfolios, and to meet the stress testing requirements set by supervisors. Stress testing also informs the ICAAP and ILAAP and supports recovery planning. It is an important output used to evaluate how much capital and liquidity the Group requires in setting risk appetite for capital and liquidity risk. It is also used to re-evaluate business plans where analysis shows capital, liquidity and/or returns do not meet their target.

In addition to a range of internal stress tests, we are subject to supervisory stress testing in many jurisdictions. These include the programmes of the Bank of England, the European Banking Authority, the European Central Bank, as well as stress tests undertaken in other jurisdictions. The results of regulatory stress testing and our internal stress tests are used when assessing our internal capital requirements through the ICAAP. The outcomes of stress testing exercises carried out by the PRA and other regulators feed into the setting of regulatory minimum ratios and buffers.

The Group and subsidiaries have established recovery plans, which set out potential options management could take in a range

of stress scenarios that could result in a breach of capital or liquidity buffers. All entities monitor internal and external triggers that could threaten their capital, liquidity or funding positions. Entities have established recovery plans providing detailed actions that management would consider taking in a stress scenario should their positions deteriorate and threaten to breach risk appetite and regulatory minimum levels. This is to help ensure that our capital and liquidity position can be recovered even in an extreme stress event.

Overall, recovery and resolution plans form part of the framework safeguarding the Group's financial stability. The Group is committed to developing its recovery and resolution capabilities further, including in relation to the BoE's Resolvability Assessment Framework.

Structural foreign exchange exposures

Structural foreign exchange exposures represent net assets or capital investments in subsidiaries, branches, joint arrangement or associates, together with any associated hedges, the functional currencies of which are currencies other than pound sterling. An entity's functional currency is that of the primary economic environment in which the entity operates. We use the pound sterling as our presentation currency in our consolidated financial statements because sterling forms the major currency in which we transact and fund our business. Exchange rate differences on structural exposures are recognised in other comprehensive income ('OCI').

The structural foreign exchange exposures are managed within limits such that the capital ratios and the capital ratios of individual banking subsidiaries are largely protected from the effect of changes in exchange rates. We may hedge certain structural foreign exchange positions, either at entity level, or by relying on hedges held in other group entities, subject to approved limits.

Measurement of interest rate risk in the banking book

The following measures are used by Treasury to monitor and control interest rate risk in the banking book including:

   --    Net Interest Income ('NII') sensitivity; and 
   --    Economic Value of Equity ('EVE'). 

Net interest income sensitivity

A principal part of our management of non-traded interest rate risk is to monitor the sensitivity of expected NII under varying interest rate scenarios (simulation modelling), where all other economic variables are held constant. This monitoring is undertaken by ALCO.

The group applies a combination of scenarios and assumptions relevant to the businesses as well as applying standard scenarios that are required throughout HSBC Group.

NII sensitivity reflects the group's sensitivity of earnings to changes in market interest rates. We forecast both one year and five year NII sensitivities across a range of interest rate scenarios based on a static balance sheet assumption. Forecasts include business line rate pass-on assumptions, re-investment of maturing assets and liabilities at market rates per shock scenario and prepayment risk. NII is modelled based on no management actions i.e. the risk profile at the month end is assumed to remain constant throughout the forecast horizon.

Economic value of equity

EVE represents the present value of the future banking book cash flows that could be distributed to equity providers under a managed run-off scenario, i.e. the current book value of equity plus the present value of future net interest income in this scenario. EVE sensitivity is the extent to which the EVE value will change due to a pre-specified movement in interest rates, where all other economic variables are held constant.

Pension risk management processes

HSBC provides future pension benefits on a defined contribution basis from many of its European operations. However, there remain future defined benefit pensions provided in the region.

Pension plans are run by local fiduciaries in line with local legislative requirements. The largest pension plan is the HSBC Trinkaus & Burkhardt Pension Scheme which is regulated by the German Company Benefits Act (Gesetz zur Verbesserung der betrieblichen Altersversorgung - Betriebsrentengesetz -BetrAVG).

In defined contribution pension plans, the contributions that HSBC is required to make are known, while the ultimate pension benefit will vary, typically with investment returns achieved by investment choices made by the employee. While the market risk to HSBC of defined contribution plans is low, it is still exposed to operational and reputational risk.

In defined benefit pension plans, the level of pension benefit is known. Therefore, the level of contributions required by HSBC will vary due to a number of risks, including:

   --    investments delivering a return below that required to provide the projected plan benefits; 

-- the prevailing economic environment leading to corporate failures, thus triggering write-downs in asset values (both equity and debt);

-- a change in either interest rates or inflation, causing an increase in the value of the plan liabilities; and

   --    plan members living longer than expected (known as 

longevity risk).

Pension risk is assessed using an economic capital model that takes into account potential variations in these factors. The impact of these variations on both pension assets and pension liabilities is assessed using a one-in-200-year stress test. Scenario analysis and other stress tests are also used to support pension risk management.

To fund the benefits associated with defined benefit plans, sponsoring group companies, and in some instances employees, make regular contributions in accordance with advice from actuaries and in consultation with the plan's fiduciaries where relevant. These contributions are normally set to ensure that there are sufficient funds to meet the cost of the accruing benefits for the future service of active members. However, higher contributions are required when plan assets are considered insufficient to cover the existing pension liabilities. Contribution rates are typically revised annually or once every three years, depending on the plan.

The defined benefit plans invest contributions in a range of investments designed to limit the risk of assets failing to meet a plan's liabilities. Any changes in expected returns from the investments may also change future contribution requirements. In pursuit of these long-term objectives, an overall target allocation of the defined benefit plan assets between asset classes is established. In addition, each permitted asset class has its own benchmarks, such as stock market or property valuation indices or liability characteristics. The benchmarks are reviewed at least once every three to five years and more frequently if required by local legislation or circumstances. The process generally involves an extensive asset and liability review.

 
Capital risk in 2021 
 
 
Capital overview 
 
 
Capital adequacy metrics 
                                                     At 
                                               31 Dec                 31 Dec 
                                                 2021                   2020 
                                ---------------------  --------------------- 
Risk-weighted assets 
 ('RWAs') (GBPm) 
                                --------------------- 
Credit risk                                    67,540                 77,214 
                                --------------------- 
Counterparty credit 
 risk                                          16,434                 19,344 
                                --------------------- 
Market risk                                     9,828                 14,589 
                                --------------------- 
Operational risk                               10,512                 11,245 
                                --------------------- 
Total RWAs                                    104,314                122,392 
                                --------------------- 
Capital on a transitional 
 basis (GBPm) 
                                --------------------- 
Common equity tier 
 1 ('CET1') capital                            18,007                 18,042 
                                --------------------- 
Tier 1 capital                                 21,869                 22,165 
                                --------------------- 
Total capital                                  33,036                 33,438 
                                --------------------- 
Capital ratios on a 
 transitional basis 
 (%) 
                                --------------------- 
Common equity tier 
 1                                               17.3                   14.7 
                                --------------------- 
Total tier 1                                     21.0                   18.1 
                                --------------------- 
Total capital ratio                              31.7                   27.3 
                                --------------------- 
Leverage ratio (transitional) 
                                --------------------- 
Tier 1 capital (GBPm)                          21,869                 22,165 
                                --------------------- 
Total leverage ratio 
 exposure measure (GBPm)                      535,562                565,049 
                                --------------------- 
Leverage ratio (%)                                4.1                    3.9 
                                ---------------------  --------------------- 
Leverage ratio (fully 
 phased-in) 
                                --------------------- 
Tier 1 capital (GBPm)                          21,696                 21,732 
                                --------------------- 
Total leverage ratio 
 exposure measure (GBPm)                      535,562                565,049 
                                --------------------- 
Leverage ratio (%)                                4.1                    3.8 
                                ---------------------  --------------------- 
 

References to EU regulations and directives (including technical standards) should, as applicable, be read as references to the UK's version of such regulation and/or directive, as onshored into UK law under the European Union (Withdrawal) Act 2018, and as may be subsequently amended under UK law.

Capital figures and ratios in the table above are calculated in accordance with the revised Capital Requirements Regulation and Directive, as implemented ('CRR II'). Leverage ratios are calculated using the end point definition of capital and the IFRS 9 regulatory transitional arrangements.

Regulatory transitional arrangements for IFRS 9 'Financial Instruments'

We have adopted the regulatory transitional arrangements in

CRR II for IFRS 9, including paragraph four of article 473a. Our capital and ratios are presented under these arrangements throughout the table above. Without their application, our CET1 ratio would be 17.2%.

The IFRS 9 regulatory transitional arrangements allow banks to add back to their capital base a proportion of the impact that IFRS 9 has upon their loan loss allowances during the first five years of use. The impact is defined as:

   --    the increase in loan loss allowances on day one of IFRS 9 adoption; and 

-- any subsequent increase in expected credit losses ('ECL') in the non-credit-impaired book thereafter.

Any add-back must be tax-effected and accompanied by a recalculation of exposure and RWAs. The impact is calculated separately for portfolios using the standardised ('STD') and internal ratings based ('IRB') approaches. For IRB portfolios, there is no add-back to capital unless loan loss allowances exceed regulatory 12-month expected losses.

In the current period, the add-back to the capital base amounted to GBP48m under the STD approach with a tax impact of GBP12m which resulted in a net add-back of GBP36m.

 
Own funds 
 
 
Own funds disclosure 
(Audited) 
                                                                                   At 
                                                                             31 Dec                             31 Dec 
                                                                               2021                               2020 
Ref(*)                                                                         GBPm                               GBPm 
                                                  --------------------------------- 
        Common equity tier 1 ('CET1') capital: 
        instruments 
        and reserves 
        Capital instruments and the related 
        share premium 
1       accounts                                                                797                                797 
                                                  --------------------------------- 
 
          *    ordinary shares                                                  797                                797 
2       Retained earnings(1)                                                 15,511                             17,229 
                                                  --------------------------------- 
3       Accumulated other comprehensive income                                1,975                              2,888 
        (and other 
        reserves) 
                                                  --------------------------------- 
5       Minority interests (amount allowed in                                    57                                 66 
        consolidated 
        CET1) 
                                                  --------------------------------- 
5a      Independently reviewed interim net                                      625                            (1,755) 
        profits net of 
        any foreseeable charge or dividend(2) 
                                                  --------------------------------- 
6       Common equity tier 1 capital before                                  18,965                             19,225 
        regulatory adjustments 
28      Total regulatory adjustments to common                                (958)                            (1,183) 
        equity tier 
        1(1) 
                                                  --------------------------------- 
29      Common equity tier 1 capital                                         18,007                             18,042 
36      Additional tier 1 capital before                                      3,906                              4,167 
        regulatory adjustments 
43      Total regulatory adjustments to                                        (44)                               (44) 
        additional tier 1 
        capital 
                                                  --------------------------------- 
44      Additional tier 1 capital                                             3,862                              4,123 
                                                  --------------------------------- 
45      Tier 1 capital                                                       21,869                             22,165 
51      Tier 2 capital before regulatory                                     11,591                             11,724 
        adjustments 
57      Total regulatory adjustments to tier 2                                (424)                              (451) 
        capital 
                                                  --------------------------------- 
58      Tier 2 capital                                                       11,167                             11,273 
                                                  --------------------------------- 
59      Total capital                                                        33,036                             33,438 
                                                  --------------------------------- 
 

* The references identify the lines prescribed in the European Banking Authority template, which are applicable and where there is a value.

1 From 1H21, the new deduction for insufficient coverage for non-performing exposures has been combined with IFRS 9 transitional adjustments. Comparatives have been restated.

2 This row includes losses that have been recognised and deducted as they arose and were therefore not subject to an independent review.

At 31 December 2021, our CET1 capital ratio increased to 17.3% from 14.7% at 31 December 2020. This was mainly due to a fall in RWAs.

Throughout 2021, we complied with the PRA's regulatory capital adequacy requirements, including those relating to stress testing.

 
Risk-weighted assets 
 
 
RWA movement by key driver 
 
                                            Total 
                                             RWAs 
                                             GBPm 
RWAs at 1 Jan 2021                        122,392 
Asset size                               (13,682) 
                            --------------------- 
Asset quality                               2,612 
                            --------------------- 
Model updates                               (694) 
                            --------------------- 
Methodology and policy                    (4,071) 
Foreign exchange movement                 (2,243) 
                            --------------------- 
Total RWA movement                       (18,078) 
                            --------------------- 
RWAs at 31 Dec 2021                       104,314 
                            --------------------- 
 

Risk-weighted assets ('RWAs') decreased by GBP18.1bn during the year, including a decrease of GBP2.2bn due to foreign currency translation differences. The GBP15.9bn decrease (excluding foreign currency translation differences) comprised the movements described by the following comments.

Asset size

Credit risk RWAs fell by GBP9.1bn due to management actions, lower lending and a fall in securitisation related RWAs, and a reduction in counterparty credit risk RWAs due to management actions and mark-to-market movements.

Market risk RWAs decreased by GBP4.1bn largely due to the effects of risk mitigation actions, a reduction in the equity and emerging markets bond portfolios and a decrease in stressed value at risk.

The annual calculation of operational risk RWAs led to a GBP0.5bn fall in RWAs due to lower average revenue and expenses.

Asset quality

The GBP2.6bn increase in RWAs was mainly due to portfolio changes and credit migration.

Model updates

The GBP0.7bn decrease in RWAs was mainly due to a fall in market risk RWAs largely from the implementation of an options risk model.

Methodology and policy

The GBP4.1bn decrease in RWAs was primarily due to risk parameter refinements. This included a GBP0.2bn increase arising from the adoption of a Pillar 1 approach to the capitalisation of structural foreign exchange risk.

 
Leverage ratio 
 

Our leverage ratio calculated in accordance with the Capital Requirements Regulation was 4.1% at 31 December 2021, up from 3.8% at 31 December 2020. This was mainly due to a decrease in the leverage exposure measure, primarily driven by a reduction in security finance transactions and on balance sheet exposures.

Pillar 3 disclosure requirements

Pillar 3 of the Basel regulatory framework is related to market discipline and aims to make financial services firms more transparent by requiring publication of wide-ranging information on their risks, capital and management. Our Pillar 3 Disclosures at 31 December 2021 is published on our website, www.hsbc.com/investors

Structural foreign exchange exposures

The group's structural foreign currency exposure is represented by the net assets or capital investments in subsidiaries, branches, joint arrangements or associates, the functional currencies of which are currencies other than the sterling.

For our policies and procedures for managing structural foreign exchange exposures, see page 72 of the 'Risk management' section.

.

 
Net structural foreign exchange 
 exposures 
                                          2021                    2020 
                                          GBPm                    GBPm 
                         --------------------- 
Currency of structural 
 exposure 
Euro                                     8,068                   8,511 
US Dollars                               1,470                   1,081 
South African rand                         285                     277 
Israeli new shekel                         169                     159 
Others, each less than 
 GBP150m                                   319                     446 
At 31 Dec                               10,311                  10,474 
 

Liquidity and funding risk in 2021

Liquidity coverage ratio

The LCR aims to ensure that a bank has sufficient unencumbered high-quality liquid assets ('HQLA') to meet its liquidity needs in a 30-calendar-day liquidity stress scenario. HQLA consist of cash or assets that can be converted into cash at little or no loss of value in markets.

At 31 December 2021, all the group's principal operating entities were within the LCR risk tolerance level established by the Board and applicable under the LFRF.

The following table displays the individual LCR levels for HSBC Bank plc's principal operating entities on the European Commission Delegated Regulation basis.

 
Operating entities' LCRs 
                          At 
                    31 Dec  31 Dec 
                      2021    2020 
                         %       % 
HSBC Bank plc          150     136 
                    ------  ------ 
HSBC Continental 
 Europe                145     143 
                    ------  ------ 
HSBC Germany           170     144 
                    ------  ------ 
 

HSBC Bank plc LCR increased mainly due to loan book optimisation resulting in lower loan and committed facilities positions.

The LCR increase for HSBC Germany is mainly driven by increased customer deposits and additional TLTRO III funding being raised in June 2021.

In addition to the regulatory metric, the group enhanced its liquidity framework in 2021 to include as 'internal liquidity metric', which is being used to monitor and manage liquidity risk via a low-point measure across a 270-day horizon, taking into account recovery capacity.

Net stable funding ratio

The Net Stable Funding Ratio ('NSFR') requires institutions to maintain sufficient stable funding relative to required stable funding, and reflects a bank's long-term funding profile (funding with a term of more than a year).

At 31 December 2021, all the group's principal operating entities were within the NSFR risk tolerance level established by the Board and applicable under the LFRF.

 
Operating entities' NSFRs 
                          At 
                    31 Dec  31 Dec 
                      2021    2020 
                         %       % 
                    ------ 
HSBC Bank plc(1)       124     133 
                    ------ 
HSBC Continental 
 Europe(2)             130     130 
                    ------ 
HSBC Germany           163     138 
                    ------ 
 

1 HSBC Bank plc uses an adjusted NSFR as a basis for establishing stable funding. The adjusted NSFR requires HSBC Bank plc to maintain sufficient stable funding and reflects its long term funding profile commensurate with the risk profile of the balance sheet.

   2   HBCE abide by the CRR II NSFR definition since JUN21. 

Depositor concentration and term funding maturity concentration

The LCR and NSFR metrics assume a stressed outflow based on a portfolio of depositors within each depositor segment. To ensure the validity of these assumptions in the sense that the deposit base is sufficient diversified, the depositor concentration is monitored on an ongoing basis.

In addition to this, operating entities monitor the term funding maturity concentration metric to ensure they are not overly exposed to term funding concentration of wholesale market counterparts by the current maturity profile in any defined period.

Liquid assets of the group's principal operating entities

The table below shows the unweighted liquidity value of assets categorised as liquid, which is used for the purposes of calculating the LCR metric. This reflects the stock of unencumbered liquid assets at the reporting date, using the regulatory definition of liquid assets.

 
Operating entities' liquid 
 assets 
                                    At Estimated                      At Estimated 
                                       liquidity                         liquidity 
                                           value                             value 
                                          31 Dec                            31 Dec 
                                            2021                              2020 
                                            GBPm                              GBPm 
HSBC Bank plc 
Level 1                                   89,805                            88,942 
Level 2a                                   6,320                             8,260 
Level 2b                                   3,550                             3,888 
HSBC Continental 
 Europe 
Level 1                                   39,159                            34,981 
Level 2a                                     450                               267 
Level 2b                                     142                                 - 
HSBC Germany 
Level 1                                   13,072                            11,044 
Level 2a                                      33                                 8 
Level 2b                                     327                               315 
 

Sources of funding

Our primary sources of funding are customer current accounts, repo and wholesale securities.

The following 'Funding sources and uses' table provides a consolidated view of how our balance sheet is funded, and should be read in light of the LFRF, which requires operating entities to manage liquidity and funding risk on a stand-alone basis.

The table analyses our consolidated balance sheet according to the assets that primarily arise from operating activities and the sources of funding primarily supporting these activities. Assets and liabilities that do not arise from operating activities are presented at other balance sheet lines. In 2021, the level of customer accounts continued to exceed the level of loans and advances to customers. The positive funding gap was predominantly deployed in liquid assets, cash and balances with central banks and financial investments, as required by the LFRF.

 
Funding sources and uses for the group 
                             2021                 2020                                   2021                     2020 
                             GBPm                 GBPm                                   GBPm                     GBPm 
               ------------------                                    ------------------------ 
Sources                                                 Uses 
                                                        Loans and 
Customer                                                advances to 
 accounts                 205,241              195,184  customers                      91,177                  101,491 
               ------------------  -------------------               ------------------------  ----------------------- 
                                                        Loans and 
Deposits by                                             advances to 
 banks                     32,188               34,305  banks                          10,784                   12,646 
               ------------------  -------------------               ------------------------  ----------------------- 
                                                        Reverse 
Repurchase                                              repurchase 
 agreements                                             agreements 
 -                                                      - 
 non-trading               27,259               34,903  non-trading                    54,448                   67,577 
               ------------------  -------------------               ------------------------  ----------------------- 
                                                        Cash 
                                                        collateral, 
                                                        margin 
Debt                                                    and 
 securities                                             settlement 
 in issue                   9,428               17,371  accounts                       34,907                   46,840 
               ------------------  -------------------               ------------------------  ----------------------- 
Cash 
 collateral, 
 margin 
 and 
 settlement                                             Assets held 
 accounts                  37,076               47,173  for sale                            9                       90 
               ------------------  ------------------- 
Subordinated                                            Trading 
 liabilities               12,488               13,764  assets                         83,706                   86,976 
               ------------------  ------------------- 
Financial 
 liabilities 
 designated 
 at fair                                                - reverse 
 value                     33,608               40,792  repos                           8,626                    8,182 
               ------------------  ------------------- 
Liabilities 
 under 
 insurance                                              - stock 
 contracts                 22,264               22,816  borrowing                       3,218                    4,137 
               ------------------  ------------------- 
                                                        - other 
Trading                                                 trading 
 liabilities               46,433               44,229  assets                         71,862                   74,657 
               ------------------  ------------------- 
                                                        Financial 
- repos                     7,663                8,441  investments                    41,300                   51,826 
                                                                     ------------------------  ----------------------- 
                                                        Cash and 
                                                        balances 
                                                        with 
- stock                                                 central 
 lending                    1,637                3,356  banks                         108,482                   85,092 
                                                                     ------------------------  ----------------------- 
                                                        Other 
- other                                                 balance 
 trading                                                sheet 
 liabilities               37,133               32,432  assets                        171,798                  228,612 
                                                                     ------------------------  ----------------------- 
Total equity               23,715               23,849  At 31 Dec                     596,611                  681,150 
               ------------------  -------------------               ------------------------  ----------------------- 
Other balance 
 sheet 
 liabilities              146,911              206,764 
               ------------------  ------------------- 
At 31 Dec                 596,611              681,150 
               ------------------  ------------------- 
 

Contingent liquidity risk arising from committed lending facilities

The group provides customers with committed facilities such as standby facilities to corporate customers and committed backstop lines to conduits sponsored by the group. All of the undrawn commitments provided to conduits or external customers are accounted for in the LCR and NSFR in line with the applicable regulations. This ensures that under a stress scenario any additional outflow generated by increased utilisation of these committed facilities by either customers or the group's sponsored conduits is appropriately reflected in our liquidity and funding position.

In relation to commitments to customers, the table below shows the level of undrawn commitments outstanding in terms of the five largest single facilities and the largest market sector.

 
The group's contractual exposures at 31 December monitored under the 
 contingent liquidity risk limit structure 
                                                                       2021                           2020 
                                                                      GBPbn                          GBPbn 
Commitments to conduits 
Multi-seller conduits(1) 
- total lines                                                           4.2                            5.8 
- largest individual lines                                              0.2                            0.4 
Securities investment conduits - total lines                            1.3                            1.6 
Commitments to customers 
- five largest (2)                                                     10.4                            6.6 
- largest market sector(3)                                              7.7                            8.0 
 

1 Exposures relate to the Regency multi-seller conduit. This vehicle provides funding to group customers by issuing debt secured by a diversified pool of customer-originated assets.

2 Represents the undrawn balance for the five largest committed liquidity facilities provided to customers, other than those facilities to conduits.

3 Represents the undrawn balance for the total of all committed liquidity facilities provided to the largest market sector, other than those facilities to conduits.

Asset encumbrance and collateral management

An asset is defined as encumbered if it has been pledged as collateral against an existing liability and, as a result, is no longer available to the group to secure funding, satisfy collateral needs or be sold to reduce the funding requirement. Collateral is managed on an operating entity basis consistent with the approach to managing liquidity and funding. Available collateral held in an operating entity is managed as a single consistent collateral pool

from which each operating entity will seek to optimise the use of the available collateral. The objective of this disclosure is to facilitate an understanding of available and unrestricted assets that could be used to support potential future funding and collateral needs. The disclosure is not designed to identify assets which would be available to meet the claims of creditors or to predict assets that would be available to creditors in the event of a resolution or bankruptcy.

 
Summary of assets available to support potential future funding and 
 collateral needs (on- and off-balance sheet) 
                                                                                   2021                           2020 
                                                                                   GBPm                           GBPm 
----------------------------------------------------------  --------------------------- 
Total on-balance sheet assets at 31 Dec                                         596,611                        681,150 
----------------------------------------------------------  ---------------------------  ----------------------------- 
Less: 
---------------------------------------------------------- 
- reverse repo/stock borrowing receivables and derivative 
 assets                                                                       (207,513)                      (281,125) 
----------------------------------------------------------  ---------------------------  ----------------------------- 
- other assets that cannot be pledged as collateral                            (48,350)                       (51,068) 
----------------------------------------------------------  ---------------------------  ----------------------------- 
Total on-balance sheet assets that can support funding 
 and collateral needs at 31 Dec                                                 340,748                        348,957 
----------------------------------------------------------  ---------------------------  ----------------------------- 
Add: off-balance sheet assets 
---------------------------------------------------------- 
- fair value of collateral received in relation to 
 reverse repo/stock borrowing/derivatives that is 
 available 
 to sell or repledge                                                            202,794                        213,690 
----------------------------------------------------------  ---------------------------  ----------------------------- 
Total assets that can support future funding and 
 collateral 
 needs                                                                          543,542                        562,647 
----------------------------------------------------------  ---------------------------  ----------------------------- 
Less: 
---------------------------------------------------------- 
- on-balance sheet assets pledged                                              (93,513)                      (107,671) 
----------------------------------------------------------  ---------------------------  ----------------------------- 
- re-pledging of off-balance sheet collateral received 
 in relation to reverse repo/stock borrowing/derivatives                      (151,378)                      (154,486) 
----------------------------------------------------------  ---------------------------  ----------------------------- 
Assets available to support funding and collateral 
 needs at 31 Dec                                                                298,651                        300,490 
----------------------------------------------------------  ---------------------------  ----------------------------- 
 

Market risk

Overview

Market risk is the risk that movements in market factors, including foreign exchange rates and commodity prices, interest rates, credit spreads and equity prices will reduce the group's income or the value of its portfolios.

Exposure to market risk is separated into two portfolios.

Trading portfolios comprise positions arising from market-making and warehousing of customer-derived positions.

Non-trading portfolios including Markets Treasury comprise positions that primarily arise from the interest rate management of the group's retail and commercial banking assets and liabilities, financial investments designated as held-to-collect-and-sale ('HTCS'), and exposures arising from the group's insurance operations.

Key developments in 2021

There were no material changes to our policies and practices for the management of market risk in 2021.

Market risk governance

(Audited)

The following diagram summarises the main business areas where trading and non-trading market risks reside, and the market risk measures used to monitor and limit exposures.

 
                                           Non-trading 
  Trading risk                              risk 
 
    *    Foreign exchange and commodities    *    Interest rates 
 
 
    *    Interest rates                      *    Credit spreads 
 
 
    *    Credit spreads                      *    Foreign exchange 
 
 
    *    Equities 
  Value at risk                            Value at risk 
   | Sensitivity                            | Sensitivity 
   | Stress testing                         | Stress testing 
 

Where appropriate, we apply similar risk management policies and measurement techniques to both trading and non-trading portfolios. Our objective is to manage and control market risk exposures to optimise return on risk while maintaining a market profile consistent with our established risk appetite.

Market risk is managed and controlled through limits approved by the group Chief Risk Officer. These limits are allocated across business lines and to the group and its subsidiaries. The majority of HSBC's total VaR and almost all trading VaR reside in GBM. Each major operating entity has an independent market risk management and control sub-function, which is responsible for measuring, monitoring and reporting market risk exposures against limits on a daily basis. Each operating entity is required to assess the market risks arising in its business and to transfer them either to its local Markets & Securities Services or Markets Treasury unit for management, or to separate books managed under the supervision of the local ALCO. The Traded Risk function enforces the controls around trading in permissible instruments approved for each site as well as following completion of the new product approval process. Traded Risk also restricts trading in the more complex derivative products to offices with appropriate levels of product expertise and robust control systems.

Market risk measures

Monitoring and limiting market risk exposures

Our objective is to manage and control market risk exposures while maintaining a market profile consistent with the group's risk appetite.

We use a range of tools to monitor and limit market risk exposures including sensitivity analysis, VaR, and stress testing

Sensitivity analysis

Sensitivity analysis measures the impact of individual market factor movements on specific instruments or portfolios, including interest rates, foreign exchange rates, credit spreads and equity prices, such as the effect of a one basis point change in yield. We use sensitivity measures to monitor the market risk positions within each risk type. Sensitivity limits are set for portfolios, products and risk types, with the depth of the market being one of the principal factors in determining the level of limits set.

Value at risk

VaR is a technique that estimates the potential losses on risk positions as a result of movements in market rates and prices over a specified time horizon and to a given level of confidence. The use of VaR is integrated into market risk management and is calculated for all trading positions regardless of how the group capitalises those exposures. Where there is not an approved internal model, the group uses the appropriate local rules to capitalise exposures.

In addition, the group calculates VaR for non-trading portfolios in order to have a complete picture of risk. The models are predominantly based on historical simulation. VaR is calculated at a 99% confidence level for a one-day holding period. Where we do not calculate VaR explicitly, we use alternative tools like Stress Testing.

The VaR models used by us are based predominantly on historical simulation. These models derive plausible future scenarios from past series of recorded market rates and prices, taking into account inter-relationships between different markets and rates such as interest rates and foreign exchange rates. The models also incorporate the effect of option features on the underlying exposures.

The historical simulation models used incorporates the following features:

-- historical market rates and prices are calculated with reference to foreign exchange rates and commodity prices, interest rates, equity prices and the associated volatilities;

-- potential market movements utilised for VaR are calculated with reference to data from the past two years; and

   --    VaR measures are calculated to a 99% confidence level and use a one-day holding period. 

The nature of the VaR models means that an increase in observed market volatility will most likely lead to an increase in VaR without any changes in the underlying positions.

VaR model limitations

Although a valuable guide to risk, VaR should always be viewed in the context of its limitations. For example:

-- the use of historical data as a proxy for estimating future events may not encompass all potential events, particularly those which are extreme in nature;

-- the use of a holding period assumes that all positions can be liquidated or the risks offset during that period. This may not fully reflect the market risk arising at times of severe illiquidity, when the holding period may be insufficient to liquidate or hedge all positions fully;

-- the use of a 99% confidence level by definition does not take into account losses that might occur beyond this level of confidence; and

-- VaR is calculated on the basis of exposures outstanding at the close of business and therefore does not necessarily reflect intra-day exposures.

Risk not in VaR framework

Other basis risks which are not completely covered in VaR are complemented by our risk not in VaR ('RNIV') calculations, and are integrated into our capital framework.

Risk factors are reviewed on a regular basis and either incorporated directly in the VaR models, where possible, or quantified through the VaR-based RNIV approach or a stress test approach within the RNIV framework. The outcome of the VaR-based RNIV is included in the VaR calculation; a stressed VaR RNIV is also computed for the risk factors considered in the VaR-based RNIV approach.

Stress-type RNIVs include a deal contingent derivatives capital charge to capture risk for these transactions and a de-peg risk measure to capture risk to pegged and heavily managed currencies

Stress testing

Stress testing is an important procedure that is integrated into our market risk management tool to evaluate the potential impact on portfolio values of more extreme, although plausible, events or movements in a set of financial variables. In such scenarios, losses can be much greater than those predicted by VaR modelling.

Stress testing is implemented at legal entity, regional and overall Group levels. A standard set of scenarios is utilised consistently across all regions within the HSBC Group. Scenarios are tailored to capture the relevant events or market movements at each level. The risk appetite around potential stress losses for the group is set and monitored against referral limits.

Market risk reverse stress tests are undertaken on the premise that there is a fixed loss. The stress testing process identifies which scenarios lead to this loss. The rationale behind the reverse stress test is to understand scenarios which are beyond normal business settings that could have contagion and systemic implications.

Stressed VaR and stress testing, together with reverse stress testing and the management of gap risk, provide management with insights regarding the 'tail risk' beyond VaR for which the group's appetite is limited.

Trading portfolios

Back-testing

We routinely validate the accuracy of our VaR models by back-testing the VaR metric against both actual and hypothetical profit and loss. Hypothetical profit and loss excludes non-modelled items such as fees, commissions and revenue of intra-day transactions. The hypothetical profit and loss reflects the profit and loss that would be realised if positions were held constant from the end of one trading day to the end of the next. This measure of profit and loss does not align with how risk is dynamically hedged, and is not therefore necessarily indicative of the actual performance of the business.

The number of back-testing exceptions is used to gauge how well the models are performing. We consider enhanced internal monitoring of a VaR model if more than five profit exceptions or more than five loss exceptions occur in a 250-day period.

We back-test our VaR at set levels of our group entity hierarchy.

Non-trading portfolios

Non-trading VaR of HSBC Bank plc includes the interest rate risk of non-trading financial instruments held by the global businesses and transferred into portfolios managed by Markets Treasury or Asset, Liability and Capital Management ('ALCM') functions. In measuring, monitoring and managing risk in our non-trading portfolios, VaR is just one of the tools used. The management of interest rate risk in the banking book is described further in 'Non-trading interest rate risk' below, including the role of Markets Treasury. The Group's and HSBC Bank plc's control of market risk in the non-trading portfolios is based on transferring the assessed market risk of non-trading assets and liabilities created outside

Markets Treasury or Markets, to the books managed by Markets Treasury, provided the market risk can be neutralised. The net exposure is typically managed by Markets Treasury through the use of fixed rate government bonds (liquid asset held in held-to-collect-and-sale ('HTCS' books)) and interest rate swaps. The interest rate risk arising from fixed rate government bonds held within HTCS portfolios is reflected within the group's non-trading VaR. Interest rate swaps used by Markets Treasury are typically classified as either a fair value hedge or a cash flow hedge and included within the group's non-trading VaR. Any market risk that cannot be neutralised in the market is managed by HSBC Bank plc ALCM in segregated ALCO books.

Defined benefit pension plans

Market risk also arises within the Bank's defined benefit pension plans to the extent that the obligations of the plans are not fully matched by assets with determinable cash flows. Refer to the Pension risk management processes section on page 73 for additional information.

Market risk in 2021

Financial markets performed well in 2021. During the first half of the year, the rollout of COVID vaccination programmes, loose financial conditions and continued fiscal support contributed to a gradual reopening of major economies. Concerns of rising inflationary pressures were mainly interpreted as transitory. Whilst the path of monetary policies remained uncertain, central banks continued to provide liquidity. This supported risk assets valuations, while volatility in most asset classes was subdued. In the second half of 2021, amid the emergence of new COVID variants, global equities reached further record highs, as investors focused on global economic resilience and corporate earnings. Yields followed a downward trend for most of 3Q-21, before reversing in the final weeks of the year, when markets began pricing a faster pace of interest rate rises in some of the major economies, due to persistently elevated inflation and the expectation of tighter monetary policies. Credit markets remained strong, with credit benchmark indices for investment-grade and high-yield debt close to pre-pandemic levels.

We continued to manage market risk prudently during 2021. Sensitivity exposures and VaR remained within appetite as the business pursued its core market-making activity in support of our customers. Market risk was managed using a complementary set of risk measures and limits, including stress and scenario analysis.

Trading portfolios

Value at risk of the trading portfolios

(Audited)

Trading VaR predominantly resides within Market Securities Services where it was GBP19m at 31 December 2021 compared with GBP27.5m at 31 December 2020. The Total Trading VaR peaked at GBP31.9m early January owing to some negative convexity positions in the FX options portfolio and then rapidly decreased and remained fairly stable during the year, ranging between GBP15m and GBP25m. We saw it spike to GBP29.8m end of March, owing to an unusually large increase of the TRY Rates and the sensitivity of the FX cash desk to that risk factor.

 
Daily VaR (trading portfolios), 99% 1 day (GBPm) 
 

.

The group's trading VaR for the year is shown in the table below.

 
Trading VaR, 99% 1 day 
(Audited) 
                                       Foreign 
                                      exchange                                                                                                Credit 
                                    ('FX') and                          Interest                            Equity                            Spread                         Portfolio 
                                     commodity                       rate ('IR')                            ('EQ')                            ('CS')                Diversification(1)                         Total(2) 
                                          GBPm                              GBPm                              GBPm                              GBPm                              GBPm                             GBPm 
                                                --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Balance 
 at 31 
 Dec 
 2021                                      4.5                              10.0                              10.5                              14.9                            (20.9)                             19.0 
          ------------------------------------  --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Average                                    7.1                              12.8                              10.2                              12.6                            (20.4)                             22.3 
          ------------------------------------  --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Maximum                                   19.3                              26.7                              14.9                              16.7                                 -                             31.9 
          ------------------------------------  --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Minimum                                    3.7                               9.3                               6.3                               9.2                                 -                             17.3 
          ------------------------------------  --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
 
Balance 
 at 31 
 Dec 
 2020                                      7.6                              11.0                              13.9                              14.1                            (19.2)                             27.5 
                                                --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Average                                    6.5                              13.5                              18.7                              14.1                            (20.8)                             32.1 
                                                --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Maximum                                   14.2                              21.2                              33.2                              29.2                                 -                             47.7 
                                                --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
Minimum                                    2.0                               9.2                               8.1                               9.6                                 -                             20.9 
                                                --------------------------------  --------------------------------  --------------------------------  --------------------------------  ------------------------------- 
 

1 Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in unsystematic market risk that occurs when combining a number of different risk types, for example, interest rate, equity and foreign exchange, together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A negative number represents the benefit of portfolio diversification. As the maximum occurs on different days for different risk types, it is not meaningful to calculate a portfolio diversification benefit for this measure.

2 The total VaR is non-additive across risk types due to diversification effect and it includes VaR RNIV.

Back-testing

In 2021, HSBC Bank plc experienced 5 back testing exceptions in total, 2 of which against the Hypothetical P&L and 3 of which against the Actual P&L.

The first exception against hypothetical P&L occurred in March and was mostly due to a rates sell-off and a decrease of the Equity volatilities.

The second exception against hypothetical P&L occurred at the end of December and was mostly due to a decrease of the Equity volatilities, which had a negative impact on the Equity Derivative desk.

Two of the three exceptions against the Actual P&L were due to the novation of trades from the RWA optimization unit in HBCE. The last exception against the Actual P&L was mostly due to the February month end Independent Price verification and Bid-Offer reserve across HSBC Bank plc and HSBC France.

Non-trading portfolios

Value at risk of the non-trading portfolios

(Audited)

The non-trading VaR in 2021 was driven by interest rate risk in the banking book. During the first half of the year, the non-trading VaR trended upwards into the month of May as the Markets Treasury business took advantage of higher yield environment and increased USD and GBP sovereign bond holdings in their book, with non-trading VaR reaching a high of GBP37.8m. Bond positions receded during Q2 before increasing again at the tail end of Q3 as rates sold off and inflation pressures grew. Markets Treasury business re-deployed cash within the Liquid Asset Buffer (LAB) into local government securities as opportunities arose. The positions and non-trading VaR then declined in December to end the year at GBP29.4m. The daily levels of total non-trading VaR over the last year are set out in the graph below.

 
Daily VaR (non-trading portfolios), 99% 1 day (GBPm) 
 

The group's non-trading VaR for the year is shown in the table below.

 
Non-trading VaR, 99% 1 day 
(Audited) 
                           Interest                      Credit 
                               rate                      spread                     Portfolio 
                             ('IR')                      ('CS')            diversification(1)                   Total(2) 
                               GBPm                        GBPm                          GBPm                       GBPm 
Balance 
 at 
 Balance 
 at 31 
 Dec 
 2021                          28.7                         9.0                         (8.4)                       29.4 
Average                        26.6                        10.0                         (5.6)                       31.0 
Maximum                        34.6                        12.7                             -                       37.8 
Minimum                        18.0                         7.2                             -                       22.5 
 
Balance 
 at 31 
 Dec 
 2020                          25.1                        11.6                         (3.4)                       33.3 
          -------------------------  --------------------------                                ------------------------- 
Average                        21.9                        12.3                         (6.3)                       27.9 
          -------------------------  --------------------------                                ------------------------- 
Maximum                        28.8                        16.6                             -                       35.0 
          -------------------------  --------------------------                                ------------------------- 
Minimum                        14.3                         5.5                             -                       15.0 
          -------------------------  --------------------------                                ------------------------- 
 

1 Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in unsystematic market risk that occurs when combining a number of different risk types, for example, interest rate, equity and foreign exchange, together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A negative number represents the benefit of portfolio diversification. As the maximum occurs on different days for different risk types, it is not meaningful to calculate a portfolio diversification benefit for this measure.

   2   The total VaR is non-additive across risk types due to diversification effect. 

Resilience Risk

Overview

Resilience risk is the risk that we are unable to provide critical services to our customers, affiliates and counterparties, as a result of sustained and significant operational disruption. Resilience risk arises from failures or inadequacies in processes, people, systems or external events.

Resilience Risk management

Key developments in 2021

Our Operational and Resilience Risk function provides robust non-financial risk steward oversight of the management of risk within the group's businesses, functions and legal entities. It also provides effective and timely independent challenge. During the year we carried out a number of initiatives to strengthen the management of non-financial risks:

-- We developed a more robust understanding of our risk and control environment, by updating our material risk taxonomy and control libraries, and refreshing material risk and control assessments.

   --    We further strengthened our non-financial risk governance and senior leadership. 

-- We created a consolidated view of risk issues enabling better senior management focus on non-financial risk, and the ability to identify material control issues and intervention as required.

-- We improved how we provide analysis and reporting of non-financial risks, with more risk practitioners having access to a wider range of management information on their risks and controls.

-- We increased the capability of risk stewards to allow for effective stewardship to be in place in HSBC Bank plc.

-- We strengthened our approach in the comparison of issues and near misses by implementing a group approach that considers all events across the global businesses, functions and regions.

-- We enhanced risk management oversight across our most material change initiatives to support growth in our strategic transformation.

We prioritise our efforts on material risks and areas undergoing strategic growth, aligning our location strategy to this need.

Governance and structure

The Operational and Resilience Risk target operating model provides a consistent view across resilience risks, strengthening our risk management oversight while operating effectively as part of a simplified non-financial risk structure. We view resilience risk across seven risk types related to: third parties and supply chains; information, technology and cybersecurity; payments and manual processing; physical security; business interruption and contingency risk; building unavailability; and workplace safety.

Operational and Resilience Risk is governed in the group through the RMM and our Risk Committee with clear global escalation routes through to the Non-Financial Risk Management Board ('NFRMB'), chaired by the Group Chief Risk and Compliance Officer, and the Group Risk Management Meeting ('GRMM').

Key risk management process

Operational resilience is our ability to anticipate, prevent, adapt, respond to, recover and learn from internal or external disruption, protecting customers, the markets we operate in and economic stability. Resilience is determined by assessing whether we are able to continue to provide our most important services, within an agreed level. We accept we will not be able to prevent all disruption, we prioritise investment to continually improve the response and recovery strategies for our most important business services.

Business operations continuity

Business Continuity, in response to the Covid-19 pandemic, remains in place across a number of locations where we operate, allowing the majority of service level agreements to be maintained. There were no significant impacts to service delivery in locations where we operate.

Regulatory compliance risk

Overview

Regulatory compliance risk is the risk that we fail to observe the letter and spirit of all relevant laws, codes, rules, regulations and standards of good market practice, which as a consequence incur fines and penalties and suffer damage to our business.

Regulatory compliance risk arises from the risks associated with breaching our duty to our customers and inappropriate market conduct, as well as breaching regulatory licensing, permissions and rules.

Key developments in 2021

In 2021, we continued to embed the structural changes made in the prior year to our wider approach to Compliance Risk Management. Further, the integration of the Risk and Compliance Functions in May 2021 has brought together two complimentary functions which will strengthen the Regulatory Conduct mandate and our capability to drive ever greater standards in regard to conduct of our business.

In June 2021, we also announced HSBC's new purpose-led approach to conduct. As part of this, we have taken the opportunity to simplify our approach, making Conduct easier to understand and showing how it fulfils our value: 'we take responsibility'.

Governance and structure

We have evolved our structure in response to ever-changing business and industry needs. We reviewed the effectiveness of our governance framework to manage regulatory compliance risk, such as to enable compliance with the letter and the spirit of all applicable laws and regulations, as well as our own standards, values and policies.

In 2021, the key governance meeting was the HBEU Risk Management Meeting ('RMM'). The RMM acts as the sole governance for risk management across all risk types. The Chief Risk Officer ('CRO'), currently chairs the RMM, attended by the CEO, Business Heads and Risk Stewards. To attend to all compliance related discussions and matters in the RMM, the Chief Compliance Officer is a key member of the RMM.

The Europe Regulatory Conduct capability continues to work closely with the Country Chief Compliance Officers and their respective teams to help them identify and manage regulatory compliance risks across the region. They also work together to ensure good conduct outcomes and provide enterprise-wide support on the regulatory agenda.

Key risk management processes

The Europe Regulatory Conduct function is responsible for setting policies, standards and risk appetite to guide the management of regulatory compliance. It also devises clear frameworks and support processes to mitigate regulatory compliance risks. The capability provides oversight, review and challenge to the Country Chief Compliance Officers and their teams to help them identify, assess and mitigate regulatory compliance risks, where required. The regulatory compliance risk policies are regularly reviewed. Policies and procedures require the prompt identification and escalation of any actual or potential regulatory breach. Relevant reportable events are escalated to the HBEU RMM and to the Group Risk Committee, as appropriate.

Conduct of business

Our new simplified Conduct Approach, which was launched in 2021, guides us to do the right thing and to recognise the real impact we have for our customers and the financial markets in which we operate. It complements our Purpose and Values, setting the right outcomes to be achieved for our customers and markets. It recognises cultural and behavioural drivers of good Conduct Outcomes and applies across all risk disciplines, operational processes and technologies. During 2021:

a. We understood and serviced our customer's ongoing needs and continued to champion a strong conduct and customer-focused culture.

b. We demonstrated this through providing support to our customers facing financial difficulties as a result of the prolonged impacts of the pandemic and the resulting uncertainty in trading conditions.

c. We acted with integrity through areas such as commencing the integration of Climate Risk into the Risk Management approach to recognise the importance of strengthened controls and oversight for our related activities.

d. We operated resiliently and securely to avoid harm to our customers and markets by continuing to embed conduct within our business line processes and through our Non- Financial and Financial Risk Steward activities.

e. We continued our focus on culture and behaviours as a driver of good conduct outcomes.

f. We placed a particular focus on the importance of well-being and collaborative working as we continued to adapt to changing working practices as the pace of change resulting from the pandemic varied across our markets.

g. We continued to emphasise - and worked to create - an environment in which employees are encouraged and feel safe to speak up.

h. We delivered our annual global mandatory training course on conduct to reinforce the important role we all play in adhering to good conduct and values.

Regulators and governments

We seek strong, open and transparent engagement with all our regulators and have extensive interaction with them as they pursue their regulatory objectives. We engage with governments and policymakers at a regional and national level to make a positive contribution to the evolving regulatory landscape. We also actively monitor changes in the laws and regulations that apply to our activities, and respond to various formal consultations published by governments, regulatory agencies and standard setting bodies, either directly or through input to trade body responses.

Financial crime risk

Overview

Financial crime risk is the risk of knowingly or unknowingly helping parties to commit or to further illegal activity through HSBC, including money laundering, terrorist and proliferation financing, tax evasion, bribery and corruption, sanctions, fraud and market abuse. Financial crime risk arises from day-to-day banking operations involving customers, third parties and employees.

Key developments in 2021

We consistently review the effectiveness of our financial crime risk management framework, which includes consideration of geopolitical and wider economic factors, and 2021 was no exception. We continued to support the business in navigating the complex and dynamic nature of geopolitics as it relates to sanctions and export control risk, notably with respect to the array of new regulations and designations in 2021 and in alignment with our policy, which is to comply with all applicable sanctions regulations in the jurisdictions in which we operate.

We also continued to progress several key financial crime risk management initiatives based on an increased use of technology to enhance our processes, while minimising the impact to the customer, including:

-- Deployment of a key component of our intelligence-led, dynamic risk assessment capabilities for customer account monitoring in one of our home markets, as well as undertaking key enhancements to our traditional transaction monitoring systems

-- Strengthening our anti-fraud capabilities, notably with respect to the early identification of first party lending fraud and the identification of new strategic detection tools

-- Ongoing developments in leading-edge surveillance technology and capabilities to identify potential market abuse, including testing Machine Learning within Unauthorised Trading

-- Investing in the use of artificial intelligence ('AI') and advanced analytics techniques to manage financial crime risk, notably new automated capabilities in name and transaction screening

-- Implementing a market leading gifts and entertainment ('G&E') recording and approval system, which, in combination with an expenses reconciliation tool, allows HSBC to manage its G&E risk consistently and effectively.

Governance and Structure

Since establishing a global framework of financial crime risk management committees, we have continued to review the effectiveness of our governance framework to manage financial crime risk, such as to enable compliance with the letter and the spirit of all applicable financial crime laws and regulations, as well as our own standards, values and policies relating to financial crime risks.

In 2021, the key financial crime governance meeting, HBEU Financial Crime Risk Management Committee ('FCRMC'), established in June 2017, merged into the HBEU Risk Management Meeting ('RMM'), to support the strategic objectives of reducing bureaucracy and increasing efficiency in decision making. This ensures a more efficient approach to the management of financial crime risk, by streamlining the body for executive governance. This is also due to the success of the FCRMC framework, which helped successfully embed the management of financial crime risk under the three lines of defence model. The RMM now acts as the sole governance for risk management across all risk types. This does not reduce the importance which HSBC places on the management of financial crime risk, nor does it reduce any of the underlying activities or commitments. The Chief Risk Officer ('CRO'), currently chairs the RMM, attended by the CEO and Business Heads. To attend to all financial crime risk related discussions and matters in the RMM, the Chief Compliance Officer and Money Laundering Reporting Officer are key members of the RMM.

Key risk management processes

We assess the effectiveness of our financial crime risk management framework on an ongoing basis and invest in enhancing our operational control capabilities and technology solutions to deter and detect criminal activity. We have continued to simplify our end to end financial crime risk management framework, streamlining and de-duplicating policy requirements, while also strengthening our financial crime risk taxonomy and control libraries, our investigative and monitoring capabilities through technology deployments, as well as developing more targeted metrics. We have also enhanced governance and reporting.

We are committed to working in partnership with the wider industry and the public sector in managing financial crime risk, protecting the integrity of the financial system and the communities we serve. We participate in numerous public-private partnerships and information-sharing initiatives, also supporting national governments and international standard setters' reform activity. In 2021, there was a particular focus on reform activity in the EU and the UK, where we were front and centre of industry responses to a number of consultation papers focused on the overall effectiveness of the anti-money laundering framework. We also took part in a number of round-tables organised by the Financial Action Task Force, supporting their strategic review, as well as their work on digitisation and beneficial ownership registers. These align with our objectives of promoting a public policy and regulatory environment that embraces the use of technology in building the future financial crime framework to ensure our bank is more resilient and secure, while enabling benefits for customers.

ESG disclosures

We have continued our efforts to combat financial crime risks and reduce their impact on our organisation, our customers and the communities that we serve. These financial crime risks include money laundering, terrorist and proliferation financing, tax evasion, bribery and corruption, sanctions, fraud and market abuse. As part of this work, we have made progress on several key initiatives, enabling us to manage and mitigate these risks more effectively, and further our pioneering work in financial crime risk management across the financial services industry.

HSBC operates a zero tolerance approach to bribery and corruption, and considers such activity to be unethical and contrary to good environmental, social and corporate governance. HSBC, its staff and third parties are prohibited from engaging in or facilitating bribery or corruption. HSBC has a global anti-bribery and corruption policy ('AB&C Policy'), which sets out the key principles and minimum control requirements that enable HSBC to mitigate bribery and corruption risk and comply with all laws and regulations in the countries where we operate, including the UK Bribery Act and France's Loi Sapin II. In order to prevent bribery and corruption, the AB&C Policy requires that all activity:

   --    must be conducted without intent to bribe or corrupt; 
   --    must be reasonable and transparent; 
   --    must not be considered lavish or disproportionate to the professional relationship; 
   --    must be appropriately documented with business rationale; and 
   --    must be authorised at an appropriate level of seniority. 

HSBC requires all staff, board of directors and associated persons comply with the principles in the AB&C Policy. Annual mandatory AB&C training is provided to all staff (including temporary workers and contractors), with additional targeted training tailored to the roles and risk rating of individuals. HSBC carries out regular risk assessments, monitoring and testing of its AB&C programme, with any applicable findings included within the annual AB&C Policy refresh. HSBC also maintains clear whistleblowing policies and processes, to ensure that individuals can confidentially report concerns.

There are currently no concluded legal cases regarding bribery or corruption brought against the issuer or its employees during the reporting period.

We continue to invest in new technology to enable us to make an impact in the fight against financial crime, including the use of contextual monitoring in our trade finance business, the enhancement of our fraud monitoring and market surveillance capabilities and the application of machine learning techniques to improve the accuracy and timeliness of our financial crime detection capabilities, with due care and attention paid to the ethical questions arising with the use of AI in particular.

We are confident our adoption of these new technologies will continue to enhance our ability to respond quickly to suspicious activity and be more granular in our risk assessments, helping to protect our customers and the integrity of the financial system.

Skilled Person & Independent Consultant

In December 2012, HSBC Holdings entered into a number of agreements, including an undertaking with the UK Financial Services Authority (replaced with a Direction issued by the UK Financial Conduct Authority ('FCA') in 2013 and again in 2020), as well as a cease-and-desist order with the US Federal Reserve Board ('FRB'), both of which contained certain forward-looking anti-money laundering ('AML') and sanctions-related obligations. HSBC also agreed to retain an independent compliance monitor (who was, for FCA purposes, a 'Skilled Person' under section 166 of the Financial Services and Markets Act and, for FRB purposes, an 'Independent Consultant') to produce periodic assessments of the Group's AML and sanctions compliance programme.

In 2020, HSBC's engagement with the independent compliance monitor, acting in his roles as both Skilled Person and Independent Consultant, concluded. The role of FCA Skilled Person was assigned to a new individual in the second quarter of 2020. Separately, a new FRB Independent Consultant was appointed in the second quarter of 2021 pursuant to the cease-and-desist order.

The new Skilled Person issued a final report in June 2021, concluding its review. The 2021 FCA Firm Evaluation Letter confirmed that there is no requirement for a further Skilled Person review, finding that "HSBC had delivered its plans and developed an automated transaction monitoring capability that is effective overall". The new Independent Consultant carried out the eighth annual review for the FRB and issued its report in November 2021. Overall, the Independent Consultant assessed that HSBC's OFAC compliance programme is substantially compliant with regulatory expectations and is "well-performing, relative to its purpose and design". For the second year running the Independent Consultant also found HSBC in compliance with each sub-paragraph of the December 2012 FRB Cease and Desist Consent Order (the 'Consent Order').

Model risk

Overview

Model risk is the potential for adverse consequences from business decisions informed by models, which can be exacerbated by errors in methodology, design or the way they are used. Model risk arises in both financial and non-financial contexts whenever business decision making includes reliance on models.

Key developments in 2021

In 2021, we continued to make improvements in our model risk management processes, amid regulatory changes in model requirements.

Initiatives during the year included:

-- We redeveloped, validated and submitted critical Internal Ratings Based ('IRB') Approach models for credit risk, Internal Model Method ('IMM') for counterparty credit risk and Internal Model Approach ('IMA') models for market risk to the PRA in response to regulatory capital changes. These new models have been built to enhanced standards using improved data as a result of investment in processes and systems.

-- We redeveloped and validated models impacted by changes to alternative rate setting mechanisms due to the IBOR transition.

-- We made further enhancements to our control framework for models used in financial reporting processes to address the control weaknesses that emerged as a result of significant increases in model adjustments and overlays that were applied to compensate for the impact of Covid-19 on models and to introduce a requirement for second line of defence to approve material models prior to use.

-- Our businesses and functions were more involved in the development and management of models, hiring colleagues who had strong model risk skills. They also put an enhanced focus on key model risk drivers such as data quality and model methodology.

-- Our model owners in businesses and functions fully embedded the requirements included in the model risk policy and standards introduced in 2020.

-- We delivered a suite of training on model risk to front line teams to improve their awareness of model risk and their adherence to the governance framework.

-- We rolled out new model risk appetite measures, which are more forward looking and will help our businesses and functions manage model risk more effectively.

-- We continued the transformation of the Model Risk Management team, with changes to the model validation processes, including new systems and processes. Key senior hires were made during the year to lead the business areas and regions to strengthen oversight and expertise within the function. We also made changes to the model inventory system to provide businesses and functions with improved functionality and more detailed information related to model risk.

-- We initiated a programme of development related to climate risk and models using advanced analytics and machine learning, which have become critical areas of focus that will grow in importance in 2022 and beyond. We also added qualified specialist skills to the model risk teams to manage the increased model risk.

Governance and structure

The group's Model Risk Committee is chaired by our Chief Risk Officer and provides oversight of model risk. The committee includes senior leaders and risk owners across the Lines of Business and Risk and focuses on model-related concerns and key model risk metrics.

Key risk management processes

We use a variety of modelling approaches, including regression, simulation, sampling, machine learning and judgemental scorecards for a range of business applications. These activities include customer selection, product pricing, financial crime transaction monitoring, creditworthiness evaluation and financial reporting. Global responsibility for managing model risk is delegated from the RMM to the Group Model Risk Committee, which is chaired by the Group Chief Risk and Compliance Officer. This committee regularly reviews our model risk management policies and procedures, and requires the first line of defence to demonstrate comprehensive and effective controls based on a library of model risk controls provided by Model Risk Management.

Model Risk Management also reports on model risk to senior management on a regular basis through the use of the risk map, risk appetite metrics and top and emerging risks.

We regularly review the effectiveness of these processes, including the model oversight committee structure, to help ensure appropriate understanding and ownership of model risk is embedded in the businesses and functions.

Insurance manufacturing operations risk Overview

The key risks for our insurance manufacturing operations are market risks, in particular interest rate and equity, credit risks and insurance underwriting and operational risks. These have a direct impact on the financial results and capital positions of the insurance operations. Liquidity risk, whilst significant in other parts of the bank, is relatively minor for our insurance operations.

HSBC's insurance business

We sell insurance products worldwide through a range of channels including our branches, direct channels and third-party distributors. The majority of sales are through an integrated bancassurance model that provides insurance products principally for customers with whom we have a banking relationship.

The insurance contracts we sell relate to the underlying needs of our customers, which we can identify from our point-of-sale contacts and customer knowledge. For the products we manufacture, the majority of sales are of savings, universal life and protection contracts.

We choose to manufacture these insurance products in HSBC subsidiaries based on an assessment of operational scale and risk appetite. Manufacturing insurance allows us to retain the risks and rewards associated with writing insurance contracts by keeping part of the underwriting profit and investment income within the Group.

Where we do not have the risk appetite or operational scale to be an effective insurance manufacturer, we engage with a small number of leading external insurance companies in order to provide insurance products to our customers through our banking network and direct channels. These arrangements are generally structured with our exclusive strategic partners and earn the group a combination of commissions, fees and a share of profits. We distribute insurance products in all of our geographical regions.

Insurance products are sold through all global businesses, but predominantly by WPB and CMB through our branches and direct channels

Insurance manufacturing operations risk management

Key developments in 2021

The insurance manufacturing subsidiaries follow the group's risk management framework. In addition, there are specific policies and practices relating to the risk management of insurance contracts. There were no material changes to the policies and practices over 2021, although enhancements were made to the product pricing and profitability framework to allow for the transition to IFRS17.

Governance

Insurance manufacturing risks are managed to a defined risk appetite, which is aligned to the bank's risk appetite and risk management framework, including the three lines of defence model. For details on the governance framework, see page 21. The Group Insurance Risk Management Meeting oversees the control framework globally and is accountable to the WPB Risk Management Meeting on risk matters relating to the insurance business.

The monitoring of the risks within the insurance operations is carried out by Insurance Risk teams. The Bank's risk stewardship functions support the Insurance Risk teams in their respective areas of expertise.

Stress and scenario testing

Stress testing forms a key part of the risk management framework for the insurance business. We participate in local and Group-wide regulatory stress tests, including the Bank of England stress test of the banking system, the European Insurance and Occupational Pensions Authority stress test, and individual country insurance regulatory stress tests.

The results of these stress tests and the adequacy of management action plans to mitigate these risks are considered in the HBEU ICAAP and the entities' regulatory Own Risk and Solvency Assessments (ORSAs).

Management and mitigation of key risk types

Market risk

All our insurance manufacturing subsidiaries have market risk mandates and limits that specify the investment instruments in which they are permitted to invest and the maximum quantum of market risk that they may retain. They manage market risk by using, among others, some or all of the techniques listed below, depending on the nature of the contracts written:

-- We are able to adjust bonus rates to manage the liabilities to policyholders for products with discretionary participating features ('DPF'). The effect is that a significant portion of the market risk is borne by the policyholder.

-- We use asset and liability matching where asset portfolios are structured to support projected liability cash flows. The Group manages its assets using an approach that considers asset quality, diversification, cash flow matching, liquidity, volatility and target investment return. We use models to assess the effect of a range of future scenarios on the values of financial assets and associated liabilities, and ALCOs employ the outcomes in determining how best to structure asset holdings to support liabilities.

   --    We use derivatives to protect against adverse market movements. 

-- We design new products to mitigate market risk, such as changing the investment return sharing portion between policyholders and the shareholder.

   --    We exit, to the extent possible, investment portfolios whose risk is considered unacceptable. 

Credit risk

Our insurance manufacturing subsidiaries also have credit risk mandates and limits within which they are permitted to operate, which consider the credit risk exposure, quality and performance of their investment portfolios. Our assessment of the creditworthiness of issuers and counterparties is based primarily upon internationally recognised credit ratings and other publicly available information.

Stress testing is performed on investment credit exposures using credit spread sensitivities and default probabilities.

We use a number of tools to manage and monitor credit risk. These include a credit report containing a watch-list of investments with current credit concerns, primarily investments that may be at risk of future impairment or where high concentrations to counterparties are present in the investment portfolio. Sensitivities to credit spread risk are assessed and monitored regularly.

Capital and liquidity risk

Capital risk for our insurance manufacturing subsidiaries is assessed in the group's ICAAP based on their financial capacity to support the risks to which they are exposed. Capital adequacy is assessed on both the group's economic capital basis, and the relevant local insurance regulatory basis. The group's economic capital basis is largely aligned to European Solvency II regulations.

Risk appetite buffers are set to ensure that the operations are able to remain solvent on both bases, allowing for business-as-usual volatility and extreme but plausible stress events.

Liquidity risk is managed by cash flow matching and maintaining sufficient cash resources, investing in high credit-quality investments with deep and liquid markets, monitoring investment concentrations and restricting them where appropriate, and establishing committed contingency borrowing facilities.

Insurance manufacturing subsidiaries complete quarterly liquidity risk reports and an annual review of the liquidity risks to which they are exposed.

Insurance underwriting risk

Our insurance manufacturing subsidiaries primarily use the following frameworks and processes to manage and mitigate insurance underwriting risks:

   --    a formal approval process for launching new products or making changes to products; 

-- a product pricing and profitability framework which requires initial and ongoing assessment of the adequacy of premiums charged on new insurance contracts to meet the risks associated with them;

   --    a framework for customer underwriting; 

-- reinsurance which cedes risks above our appetite thresholds to third party reinsurer thereby limiting our exposure; and

   --    oversight of expense and reserving risks by entity Actuarial Control Committees. 

--

Insurance manufacturing operations risk in 2021

Measurement

The following table shows the composition of assets and liabilities by contract type.

 
Balance sheet of insurance manufacturing subsidiaries by type of contract 
(Audited) 
                                                                                                                                                     Shareholder 
                                                                                With                     Unit-                   Other                    assets 
                                                                                 DPF                    linked            contracts(1)           and liabilities                   Total 
                                                                                GBPm                      GBPm                    GBPm                      GBPm                    GBPm 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Financial assets                                                              19,384                     2,924                     254                     2,704                  25,266 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
 
  *    financial assets designated and otherwise mandatorily 
       measured at fair value through profit or loss                           9,876                     2,859                      89                     1,236                  14,060 
- derivatives                                                                     47                         -                       -                         1                      48 
- financial investments - at amortised 
 cost                                                                            815                         -                       -                        42                     857 
- financial investments - at fair value 
 through other comprehensive income                                            7,490                         -                     104                     1,327                   8,921 
- other financial assets(2)                                                    1,156                        65                      61                        98                   1,380 
Reinsurance assets                                                                 -                        53                     104                         -                     157 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
PVIF(3)                                                                            -                         -                       -                       811                     811 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Other assets and investment properties                                           748                         1                       -                        59                     808 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Total assets at 31 Dec 2021                                                   20,132                     2,978                     358                     3,574                  27,042 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Liabilities under investment contracts 
 designated at fair value                                                          -                     1,031                       -                         -                   1,031 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Liabilities under insurance contracts                                         19,998                     1,938                     328                         -                  22,264 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Deferred tax(4)                                                                  133                         6                       -                        46                     185 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Other liabilities                                                                  -                         -                       -                     2,003                   2,003 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Total liabilities at 31 Dec 2021                                              20,131                     2,975                     328                     2,049                  25,483 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Total equity at 31 Dec 2021                                                        -                         -                       -                     1,559                   1,559 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
Total liabilities and equity at 31 Dec 
 2021                                                                         20,131                     2,975                     328                     3,608                  27,042 
                                                              ----------------------  ------------------------  ----------------------  ------------------------  ---------------------- 
 
 
Financial assets                                                               20,261                     2,412                      249                     2,490                   25,412 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
 
  *    financial assets designated and otherwise mandatorily 
       measured at fair value through profit or loss                            9,148                     2,352                       92                       991                   12,583 
- derivatives                                                                      76                         -                        -                         2                       78 
- financial investments - at amortised 
 cost                                                                             372                         1                        -                        17                      390 
- financial investments - at fair value 
 through other comprehensive income                                             8,724                         -                      112                     1,341                   10,177 
- other financial assets(2)                                                     1,941                        59                       45                       139                    2,184 
Reinsurance assets                                                                  -                        47                      134                         -                      181 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
PVIF(3)                                                                             -                         -                        -                       647                      647 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Other assets and investment properties                                            809                         1                        -                        60                      870 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Total assets at 31 Dec 2020                                                    21,070                     2,460                      383                     3,197                   27,110 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Liabilities under investment contracts 
 designated at fair value                                                           -                       944                        -                         -                      944 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Liabilities under insurance contracts                                          20,962                     1,512                      342                         -                   22,816 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Deferred tax(4)                                                                   107                         3                        -                        39                      149 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Other liabilities                                                                   -                         -                        -                     1,776                    1,776 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Total liabilities at 31 Dec 2020                                               21,069                     2,459                      342                     1,815                   25,685 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Total equity at 31 Dec 2020                                                         -                         -                        -                     1,425                    1,425 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
Total liabilities and equity at 31 Dec 
 2020                                                                          21,069                     2,459                      342                     3,240                   27,110 
                                                              -----------------------  ------------------------  -----------------------  ------------------------  ----------------------- 
 
   1   'Other contracts' includes term assurance and credit life insurance. 

2 Comprise mainly loans and advances to banks, cash and intercompany balances with other non-insurance legal entities.

   3   Present value of in-force long-term insurance business. 

4 'Deferred tax' includes the deferred tax liabilities arising on recognition of PVIF.

Key risk types

Market risk

(Audited)

Description and exposure

Market risk is the risk of changes in market factors affecting the bank's capital or profit. Market factors include interest rates, equity and growth assets and foreign exchange rates.

Our exposure varies depending on the type of contract issued. Our most significant life insurance products are investment contracts with discretionary participating features ('DPF') issued in France. These products typically include some form of capital guarantee or guaranteed return on the sums invested by the policyholders, to which discretionary bonuses are added if allowed by the overall performance of the funds. These funds are primarily invested in fixed interest assets with a proportion allocated to other asset classes, to provide customers with the potential for enhanced returns. DPF products expose the bank to the risk of variation in

asset returns, which will impact our participation in the investment performance. In addition, in some scenarios the asset returns can become insufficient to cover the policyholders' financial guarantees, in which case the shortfall has to be met by the bank. Amounts are held against the cost of such guarantees. The cost of such guarantees is accounted for as a deduction from the present value of in-force 'PVIF' asset, unless the cost of such guarantees is already explicitly allowed for within the insurance contracts liabilities. The table below shows the total reserve held for the cost of guarantees, the range of investment returns on assets supporting these products and the implied investment return that would enable the business to meet the guarantees. The cost of guarantees decreased to GBP299m (2020: GBP347m) primarily due to increases in interest rates and favourable equity performances in France. For unit-linked contracts, market risk is substantially borne by the policyholder, but some market risk exposure typically remains as fees earned are related to the market value of the linked assets.

 
Financial return guarantees 
(Audited) 
                                            2021                                                                      2020 
                                                Long-term                                                                  Long-term 
                       Investment              investment                                        Investment               investment 
                          returns                 returns                                           returns                  returns 
                          implied             on relevant                     Cost                  implied              on relevant                     Cost 
                     by guarantee              portfolios            of guarantees             by guarantee               portfolios            of guarantees 
                                %                       %                     GBPm                        %                        %                     GBPm 
          -----------------------  ---------------------- 
                                                    0.8 -                                                                      0.7 - 
Capital                         -                     2.0                      127                        -                      2.0                      162 
Nominal 
 annual 
 return                       2.6                     2.2                       92                      2.6                      2.0                       96 
Nominal 
 annual 
 return                       4.5                     2.2                       80                      4.5                      2.0                       89 
At 31 
 Dec                                                                           299                                                                        347 
 

Sensitivities

The following table illustrates the effects of selected interest rate and equity price scenarios on our profit for the year and the total equity of our insurance manufacturing subsidiaries.

Where appropriate, the effects of the sensitivity tests on profit after tax and equity incorporate the impact of the stress on the PVIF. Due in part to the impact of the cost of guarantees and hedging strategies which may be in place, the relationship between the profit and total equity and the risk factors is non-linear. Therefore, the results disclosed should not be extrapolated

to measure sensitivities to different levels of stress. For the same reason, the impact of the stress is not necessarily symmetrical on the upside and downside. The sensitivities are stated before allowance for management actions which may mitigate the effect of changes in the market environment. The sensitivities presented allow for adverse changes in policyholder behaviour that may arise in response to changes in market rates. The differences between the impacts on profit after tax and equity are driven by the changes in value of the bonds measured at fair value through other comprehensive income, which are only accounted for in equity.

 
Sensitivity of the group's insurance manufacturing subsidiaries to 
 market risk factors 
(Audited) 
                                                2021                                                                 2020 
                                           Effect                             Effect                                                              Effect 
                                               on                                 on                           Effect                                 on 
                                           profit                              total                        on profit                              total 
                                        after tax                             equity                        after tax                             equity 
                                             GBPm                               GBPm                             GBPm                               GBPm 
+100 basis 
 point 
 parallel 
 shift 
 in yield 
 curves                                       119                                 96                              110                                 89 
--------------  ---------------------------------  ---------------------------------                                   --------------------------------- 
-100 basis 
 point 
 parallel 
 shift 
 in yield 
 curves                                     (229)                              (203)                            (203)                              (179) 
--------------  ---------------------------------  ---------------------------------                                   --------------------------------- 
10% increase 
 in equity 
 prices                                        46                                 46                               39                                 39 
--------------  ---------------------------------  ---------------------------------                                   --------------------------------- 
10% decrease 
 in equity 
 prices                                      (49)                               (49)                             (42)                               (42) 
--------------  ---------------------------------  ---------------------------------                                   --------------------------------- 
 

.

Credit risk

(Audited)

Description and exposure

Credit risk is the risk of financial loss if a customer or counterparty fails to meet their obligation under a contract. It arises in two main areas for our insurance manufacturers:

-- risk associated with credit spread volatility and default by debt security counterparties after investing premiums to generate a return for policyholders and shareholders; and

-- risk of default by reinsurance counterparties and non-reimbursement for claims made after ceding insurance risk.

The amounts outstanding at the balance sheet date in respect of these items are shown in the table on page 85. The credit quality of the reinsurers' share of liabilities under insurance contracts is assessed as 'satisfactory' or higher as defined on page 33, with 100% of the exposure being neither past due nor impaired. Credit risk on assets supporting unit-linked liabilities is predominantly borne by the policyholder; therefore our exposure is primarily related to liabilities under non-linked insurance and investment contracts and shareholders' funds. The credit quality of these financial assets is included in the table on page 50.

Liquidity risk

(Audited)

Description and exposure

Liquidity risk is the risk that an insurance operation, though solvent, either does not have sufficient financial resources available to meet its obligations when they fall due, or can secure them only at excessive cost.

The following table shows the expected undiscounted cash flows

for insurance contract liabilities at 31 December 2021. The liquidity risk exposure is wholly borne by the policyholder in the case of unit-linked business and is shared with the policyholder for non-linked insurance.

The profile of the expected maturity of insurance contracts at

31 December 2021 remained comparable with 2020.

The remaining contractual maturity of investment contract liabilities is included within 'Financial liabilities designated at fair value' in Note 27.

 
Expected maturity of insurance contract liabilities 
(Audited) 
                                                                    Expected cash flows (undiscounted) 
                                   Within                                                                                 Over 15 
                                   1 year                    1-5 years                    5-15 years                        years                      Total 
                                     GBPm                         GBPm                          GBPm                         GBPm                       GBPm 
Unit-linked                           230                          565                           927                          926                      2,648 
With DPF and 
 Other 
 contracts                          1,341                        5,102                         7,318                        6,415                     20,176 
At 31 Dec 
 2021                               1,571                        5,667                         8,245                        7,341                     22,824 
 
Unit-linked                           222                          539                           790                          672                      2,223 
With DPF and 
 Other 
 contracts                          1,565                        5,765                         7,735                        6,077                     21,142 
At 31 Dec 
 2020                               1,787                        6,304                         8,525                        6,749                     23,365 
 

.

Insurance underwriting risk

Description and exposure

Insurance underwriting risk is the risk of loss through adverse experience, in either timing or amount, of insurance underwriting parameters (non-economic assumptions). These parameters include mortality, morbidity, longevity, lapse and expense rates.

The principal risk we face is that, over time, the cost of the contract, including claims and benefits, may exceed the total amount of premiums and investment income received.

The table on page 85 analyses our insurance manufacturing exposures by type of contract.

The insurance risk profile and related exposures remain largely

consistent with those observed at 31 December 2020.

Sensitivities

The table below shows the sensitivity of profit and total equity to reasonably possible changes in non-economic assumptions across all our insurance manufacturing subsidiaries.

Mortality and morbidity risk is typically associated with life insurance contracts. The effect on profit of an increase in mortality or morbidity depends on the type of business being written.

Sensitivity to lapse rates depends on the type of contracts being written. For a portfolio of term assurance, an increase in lapse rates typically has a negative effect on profit due

to the loss of future income on the lapsed policies. However, some contract lapses have a positive effect on profit due to the existence of policy surrender charges. We are most sensitive to a change in lapse rates in France.

Expense rate risk is the exposure to a change in the allocated cost of administering insurance contracts. To the extent that increased expenses cannot be passed on to policyholders, an increase in expense rates will have a negative effect on our profits. This risk is generally greatest for smaller entities.

 
Sensitivity analysis 
(Audited) 
                                             2021                   2020 
                                             GBPm                   GBPm 
                            ---------------------  --------------------- 
Effect on profit after 
 tax and total equity 
 at 31 Dec 
                            --------------------- 
10% increase in mortality 
 and/or morbidity rates                      (20)                   (15) 
10% decrease in mortality 
 and/or morbidity rates                        19                     15 
10% increase in lapse 
 rates                                       (19)                   (19) 
10% decrease in lapse 
 rates                                         20                     21 
10% increase in expense 
 rates                                       (40)                   (46) 
10% decrease in expense 
 rates                                         40                     43 
 
 
Corporate Governance Report 
 

The statement of corporate governance practices set out on pages 88 to 96, together with the information incorporated by reference, constitutes the Corporate Governance Report of the bank. The following disclosures, read together with those in the Strategic Report, including the section 172 statement on pages 9 and 10 and reporting on employee engagement on pages 7 to 10 describe how the Board has discharged its duty under section 172 of the Companies Act 2006 (the 'Act'), as well as the requirements under the Companies (Miscellaneous Reporting) Regulations 2018 (the 'Reporting Regulations').

Engagement with employees, suppliers, customers and other key stakeholders:

 
 
Customers           Page 9       How we do business 
                    Page 9       section 172 
                                  statement 
Employees           Page 9       How we do business 
                    Pages 9 and  section 172 
                     10           statement 
                    Pages 94     Corporate Governance 
                     to 95        statement 
Communities         Pages 8 and 
 / the environment   9           How we do business 
Regulators          Page 10      How we do business 
                    Page 9       section 172 
                                  statement 
Suppliers           Page 10      How we do business 
                    Page 9       section 172 
                                  statement 
 

The bank, together with the wider Group, is committed to high standards of corporate governance. The Group has a comprehensive range of principles, policies and procedures influenced by the UK Corporate Governance Code with requirements in respect of Board independence, composition and effectiveness to ensure that the Group is well managed, with appropriate oversight and control. During the year, the bank adhered to these corporate governance principles, policies and procedures, as applicable.

 
Board of Directors 
 

As at 31 December 2021, the Board comprised 10 Directors including the Chair, eight non-executive Directors, and two executive Directors, being the Chief Executive Officer and the Chief Financial Officer. All Directors are subject to election or re-election at the bank's Annual General Meeting ('AGM'). The Directors serving at 31 December 2021 are set out below.

 
Directors 
 

Stephen O'Connor

Chairman

Chairman of the Nomination, Remuneration & Governance Committee

Appointed to the Board: May 2018. Chairman since August 2018.

Stephen is a non-executive Director and Vice Chairman of HSBC Continental Europe, Chairman of Quantile Group Limited and its subsidiary Quantile Technologies Limited, and a Director of the London Stock Exchange plc. He is also a non-executive Director of the FICC Markets Standards Board. He has more than 25 years' investment banking experience in London and New York.

Former appointments include: Senior Independent Director, Chairman of the Risk Committee and member of both the Audit and Nomination Committees of the London Stock Exchange Group plc and Chairman of the International Swaps and Derivatives Association, prior to which he was Managing Director and a member of the Fixed Income Management Committee at Morgan Stanley.

Colin Bell

Executive Director and Chief Executive Officer

Chairman of the Executive Committee and Executive Director of the Board

Appointed to the Board and as Chief Executive Officer: February 2021.

Colin Bell is Chief Executive Officer, HSBC Bank plc and HSBC Europe. He joined HSBC in July 2016 and most recently held the role of Group Chief Compliance Officer until February 2021. He is a member of the Supervisory Board, Remuneration, Nomination and Mediation Committees of HSBC Trinkaus & Burkhardt AG and is an Executive Director of HSBC Bank plc.

Before HSBC, Colin worked at UBS, where he was Head of Compliance and Operational Risk Control. He has more than 10 years of experience in managing risk and financial crime, following 16 years in the British Army.

During his time in the Army, he held a variety of command and staff appointments, including operational tours of Iraq and Northern Ireland, time in the Ministry of Defence, a NATO appointment and completion of the Advanced Command and Staff Course.

David Watts

Executive Director and Chief Financial Office r

Member of the Executive Committee and Executive Director of the Board

Appointed to the Board and as Chief Finance Officer: December 2021.

Dave joined the HSBC Group in 1994 and was previously a Director and Chief Financial Officer of HSBC UK Bank plc.

Former HSBC Group roles include: Chief Financial Officer for HSBC Bank plc, Global Commercial Banking, the Middle East and North Africa, Group HSBC Technology and Operations, Global Banking, and HSBC Securities (USA) Inc; Head of Group Cost and Investment Reporting & Analysis; and Manager Treasury Services, France.

Norma Dove-Edwin

Independent non-executive Director

Appointed to the Board: October 2021.

Norma serves as Chief Information Officer of ESO at National Grid Plc. She is also a non-executive Director of Pod Point Group Holdings plc.

Former appointments include: Group Chief Data and Information Officer at Places for People and held a number of positions at British American Tobacco Plc including as Head of Global Data Services.

Dame Mary Marsh

Non-executive Director

Member of the Transformation, Operational Resilience and Technology Committee

Appointed to the Board: January 2009.

Mary is a Director of the London Symphony Orchestra, a member of the Governing Body and the Audit and Risk Committee of the London Business School, a Trustee and Deputy Chair of the British Spanish Society and a Trustee of Teach First.

Former appointments include: Non-executive Chair of the Trustees of the Royal College of Paediatrics and Child Health, founding Director of the Clore Social Leadership Programme and Chief Executive of the National Society for the Prevention of Cruelty to Children.

Yukiko Omura

Independent non-executive Director

Member of the Audit Committee

Appointed to the Board: May 2018.

Yukiko is a senior independent non-executive Director of The Private Infrastructure Development Group Limited ('PIDG'). She also serves as a non-executive Director of Assured Guaranty Ltd, and a member of the Supervisory Board of Nishimoto HD Co. Ltd. She has more than 35 years' international professional experience in both the public and private financial sector, performing senior roles for JP Morgan, Lehman Brothers, UBS and Dresdner Bank.

Former appointments include: Chair of GuarantCo Limited, a subsidiary of PIDG, Under-Secretary General and COO/Vice President of the International Fund for Agricultural Development and Executive Vice President and CEO of the Multilateral Investment Guarantee Agency of the World Bank Group.

Juliet Robinson

Independent non-executive Director

Chair of the Transformation, Operational Resilience and Technology Committee and member of the Risk Committee

Appointed to the Board: February 2021.

Former appointments include: Dual role as European Head of Operations and Global Head of Shared Services and Banking Operations and other senior management positions at Morgan Stanley. Prior to 2007 she performed senior roles within Goldman Sachs International.

Dr Eric Strutz

Independent non-executive Director

Chairman of the Risk Committee and member of the Nomination, Remuneration & Governance Committee and Transformation, Operational Resilience and Technology Committee

Appointed to the Board: October 2016.

Eric is a member of the Supervisory Board and Risk Committee and Chairman of the Audit Committee of HSBC Trinkaus & Burkhardt AG, a member of the Board of Directors and the Remuneration Committee and Chairman of the Audit Committee of Global Blue Group Holding AG, and a member of the Advisory Board and Chairman of the Audit & Risk Committee of Luxembourg Investment Company 261 Sarl.

Former appointments include: Vice Chairman and Lead Independent Director of Partners Group Holding AG, where he also Chaired the Risk and Audit Committee, Chief Financial Officer of Commerzbank Group, Partner and Director of the Boston Consulting Group, as well as non-executive Director of Mediobanca Banca di Credito Finanziario SpA.

John Trueman

Deputy Chairman and non-executive Director

Member of the Audit Committee, the Risk Committee and the Nomination, Remuneration & Governance Committee

Appointed to the Board: September 2004. Deputy Chairman since December 2013.

Former appointments include: Chairman and member of the Risk Committee of HSBC Global Asset Management Limited and Deputy Chairman of S.G. Warburg & Co Ltd.

Andrew Wright

Independent non-executive Director

Chairman of the Audit Committee and member of the Risk Committee and the Nomination, Remuneration & Governance Committee

Appointed to the Board: May 2018.

Andrew is a member of the Supervisory Board and chairs the Risk Committee of HSBC Trinkaus & Burkhardt AG.

Former appointments include: Treasurer to the Prince of Wales and the Duchess of Cornwall, a role he held from May 2012 until June 2019, Global Chief Financial Officer for the Investment Bank at UBS AG, Chief Financial Officer, Europe and the Middle East at Lehman Brothers and Chief Financial Officer for the Private Client and Asset Management Division at Deutsche Bank.

 
Board Changes during 2021 and following 
 the year-end 
 

Nuno Matos stepped down from the Board and Colin Bell succeeded him as a Director and Chief Executive Officer of the bank and Europe with effect from 22 February 2021.

Stephen Moss stepped down from the Board on 23 February 2021 to take up the position of Chief Executive Officer, Middle East, North Africa and Turkey (MENAT) in April 2021.

Jacques Fleurant stepped down from the Board on 30 September 2021 and Dave Watts succeeded him as a Director and Chief Financial Officer of the bank with effect from 15 December 2021.

Juliet Robinson joined the Board as an independent non-executive Director and member of the Risk Committee with effect from

1 February 2021. In 1 January 2021 she was appointed as Chair of the Transformation, Operational Resilience and Technology Committee.

Norma Dove-Edwin joined the Board as an independent non-executive Director with effect from 28 October 2021.

 
Company Secretary 
 

The responsibilities of the Company Secretary include ensuring good governance practices at Board level and effective information flows within the Board and its committees and between senior management and the non-executive Directors.

Philip Jockelson acted as Company Secretary of the bank until

28 February 2021 and Alison Campbell was appointed as Company Secretary from 1 March 2021.

 
Board of Directors 
 

Key responsibilities

The Board, led by the Chair, is responsible amongst other matters for:

(i) promoting the long-term success of the bank and delivering sustainable value to shareholders and other stakeholders;

(ii) entrepreneurial leadership of the bank within a framework of prudent and effective controls which enables risks to be assessed and managed;

(iii) setting the bank's strategy and risk appetite statement including monitoring the bank's risk profile;

(iv) establishing and monitoring the effectiveness of procedures for maintenance of a sound system of control and risk management, and compliance with statutory and regulatory obligations; and

(v) approving the capital and operating plans and material transactions on the recommendation of management.

The role of the non-executive Directors is to support the development of proposals on strategy, hold management to account and ensure the executive Directors are discharging their responsibilities properly by promoting a culture that encourages constructive challenge. Non-executive Directors also review the performance of management in meeting agreed goals and objectives. The Chair regularly meets with the non-executive Directors without executive Directors in attendance after Board meetings, and otherwise, as necessary.

Operation of the Board

During 2021, the Board was required to meet at least six times a year; six additional meetings were scheduled to help facilitate, amongst other things, the execution of the bank's transformation strategy. The Board agenda is agreed with the Chair, working closely with the Company Secretary, in advance of scheduled meetings. The agenda is informed by forward-looking planning and additional emerging matters that require Board oversight or approval.

The Chief Risk Officer, General Counsel, and Company Secretary are regular attendees at Board meetings, and other senior executives attend to contribute their subject matter expertise and insight, as required.

Board activities during 2021

During 2021, the Board focused on the implementation of approved strategy and execution of the bank's transformation programme across the region, supporting senior management and overseeing performance, risk and capital. The Board considered performance against financial and other strategic objectives, key business challenges, emerging risks, business development and relationships with the bank's key stakeholders.

Deep dives on key aspects of the bank's business were also conducted to consider the performance and strategy of targeted businesses and countries. Throughout the year, the Board received regular updates from management including the implementation of regulatory programmes, technology, operations and resilience, as well as people, culture and talent.

During the year the Board also approved the financial, capital, liquidity and funding plans put forward by management and monitored the implementation of plans. Further information on the principal decisions made by the Board during 2021, including in respect of the strategic reset and capital plans is located in the section 172 statement on pages 9 to 11.

 
Directors' emoluments 
 

Details of the emoluments of the Directors of the bank for 2021, disclosed in accordance with the Act, are shown in Note 5 'Employee compensation and benefits'.

Non-executive Directors do not have service contracts, but are engaged through letters of appointment. There are no obligations in the non-executive Directors' letters of appointment that could give rise to payments other than fees due or payments for loss of office.

 
Board committees 
 

The Board delegates oversight of certain audit, risk, remuneration, nomination and governance matters to its committees. Each standing Board committee is chaired by a non-executive Board member and has a remit to cover specific topics in accordance with their respective terms of reference. Only non-executive Directors are members of Board committees. The Chairman of each non-executive Board Committee reports to the Board on the activities of the Committee since the previous Board meeting.

Board and Committee effectiveness and performance

The Board understands the importance of, and benefits that derive from regular reviews of the effectiveness of the Board and its committees. In 2020, the bank was subject to an internally facilitated subsidiary governance review of the Group's main subsidiary Boards and Committees. The review focused on (i) the composition, skill-set, time commitment and fees for Boards and Committees; (ii) service quality and scope of governance and secretarial support; and (iii) the effectiveness of the bank's relationship with the Group. The results of the subsidiary governance review of the bank have been considered by the Board and work was progressed during 2021 to address recommendations. An annual review of the terms of reference for the Board and its committees was facilitated by the Corporate Governance and Secretariat function which assessed that the Board and its committees had materially complied with their respective terms of reference during 2021. Executive Directors are also subject to performance evaluation which helps to determine the level of variable pay they receive each year.

At the date of this report, the following are the principal Committees of the Board:

Audit Committee

Key Responsibilities

The Audit Committee is accountable to the Board and has non-executive responsibility for oversight of financial reporting related matters, internal controls over financial reporting and implementation of the group policies and procedures for capturing and responding to whistleblower concerns.

The Committee's key responsibilities include:

(i) monitoring and assessing the integrity of the financial statements, formal announcements and supplementary regulatory information in relation to the bank's financial performance;

(ii) reviewing, as applicable, compliance with accounting standards, listing rules, and other requirements in relation to financial reporting;

(iii) reviewing and monitoring the relationship with the external auditor; and

(iv) overseeing the work of Internal Audit and monitoring and assessing the effectiveness, performance, resourcing, independence and standing of the function.

The committee has responsibility for the oversight of the bank's whistleblowing arrangements, and receives regular updates on matters relating to the whistleblowing arrangements that are in place.

Committee activities during 2021

In addition to significant accounting judgements, key matters considered by the Committee during the year were regulatory reporting and control enhancements, interbank offered rates (IBOR) transition, IFRS 17 implementation, the development of climate-related disclosure, pension risk, the bank's financial resources and capital, transformation of the Finance function, the independence, fees and performance of the external auditor, PwC, and updates on key issues identified by Internal Audit related to the bank and its subsidiaries.

The committee also received updates from the Chairs of the Audit committees of key subsidiaries of the Bank, updates from the external auditor on the progress and findings of their audit, and bi-annual updates on the tax position of the bank and its subsidiaries.

Operation of the Committee

The committee held seven scheduled meetings during the year and held separate meetings with each of the Chief Finance Officer, the Chief Risk Officer, the Head of Internal Audit and representatives of the external auditor without management present.

The committee meets regularly with the bank's senior financial and Internal Audit management and the external auditors to consider, among other matters, the bank's financial reporting, the nature and scope of audit reviews, the effectiveness of the systems of internal control relating to financial reporting and the monitoring of the Finance function transformation programme.

The Chief Financial Officer, Financial Controller, Chief Risk Officer, Head of Internal Audit, and Company Secretary are standing attendees and regularly attend Committee meetings to contribute their subject matter expertise and insight. Other members of senior management routinely attended meetings of the Committee. The external auditor attended all meetings.

During 2021 the committee continued to actively engage with the bank's key subsidiaries and key subsidiary audit committees, with regular reporting throughout the year. The Chair of the committee regularly meets with the Chair of the Group Audit Committee (GAC) to help maintain connectivity with the group and develop deeper understanding on judgements around key matters. Further, from time to time the Chair is invited to attend meetings of the GAC on relevant topics. The committee comprises a majority of independent non-executive Directors. The current members are Andrew Wright (Chair), Yukiko Omura and John Trueman.

 
Significant accounting judgements and related matters considered by 
 the Audit Committee ('AC') for the year ended 2021 included: 
 
Interim and annual reporting        The AC considered key matters in relation 
                                     to interim and annual reporting, including 
                                     changes to segmental reporting. 
Expected credit loss ('ECL')        The AC considered key judgements in relation 
                                     to ECL, in particular post-model adjustments 
                                     in certain sectors due to economic uncertainty. 
Valuation of financial instruments  The AC considered key valuation metrics and 
                                     judgements involved in the determination of 
                                     the fair value of financial instruments. The 
                                     AC also considered management's analysis of 
                                     exit losses upon the novation of certain derivative 
                                     portfolios and the determination that there 
                                     was insufficient evidence to support the introduction 
                                     of fair value adjustments in respect of these. 
Going concern                       The AC considered a wide range of information 
                                     relating to present and potential conditions, 
                                     including projections for profitability, cash 
                                     flows, liquidity and capital. 
Impairment of investment            The AC reviewed management's periodic assessment 
 in subsidiaries                     of impairment of investments in subsidiaries 
                                     and paid particular attention to the reliability 
                                     of cash flow projections and long-term growth 
                                     rate and discount rate assumptions. Management 
                                     assessed that there had been no impairment 
                                     of the bank's investment in HSBC Continental 
                                     Europe for the year ended 2021 with due regard 
                                     to the sensitivity of this judgement to changes 
                                     in assumptions, in particular those relating 
                                     to the sale of retail banking activities in 
                                     Continental Europe. 
Appropriateness of provisioning     The AC received reports from management on 
 for legal proceedings and           the recognition and measurement of provisions 
 regulatory matters                  and contingent liabilities for legal proceedings 
                                     and regulatory matters, including investigations 
                                     by regulators and competition and law-enforcement 
                                     authorities. 
Regulatory reporting                The AC reviewed management's efforts to strengthen 
                                     and simplify the end-to-end operating and 
                                     control model, including independent external 
                                     reviews of key aspects of regulatory reporting. 
IBOR transition                     The AC considered the implications of benchmark 
                                     interest rate reform, including the recognition 
                                     and measurement of financial instruments and 
                                     related disclosures. 
Controls                            The AC considered the financial control environment 
                                     on an ongoing basis through the year, reviewing 
                                     and challenging remediation actions undertaken 
                                     and enhancements made. This included confirmation 
                                     of mitigating controls where programmes of 
                                     work had not fully completed by the year end. 
                                     Areas of particular focus in 2021 have been 
                                     Model Risk Governance, controls over use of 
                                     external market data, accounting and tax implications 
                                     of Merger and Acquisition ('M&A') transactions, 
                                     general ledger substantiation and Financial 
                                     Statement Disclosures. 
Tax                                 The AC reviewed management's judgements on 
                                     the recognition and measurement of deferred 
                                     tax assets and liabilities, in particular 
                                     those arising from the sale of retail banking 
                                     activities in Continental Europe, and the 
                                     accounting and disclosure of retrospective 
                                     VAT assessments issued by HMRC. 
Environmental, Social and           The AC considered regulatory developments 
 Governance ('ESG') Reporting        in ESG Reporting, in particular at 31 December 
                                     2021 for bank subsidiaries in the European 
                                     Union. 
Restructuring provisions            The AC considered key judgements in relation 
                                     to restructuring provisions, mainly relating 
                                     to transformation in Continental Europe and 
                                     Germany. 
 

Risk Committee

Key Responsibilities

The Risk Committee is accountable to the Board and has overall non-executive responsibility for oversight of risk-related matters and the risks impacting the bank.

The committee's key responsibilities include:

(i) advising the Board on risk appetite-related matters, and key regulatory submissions;

(ii) overseeing and advising the Board on all risk-related matters, including financial risks, non-financial risks and the effectiveness of the bank's conduct framework;

(iii) reviewing, challenging and satisfying itself that the bank's stress testing framework, governance and internal controls are robust; and

(iv) to review the effectiveness of the bank's risk management framework and internal control systems (other than internal financial controls overseen by the Audit Committee).

Committee activities during 2021

Key matters considered by the committee during the year included the bank's approach to the financial and non-financial risks in the context of evolving Covid-19 infections and strict lockdown measures across the region, wholesale credit and market risks including, interbank offered rates ('IBOR') transition, geopolitical, operational and climate-related risks.

The committee also reviewed and challenged management on key regulatory processes, including the bank's internal capital adequacy assessment process ('ICAAP') and the internal liquidity adequacy assessment process ('ILAAP'); recovery and resolution plans (including the bank's response to the Bank of England's Resolvability Assessment Framework requirements); the outcome of stress tests undertaken during the year; and the bank's capital liquidity and funding plans.

Operation of the Committee

The committee held 11 scheduled meetings during the year. The Chief Risk Officer, Chief Financial Officer, Head of Internal Audit, and Head of Risk Strategy are standing attendees and regularly attend committee meetings to contribute their subject matter expertise and insight.

The committee reviews and challenges current and forward-looking risk issues, and the regional senior business leaders are regularly invited to participate at committee meetings, working together with functional and regional leaders across all three lines of defence.

The Chair and members of the committee meet regularly with the bank's senior financial, risk, internal audit and compliance management and the external auditors to consider, among other matters, risk reports and internal audit reports and the effectiveness of compliance activities.

During 2021 the committee continued to actively engage with the bank's key subsidiaries and key subsidiary risk committees, with regular reporting from the respective Chairs throughout the year. The Chair of the committee attended several Group-led meetings to help promote connectivity, escalation and cascade of important topics. The committee comprises a majority of independent non-executive Directors. The current members are: Eric Strutz (Chair), Juliet Robinson, John Trueman and Andrew Wright.

Transformation, Operational Resilience and Technology Committee

Key Responsibilities

The Transformation, Operational Resilience and Technology Committee ('TRT') was established during the year to assist the Board and Risk Committee with their respective responsibilities in relation to the bank's transformation strategy, operational resilience, as well as the governance and oversight of technology.

The Committee's key responsibilities include:

(i) reviewing progress of the transformation strategy and the steps management have taken to manage risk, and to monitor progress against set objectives;

(ii) reviewing the effectiveness of governance frameworks to set and oversee the internal control environment in relation to technology;

(iii) reviewing regional technology strategy, ensuring it is aligned with the adopted business strategies of the bank; and

(iv) overseeing and challenging management on execution of operational resilience objectives and deliverables.

Committee activities during 2021

Key matters considered by the Committee during the year included a review of IT and Cloud strategies, oversight of the bank's operating systems, operational resilience and technology infrastructure, including operational resilience of critical IT and other business services, information and cyber security risks, and major IT change programmes.

The Committee also reviewed and challenged management on the progress and associated risks with respect the transformation strategy, including transformation governance, cost complexity and key change programmes underway.

Operation of the Committee

The Committee has been established for an initial 12-month period from March 2021. The Board has recommended the continuation of the Committee for the duration of 2022.

The Committee held eight scheduled meetings during 2021.

The Chief Operating Officer, Chief Information Officer, Chief Risk Officer, Head of Internal Audit, and Head of Transformation are standing attendees and regularly attend Committee meetings to contribute their subject matter expertise and insight.

The current members are: Juliet Robinson (Chair), Mary Marsh, and Eric Strutz.

Nomination, Remuneration & Governance Committee

Key Responsibilities

The Nomination, Remuneration & Governance Committee has responsibility for:

(i) leading the process for Board appointments and for identifying and nominating, for the approval of the Board, candidates for appointment to the Board;

(ii) the endorsement of the appointment of individuals to certain Board and management positions at the bank's subsidiaries; including proposed fees payable to non-executive Directors on subsidiary boards;

(iii) reviewing the implementation and appropriateness of the Group's Director remuneration policy and the remuneration of the bank's senior executives, including the identification of the Material Risk Taker population for the purposes of the Capital Requirements Directive;

(iv) reviewing and developing the corporate governance framework on behalf of the Board and ensuring it is consistent

with best corporate governance standards and practices while remaining appropriate to the size, complexity and strategy of the bank; and

(v) overseeing the implementation and compliance with the HSBC Group Subsidiary Accountability Framework ('SAF').

Further information in relation to the HSBC's approach to remuneration for group employees is available in the Director's remuneration report on pages 276 - 278 of HSBC's Annual Report and Accounts available on https://www.hsbc.com/investors/results-and-announcements/annual-report.

Committee activities during 2021

Key matters considered by the Committee during the year included the appointment to the Board of new Directors, including an additional independent non-executive Director, as well as a number of senior positions within the bank's executive team, including the Chief Financial Officer.

The Committee undertook a full review of Board composition, succession planning for all material subsidiaries under SAF, approval of a revised Board Diversity Policy. The Committee applies the principles in the policy when considering the composition of the Board, including in relation to gender, ethnicity and age.

Other activities during the year included, the review of key remuneration matters for the bank and its subsidiaries in the context of the HSBC's remuneration framework, including variable and fixed pay allocations, aligned with the bank's risk appetite, and in keeping with the bank's strategy, culture and values, and long-term interests of the bank. The Committee reviewed the annual pay review outcomes across the region.

Operation of the Committee

The Committee held eight scheduled meetings during 2021, with additional meetings arranged to consider specific matters.

The Head of HR and Head of Performance & Reward attend Committee meetings on a regular basis to contribute their subject matter expertise and insight. Other senior executives attend periodically for specific items considered by the Committee.

The Committee comprises a majority of non-executive Directors. The current members are: Stephen O'Connor (Chair), Eric Strutz, Andrew Wright, and John Trueman (for Nomination and Governance matters only).

Executive Committee

The Executive Committee is a committee of the Board and has overall executive responsibility, under formal delegation, for the management and day-to-day running of the bank. The committee is accountable to the Board for overseeing the execution of the bank's strategy.

The purpose of the committee is to support the Chief Executive Officer of the bank in the performance of their duties and exercise of their powers, authorities and discretions in relation to the management of the bank and its subsidiaries. The committee meets on a regular basis and is chaired by the Chief Executive Officer.

During 2021, in addition to its day-to-day oversight of the bank's operations, the committee's principal areas of focus included managing the bank's response to the evolving nature of the Covid-19 pandemic across the region, oversight of the bank's transformation strategy, including the sale of the French retail banking operations, oversight of the performance across the bank's lines of business, review of the bank's financial performance. cost management, and preparing the bank's forward looking Financial Resource Plan. The committee also received updates on regulatory remediation programmes, regulatory engagement themes across the region and the transition to IBOR.

 
Dividends 
 

Information about dividends paid during the year is provided on page 17 of the Strategic Report and in Note 8 to the financial statements.

 
Internal control 
 

The Board is responsible for maintaining and reviewing the effectiveness of risk management and internal control systems and for determining the aggregate level and types of risks the bank is willing to take in achieving its strategic objectives.

To meet this requirement and to discharge its obligations under the FCA Handbook and the PRA Handbook, procedures have been designed for safeguarding assets against unauthorised use or disposal; for maintaining proper accounting records; and for ensuring the reliability and usefulness of financial information used within the business or for publication.

These procedures provide reasonable assurance against material misstatement, errors, losses or fraud. They are designed to provide effective internal control within the group and accord with the Financial Reporting Council's guidance for Directors issued in 2014, internal control and related financial and business reporting. The procedures have been in place throughout the year and up to 21 February 2022, the date of approval of this Annual Report and Accounts 2021.

The key risk management and internal control procedures include the following:

-- Global principles: The HSBC Group's Global Principles set an overarching standard for all other policies and procedures and are fundamental to the Group's risk management structure. They inform and connect our purpose, values, strategy and risk management principles, guiding us to do the right thing and treat our customers and our colleagues fairly at all times.

-- Risk management framework ('RMF'): The risk management framework supports our Global Principles. It outlines the key principles and practices that we employ in managing material risks. It applies to all categories of risk and supports a consistent approach in identifying, assessing, managing and reporting the risks we accept and incur in our activities.

-- Delegation of authority within limits set by the Board: Subject to certain matters reserved for the Board, the Chief Executive Officer has been delegated authority limits and powers within which to manage the day-to-day affairs of the group, including the right to sub-delegate those limits and powers. Each relevant executive has authority within which to manage the day-to-day affairs of the business or function for which he or she is accountable. Those individuals are required to maintain a clear and appropriate apportionment of significant responsibilities and to oversee the establishment and maintenance of systems of control that are appropriate to their business or function. Authorities to enter into credit and market risk exposures are delegated with limits to line management of group companies. However, credit proposals with specified higher-risk characteristics require the concurrence of the appropriate global function. Credit and market risks are measured and reported at subsidiary company level and aggregated for risk concentration analysis on a group-wide basis.

-- Risk identification and monitoring: Systems and procedures are in place to identify, assess, control and monitor the material risk types facing the group as set out in the RMF.The group's risk measurement and reporting systems are designed to help ensure that material risks are captured with all the attributes necessary to support well-founded decisions, that those attributes are accurately assessed and that information is delivered in a timely manner for those risks to be successfully managed and mitigated.

-- Changes in market conditions/practices: Processes are in place to identify new risks arising from changes in market conditions/practices or customer behaviours, which could expose the group to heightened risk of loss or reputational damage. The group employs a top and emerging risks framework, which contains an aggregate of all current and forward-looking risks and enables it to take action that either prevents them materialising or limits their impact.

-- During 2021, due to the prolonged impact of the Covid-19 pandemic on the global economy, banks continued to play an expanded role to support society and customers. The pandemic and its impact on the global economy have impacted many of our customers' business models and income, requiring significant levels of support from both governments and banks. To meet the additional challenges, we supplemented our existing approach to risk management with additional tools and practices and these continue to be in place. We continue our focus on the quality and timeliness of the data used to inform management decisions, through measures such as early warning indicators, prudent active risk management of our risk appetite, and ensuring regular communication with our Board and other key stakeholders

-- Responsibility for risk management: All employees are responsible for identifying and managing risk within the scope of their role as part of the three lines of defence model. This is an activity-based model to delineate management accountabilities and responsibilities for risk management and the control environment. The second line of defence sets the policy and guidelines for managing specific areas, provides advice and guidance in relation to the risk, and challenges the first line of defence (the risk owners) on effective risk management.

-- The Board has delegated to the Audit Committee oversight for the implementation of the group's policies and procedures for capturing and responding to whistleblower concerns, ensuring confidentiality, protection and fair treatment of whistleblowers, and receiving reports arising from the operation of those policies as well as ensuring arrangements are in place for independent investigation.

-- Strategic plans: Strategic plans are prepared for global businesses, global functions and geographical regions within the framework of the HSBC Group's overall strategy. The bank also prepares and adopts a Financial Resourcing Plan, which is informed by detailed analysis of risk appetite, describing the types and quantum of risk that the bank is prepared to take in executing its strategy and sets out the key business initiatives and the likely financial effects of those initiatives.

-- The effectiveness of the group's system of risk management and internal control is reviewed regularly by the Board, the Risk Committee and the Audit Committee.

-- During 2021, the group continued to focus on operational resilience and invest in the non-financial risk infrastructure. There was a particular focus on material and emerging risks with significant progress made enhancing the end-to-end risk and control assessment process. The Risk Committee, supported by the TRT, and the Audit Committee received confirmation that executive management has taken or is taking the necessary actions to remedy any failings or weaknesses identified through the operation of the group's framework of controls. In response to the prolonged Covid-19 pandemic, our business continuity responses have been successfully implemented and the majority of service level agreements continue to be maintained.

Internal control over financial reporting

The key risk management and internal control procedures over financial reporting include the following:

-- Entity level controls: The primary mechanism through which comfort over risk management and internal control systems is achieved, is through assessments of the effectiveness of entity level controls ('ELCs'), and the reporting of risk and control issues on a regular basis through the various risk management and risk governance forums. ELCs are internal controls that have a pervasive influence over the entity as a whole. They include controls related to the control environment, for example the bank's values and ethics, the promotion of effective risk management and the overarching governance exercised by the Board and its non-executive committees. The design and operational effectiveness of ELCs are assessed annually as part of the assessment of the effectiveness of internal controls over financial reporting.

-- Process level transactional controls: Key process level controls that mitigate risk of financial mis-statement are identified, recorded and monitored in accordance with the risk framework. This includes the identification and assessment of relevant control issues against which action plans are tracked through to remediation. Further details on the group's approach to risk management can be found on page 21. The Audit Committee has continued to receive regular updates on HSBC's ongoing activities for improving the effective oversight of end-to-end business processes and management continues to identify opportunities for enhancing key controls, such as through the use of automation technologies.

-- External Reporting Forum: The External Reporting Forum reviews financial reporting disclosures made by the bank for any material errors, mis-statements or omissions. The integrity of disclosures is underpinned by structures and processes within the group's Finance and Risk functions that support rigorous analytical review of financial reporting and the maintenance of proper accounting records.

-- Disclosure Committee: The Disclosure Committee considers the external reporting obligations of the bank to ensure compliance with reporting obligations under the EU Market Abuse Regulations.

-- Financial reporting: The group's financial reporting process is controlled using documented accounting policies and reporting formats, supported by detailed instructions and guidance on reporting requirements, issued to all reporting entities within the group in advance of each reporting period end. The submission of financial information from each reporting entity is supported by a certification by the responsible financial officer and analytical review procedures at subsidiary and group levels.

-- Subsidiary certifications: Certifications are provided to the Audit Committee and the Risk Committees (full and half yearly) and to the Nomination, Remuneration and Governance Committee (annually) from the audit, risk and remuneration committees of key material subsidiary companies confirming amongst other things that:

- Audit - the financial statements of the subsidiary have been prepared in accordance with group policies, present fairly the state of affairs of the subsidiary and are prepared on a going concern basis;

- Risk - the Risk Committee of the subsidiary has carried out its oversight activities consistent with and in alignment to the RMF; and

- Remuneration - the Remuneration Committee of the subsidiary has discharged its obligations in overseeing the implementation and operation of HSBC's Group Remuneration Policy.

 
Employees 
 

Health and safety

We are committed to providing a safe and healthy working environment for everyone. We have adopted global policies, mandatory procedures, and incident and information reporting systems across the organisation that reflect our core values and are aligned to international standards. Our global health and safety performance is subject to ongoing monitoring and assurance.

Our Chief Operating Officers have overall responsibility for engendering a positive health and safety culture and ensuring that global policies, procedures and systems are put into practice locally. They also have responsibility for ensuring all local legal requirements are met.

We delivered a range of programmes in 2021 to help us understand and manage our health and safety risks:

-- We continued to provide enhancements to our workplaces globally to minimise the risks of Covid-19, including enhancing cleaning, improved ventilation and social distancing measures

-- We updated our advice and risk assessment methodology on working from home, providing more awareness and best practices on good ergonomics and wellbeing to be adopted as we transitioned to new ways of working

-- We delivered health and safety training and awareness to 49,000 employees and contractors ensuring roles and responsibilities were clear and understood

-- We completed the annual safety inspection on all of our buildings globally, subject to local Covid-19 restrictions, to ensure we were meeting our standards and continuously improving our safety performance

-- We continued to focus on enhancing the safety culture in our supply chain through our SAFER Together programme, covering the five key elements of best practice safety culture, including speaking up about safety, and recognising excellence

-- Our 2021 safety climate survey results showed a continued high level of positive safety culture, significantly above the industry average

-- Our Eat Well Live Well programme continued educating and informing our colleagues on how to make healthy food and drink choices. We enhanced the programme to provide digital educational and information resources, including a suite of videos and recipe ideas. The programme was a key component of HSBC's winning entry in the 2021 Global Healthy Workplace Awards

 
Employee health and safety 
                                    2021            2020            2019 
Number of workplace                    -               -               - 
 fatalities 
------------------------- 
Number of major injuries 
 to employees(1)                       2               2               3 
-------------------------                 -------------- 
All injury rate per 
 100,000 employees                    14              35             130 
-------------------------                 -------------- 
 
   1   Fractures, dislocation, concussion, hospitalisation, unconsciousness. 

1

Diversity and Inclusion

Our employees and the societies they represent and serve span many cultures, communities and continents. We believe this diversity makes us stronger, and we are dedicated to building a diverse and connected workforce where everyone feels a sense of belonging. In Europe, we have carried out actions to drive improvements in representation and sentiment across multiple diversity strands, strengthen our employee networks, and improve our diversity data.

We set up a HBEU Diversity and Inclusion Council, including several members from the European Executive Committee in order to reinforce our commitments, engage more closely with our Employee Resources Groups and track our progress.

Throughout the year, more than thirty events and conferences were organised across several European countries on topics such as inclusive leadership, disability, parenthood, resilience, mental health, hypersensitivity, women in leadership, cross-generation, multicultural working environment.

Exchange meetings to discuss key diversity topics including ethnicity and multiculturalism took place in several countries e.g. Germany, Malta, Italy and France.

We actively participated in the #24 hours of Pride through virtual events and building lightening in the UK, Poland, Malta, Luxembourg, France, Channel Islands, Ireland and Italy

We continued to increase Employee Resources Groups (ERG) representation across Europe. In 2021, we launched a new Pan-European ERG called 'Inclusive Europe' aiming to create an inclusive culture, reinforce collaboration between existing ERGs. Our Pride ERGs in countries have gathered to create a European structure. A new 'EmbRace' ERG has been launched in Ireland to promote ethnic diversity and an ERG to support people with disabilities has also been set up in France.

All our ERGs are actively involved in supporting employees locally. Balance, our ERG dedicated to gender diversity, have run a programme (e-Taste of the Top) to give exposure to 27 female talent allowing them to cover a week of leave for very senior positions. A new initiative, Coaching Circles, has been launched to create a peer to peer coaching culture. This is available to all employees.

In 2021, we updated our recruitment training to emphasise the need for inclusivity, and made this mandatory for all hiring managers. We also ran sessions for leadership teams on 'Unconcious Bias' to raise awareness of affinity bias amongst others. In the UK, acknowledging the previous under representation of Black and Ethnic Minority talent on our development programmes and introducing leadership development specifically for talented individuals in this group. In 2021, 189 colleagues at GCB 4 (mid manager) took part in our ethnic minority Accelerate into Leadership programme and, to date, 15% of participants have progressed in their career.

In France, HSBC has signed a charter along with other large financial companies in order to significantly improve female representation.

Gender diversity statistics HSBC Bank plc's overall female representation is improving and we are committed to building a strong pipeline of female talent to improve gender balance in senior leadership across Europe. Our target was 24.3% of women in senior leadership (Global Career Band 0-3) roles by the end of 2021. The outcome for 2021 was 24% of women in senior leadership roles.

Female representation by management level:

All grades - 52.2%

GCB 6-8 Clerical grades - 65.8%

GCB 4-5 Management - 43.6%

GCB 0-3 Senior management - 24%

HBEU Executive Committee - 29.4%

Employment of people with a disability

We strongly believe in providing equal opportunities for all employees. The employment of people with a disability is included in this commitment. The recruitment, training, development and promotion of people with a disability are based on the aptitudes and abilities of the individual. Should employees become disabled during their employments with us, efforts are made to continue their employment. Where necessary, we will provide appropriate training, facilities and reasonable equipment. A number of countries have dedicated teams to ensure that barriers to work are removed for colleagues.

Continuous work is done to ensure individual support is provided to make home office adjustments. Learning and talent development

The development of our people continues to be of critical importance to our organisations success as we develop and implement practices that identifies talent, and builds broad employee capability, together with the right values, skills and experience to meet the future needs of our business. This applies across all levels of our business including the launch of our new General Manager Curriculum in 2021 which will be followed with the launch of a new learning curriculum for our Managing Directors in 2022.

With the launch of our new Learning Experience Platform - Degreed, we continue to make progress in the move to a modern learning culture where, 'on demand' resources are available for our learners to access as the need arises, driving a departure from 'done to', mandatory learning and moving to a self-driven learner-led culture. We commit to continually providing opportunities for our colleagues to develop skills and capability that empower them to realise their potential for the future.

HSBC University remains the hub for dedicated HSBC learning and during the year the offering was extended to provided targeted guidance and development to help colleagues navigate through hybrid working patterns and broader Future of Work topics. This sits within the broader offering of HSBC Leadership, risk management, strategy and performance, as well as business-specific technical training all with virtual online formats.

Employee relations

We consult with and, where appropriate, negotiate with employee representative bodies where we have them. We also aim to maintain well-developed communications and consultation programmes with all employee representative bodies and there have been no material disruptions to our operations from labour disputes during the past five years.

 
Disclosure of information to auditors 
 

The directors are not aware that there is any relevant audit information (as defined in the Companies Act 2006) of which the bank's auditors are unaware and processes are in place to ensure that the bank's auditors are aware of any relevant audit information.

 
Auditors 
 

PricewaterhouseCoopers LLP ('PwC') are the external auditors to the bank. PwC has expressed its willingness to continue in office and the Board recommends that PwC be re-appointed as the bank's auditors. A resolution proposing the re-appointment of PwC as the bank's auditors, and giving authority to the Audit Committee to determine its remuneration, will be submitted to the forthcoming AGM.

 
Branches 
 

HSBC Bank plc provides a wide range of banking and financial services through 20 markets. HSBC Bank plc is simplifying its operating model to one integrated business supporting a wholesale banking hub for the European Union ('EU') in Paris and a wholesale banking hub for western markets in London. Further information on the bank's branches are located in 'HSBC in Europe' on page 4.

Disclosures required pursuant to the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 as updated by Companies (Miscellaneous Reporting) Regulations 2018 can be found on the following pages:

 
Engagement with employees 
 (Sch.7 Para 11 and 11A 2008/2018  Pages 9 
 Regs), s172 Statement)             and 10 
Engagement with suppliers, 
 customers and others in 
 a business relationship 
 with the bank (Sch.7 Para 
 11B 2008 Regs)                    Page 9 
Policy concerning the employment 
 of disabled persons (Sch.7 
 Para 10 2008 Regs)                Page 95 
Financial Instruments (Sch.7       Pages 32 
 Para 6 2008 Regs)                  to 70 
                                   Note 14, 
Hedge accounting policy             Pages 150 
 (Sch.7 Para 6 2008 Regs)           to 154 
 
 
Articles of Association, Conflicts 
 of interest 
 and indemnification of Directors 
 

The bank's Articles of Association gives the Board authority to approve Directors' conflicts and potential conflicts of interest. The Board has adopted policies and procedures for the approval of Directors' conflicts or potential conflicts of interest. On appointment, new Directors are advised of the process for dealing with conflicts and a review of those conflicts that have been authorised, and the terms of those authorisations, is routinely undertaken by the Board.

The Articles of Association of the bank contain a qualifying third-party indemnity provision, which entitles Directors and other

officers to be indemnified out of the assets of the bank against claims from third parties in respect of certain liabilities. HSBC Group has granted, by way of deed poll, indemnities to the Directors, including former Directors who retired during the year, against certain liabilities arising in connection with their position as a Director of or of any Group company, including the bank and its subsidiaries. Directors are indemnified to the maximum extent permitted by law.

The indemnities that constitute a 'qualifying third-party indemnity provision', as defined by section 234 of the Companies Act 2006, remained in force for the whole of the financial year (or, in the case of Directors appointed during 2020, from the date of their appointment). The deed poll is available for inspection at the registered office of HSBC Holdings.

Additionally, Directors have the benefit of Directors' and Officers' liability insurance. Qualifying pension scheme indemnities have also been granted to the Trustees of the Group's pension schemes, which were in force for the whole of the financial year and remain in force as at the date of this report.

 
Research and Development 
 

In the ordinary course, the lines of business develop new products and services.

 
Events after the Balance Sheet Date 
 

In its assessment of events after the balance sheet date, the group has considered and concluded that there are no events requiring adjustment or disclosures in the financial statements.

 
Statement on going concern 
 

The Directors consider it appropriate to prepare the financial statements on the going concern basis. In making their going concern assessment, the Directors have considered a wide range of detailed information relating to present and potential conditions, including profitability, cash flows, capital requirements and capital resources.

Further information relevant to the assessment is provided in the Strategic Report and the Report of the Directors, in particular:

   --    a description of the group's strategic direction; 
   --    a summary of the group's financial performance and a review of performance by business; 
   --    the group's approach to capital management and its capital position; and 

-- the top and emerging risks facing the group, as appraised by the Directors, along with details of the group's approach to mitigating those risks and its approach to risk management in general.

In addition, the objectives, policies and processes for managing credit, liquidity and market risk are set out in the 'Report of the Directors: Risk'.

The Report of the Directors comprising pages 21 to 98 was approved by the Board on 21 February 2022 and is signed on its behalf by.

By order of the Board

Dave Watts

Director

HSBC Bank plc

21 February 2022

Registered number 00014259

 
Statement of directors' responsibilities in respect of the financial 
 statements 
 

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

Company law requires the directors to prepare financial statements for each financial year. Under that law the directors have prepared the group and the company financial statements in accordance with UK-adopted accounting standards, and have also applied international financial reporting standards ('IFRSs') adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union. These financial statements are also prepared in accordance with IFRSs as issued by the International Accounting Standards Board (IASB), including interpretations issued by the IFRS Interpretations Committee, as there are no applicable differences from IFRSs as issued by the IASB for the periods presented.

Under company law, 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 company and of the profit or loss of the group for that period. In preparing the financial statements, the directors are required to:

   --    select suitable accounting policies and then apply them consistently; 

-- state whether UK-adopted accounting standards, IFRSs adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union and IFRSs as issued by the International Accounting Standards Board ('IASB'), including interpretations issued by the IFRS Interpretations Committee, have been followed, subject to any material departures disclosed and explained in the financial statements;

   --    make judgements and accounting estimates that are reasonable and prudent; and 

-- prepare the financial statements on the going concern basis unless it is inappropriate to presume that the group and company will continue in business.

The directors are responsible for safeguarding the assets of the group and company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.

The directors are also responsible for keeping adequate accounting records that are sufficient to show and explain the group's and company's transactions and disclose with reasonable accuracy at any time the financial position of the group and company and enable them to ensure that the financial statements comply with the Companies Act 2006.

The directors are responsible for the maintenance and integrity of the company's website. Legislation in the United Kingdom governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.

Directors' confirmations

The directors consider that the Annual Report and accounts, taken as a whole, is fair, balanced and understandable and provides the information necessary for shareholders to assess the group's and company's position and performance, business model and strategy.

Each of the directors, whose names and functions are listed in the Corporate Governance Report confirm that, to the best of their knowledge:

-- the group and company financial statements, which have been prepared in accordance with UK-adopted accounting standards, IFRSs adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union and IFRSs as issued by the International Accounting Standards Board ('IASB'), including interpretations issued by the IFRS Interpretations Committee, give a true and fair view of the assets, liabilities and financial position of the group and company, and of the profit of the group; and

-- the Strategic Report includes a fair review of the development and performance of the business and the position of the group and company, together with a description of the principal risks and uncertainties that it faces.

On behalf of the Board

Dave Watts

Director

HSBC Bank plc

21 February 2022

Registered number 00014259

 
Independent auditors' report to the members of HSBC Bank plc 
 
 
Report on the audit of the financial statements 
 

Opinion

In our opinion, HSBC Bank plc's group financial statements and company financial statements (the 'financial statements'):

-- give a true and fair view of the state of the group's and of the company's affairs as at 31 December 2021 and of the group's profit and the group's and company's cash flows for the year then ended;

-- have been properly prepared in accordance with UK-adopted international accounting standards; and

   --    have been prepared in accordance with the requirements of the Companies Act 2006. 

We have audited the financial statements, included within the HSBC Bank plc Annual Report and Accounts 2021 (the 'Annual Report'), which comprise:

   --    the consolidated balance sheet as at 31 December 2021; 

-- the consolidated income statement and consolidated statement of comprehensive income for the year then ended;

   --    the consolidated statement of cash flows for the year then ended; 
   --    the consolidated statement of changes in equity for the year then ended; 
   --    the HSBC Bank plc balance sheet as at 31 December 2021; 
   --    the HSBC Bank plc statement of cash flows for the year then ended; 
   --    the HSBC Bank plc statement of changes in equity for the year then ended; and 

-- the notes on the financial statements, which include a description of the significant accounting policies.

Our opinion is consistent with our reporting to the Audit Committee.

Separate opinion in relation to international financial reporting standards adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union

As explained in note 1.1(a) to the financial statements, the group, in addition to applying UK-adopted international accounting standards, has also applied international financial reporting standards adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union.

In our opinion, 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.

Separate opinion in relation to IFRSs as issued by the IASB

As explained in note 1.1(a) to the financial statements, the group, in addition to applying UK-adopted international accounting standards, has also applied international financial reporting standards ('IFRSs') as issued by the International Accounting Standards Board ('IASB').

In our opinion, the group financial statements have been properly prepared in accordance with IFRSs as issued by the IASB.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) ('ISAs (UK)') and applicable law. Our responsibilities under ISAs (UK) are further described in the Auditors' 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.

Independence

We remained independent of the group in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, which includes the FRC's Ethical Standard, as applicable to listed public interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements.

To the best of our knowledge and belief, we declare that non-audit services prohibited by the FRC's Ethical Standard were not provided.

Other than those disclosed in note 6, we have provided no non-audit services to the company or its controlled undertakings in the period under audit.

Our audit approach

Overview

Audit scope

We performed audits of the complete financial information of two components, namely the UK non-ring-fenced bank and HSBC Continental Europe (HBCE).

For five further components, specific audit procedures were performed over selected significant account balances and financial statement note disclosures.

Key audit matters

   --    Expected credit losses ('ECL') impairment of loans and advances (group and company) 
   --    Valuation of financial instruments (group and company) 
   --    Recognition of deferred tax assets (group); and 
   --    Impairment of investment in subsidiaries (company). 

Materiality

-- Overall group materiality: GBP218 million (2020: GBP222 million) based on 1% of Tier 1 capital.

-- Overall company materiality: GBP140 million (2020: GBP142 million) based on 1% of Tier 1 capital.

-- Performance materiality: GBP164 million (2020: GBP166 million) (group) and GBP105 million (2020: GBP106 million) (company).

The scope of our audit

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

Key audit matters

Key audit matters are those matters that, in the auditors' professional judgement, were of most significance in the audit of the financial statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to fraud) identified by the auditors, including those which had the greatest effect on: the overall audit strategy; the allocation of resources in the audit; and directing the efforts of the engagement team. These matters, and any comments we make on the results of our procedures thereon, were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. This is not a complete list of all risks identified by our audit. Compared to last year the number of key audit matters has reduced from six to four. The following are no longer considered to be key audit matters.

-- Impact of Covid-19 (group and company) - Given the impact of Covid-19 on working practices and international travel, the majority of our interactions continued to be undertaken virtually, including those with the partners and teams for component audit teams, and with Board members and management. Similarly, a substantial part of our audit testing was performed remotely. We have established practices throughout 2021 for interacting and undertaking our audit testing virtually, consistent with the hybrid working models at both PwC and HSBC.

-- The present value of in-force long-term insurance contracts ('PVIF') asset (group) - The risk is reduced due to a reduction in the materiality of changes to judgemental assumptions resulting in lower estimation uncertainty.

-- Information Technology ('IT') Access Management (group and company) - Management has remediated a number of the control deficiencies in relation to IT access management.

Recognition of deferred tax assets (group) is a new key audit matter this year. The remaining three key audit matters are consistent with last year.

Expected credit losses - Impairment of loans and advances (group and company)

 
 
Determining expected credit losses ('ECL') involves management judgement 
 and is subject to a high degree of estimation uncertainty. Management 
 makes various assumptions when estimating ECL. The significant assumptions 
 that we focus on in our audit included those with greater levels of 
 management judgement and for which variations had the most significant 
 impact on ECL. These included assumptions made in determining the following: 
  *    forward looking economic scenarios and their 
       probability weightings for the wholesale portfolios; 
 
 
  *    material management judgemental adjustments; 
 
 
  *    wholesale customer risk ratings ('CRRs'); and 
 
 
  *    estimating expected cash flows and collateral 
       valuations for credit impaired wholesale exposures. 
 
 
 The impact of Covid-19, including the nature and extent of government 
 support, and more recent factors, including supply chain constraints 
 and increasing energy prices, have resulted in unprecedented economic 
 conditions that vary between territories and industries, leading to 
 uncertainty around judgements made in determining the severity and 
 probability weighting of macroeconomic variable ('MEV') forecasts across 
 the different economic scenarios used in ECL models. 
 The modelling methodologies used to estimate ECL are developed using 
 historical experience. The impact of the unprecedented economic conditions 
 has resulted in certain limitations in the reliability of these methodologies 
 to forecast the extent and timing of future customer defaults and therefore 
 estimate ECL. In addition, modelling methodologies do not incorporate 
 all factors that are relevant to estimating ECL, such as differentiating 
 the impact on industry sectors of economic conditions. These limitations 
 are addressed with management adjustments, the measurement of which 
 is inherently judgemental and subject to a high level of estimation 
 uncertainty. Management makes other assumptions which are less judgemental 
 or for which variations have a less significant impact on ECL. These 
 assumptions include: 
  *    Model methodologies themselves; and 
 
 
  *    Quantitative and qualitative criteria used to assess 
       significant increases in credit risk. 
 
 
 
We held discussions with the Audit Committee covering governance and 
 controls over ECL, with a significant focus on judgemental adjustments. 
 We also discussed a number of other areas, including: 
  *    the severity of MEV forecasts in economics scenarios 
       and their related probability weightings; 
 
 
  *    management judgemental adjustments and the nature and 
       extent of analysis used to support those adjustments; 
 
 
  *    the criteria and conditions used to assess to what 
       extent management judgemental adjustments continue to 
       be needed; and 
 
 
  *    management's policies, governance and controls over 
       model validation and monitoring. 
 
 
 
We assessed the design and effectiveness of governance and controls 
 over the estimation of ECLs. We observed management's review and challenge 
 governance forums for (1) the determination of MEV forecasts and their 
 probability weightings for different economic scenarios, and (2) the 
 assessment of ECL for Wholesale portfolios, including the assessment 
 of model limitations and approval of any resulting adjustments to modelled 
 outcomes. 
 We also tested controls over: 
  *    model validation and monitoring; 
 
 
  *    credit reviews that determine CRRs for wholesale 
       customers; 
 
 
  *    the identification of credit impaired events; 
 
 
  *    the input of critical data into source systems and 
       the flow and transformation of critical data from 
       source systems to the impairment models; and 
 
 
  *    the calculation and approval of management 
       judgemental adjustments to modelled outcomes. 
 
 
 We involved our economic experts to assist in assessing the reasonableness 
 of the severity and probability weighting of MEV forecasts. These assessments 
 considered the sensitivity of ECLs to variations in the severity and 
 probability weighting of MEVs for different economic scenarios. We 
 involved our modelling experts in assessing the appropriateness of 
 the significant assumptions and methodologies used for models and management 
 judgemental adjustments. We independently reperformed the calculations 
 for a sample of those models and management judgemental adjustments. 
 We further considered whether the judgements made in selecting the 
 significant assumptions would give rise to indicators of possible management 
 bias. 
 In addition, we performed substantive testing over: 
  *    the compliance of ECL methodologies and assumptions 
       with the requirements of IFRS 9; 
 
 
  *    the appropriateness and application of the 
       quantitative and qualitative criteria used to assess 
       significant increases in credit risk; 
 
 
  *    a sample of critical data used in the year end ECL 
       calculation and to estimate management judgemental 
       adjustments as at 31 December 2021; 
 
 
  *    assumptions and critical data for a sample of credit 
       impaired wholesale exposures; and 
 
 
  *    a sample of CRRs applied to wholesale exposures. 
 
 
 We evaluated and tested the Credit Risk disclosures made in the financial 
 statements. 
 
 
 
 
  *    Credit risk, page 32. 
 
 
  *    Audit Committee, page 90. 
 
 
  *    Note 1.2(i) Impairment of amortised cost and FVOCI 
       financial assets, page 122 
 

Valuation of financial instruments (group and company)

 
 
The financial instruments held by the group range from those that are 
 traded daily on active markets with quoted prices, to more complex 
 and bespoke positions. The valuation of these financial instruments 
 can require the use of complex valuation models and/or prices or inputs 
 which are not readily observable in the market. 
 Where significant pricing inputs are unobservable, the financial instruments 
 are classified as Level 3 (L3), per the IFRS 13 fair value hierarchy. 
 Determining unobservable inputs in fair value measurement involves 
 management judgement and is subject to a high degree of estimation 
 uncertainty. There is also a risk that certain L3 portfolios are not 
 valued appropriately due to the complexity of the trades, specifically 
 where valuation modelling techniques result in significant limitations 
 or where there is greater uncertainty around the choice of an appropriate 
 pricing methodology. 
 Valuation of the L3 asset backed securities held by the Markets & Securities 
 Services business have a significant risk attached to the valuation 
 methodology due to the complexity of the valuation models and lack 
 of observable pricing inputs. 
 The own credit spread (OCS) adjustment for issued debt instruments 
 held at fair value also forms part of our significant risk due to its 
 underlying modelling complexity as well as unobservability of the inputs. 
 
 
 
We discussed with the Audit Committee the results of our review of 
 fair valuation adjustment methodology and the results of our substantive 
 testing which included independent revaluation of a range of financial 
 instruments, including a sample of Level 3 positions. 
 
 
 
For fair values based on complex valuation models and significant unobservable 
 inputs, specifically asset backed securities and issued debt instruments 
 held at fair value, we performed the following: 
  *    Tested the design and operating effectiveness of key 
       controls supporting the identification and 
       measurement of the valuation of financial instruments, 
       including the independent price verification process. 
 
 
  *    Engaged our valuation experts to perform independent 
       revaluation of a sample of trades to determine if 
       management's estimates fell within a reasonable 
       range. 
 
 
 For OCS, we engaged our valuation experts to assess the methodology 
 and underlying assumptions and compare with our knowledge of current 
 industry practice. Controls over the calculation of these adjustments 
 were also tested. 
 We also evaluated the adequacy and extent of disclosures made in the 
 financial statements in relation to valuation of L3 financial instruments. 
 
 
 
 
  *    Audit Committee, page 90. 
 
 
  *    Note 1.2(c) Valuation of financial instruments, page 
       120 
 
 
  *    Note 11: Fair values of financial instruments carried 
       at fair value, page 140 
 

Recognition of deferred tax assets (group)

 
 
Recognition of deferred tax assets ('DTAs') relies on an assessment 
 of the availability of future taxable profits against which to recognise 
 accumulated tax losses. 
 An assessment of the recoverability of deferred tax assets was performed 
 and deferred tax assets of GBP555m have been recorded in HSBC Continental 
 Europe ('HBCE') of which GBP261m relates to deductible temporary differences 
 and GBP294m relates to brought forward tax losses. 
 As at 31 December 2021, HBCE had accumulated tax losses of GBP496m, 
 of which GBP380m arose during 2021. Losses generated in 2019 and 2020 
 had not previously been recognised on the balance sheet as DTAs given 
 the history of HBCE taxable losses in those years. Management judgement 
 is required when assessing whether there is convincing other evidence 
 of future taxable profits, including over assumptions regarding the 
 forecast cash flows and determination of risk adjustments to such cash 
 flows and with regard to the timing of the reversal of temporary differences. 
 Management's assessment required consideration of the impact of the 
 disposal of the French retail business, including the impact that business, 
 and other one off restructuring costs, have had on historical taxable 
 profitability as well as the impact on future taxable profits across 
 a number of scenarios. Significant management judgements and assumptions 
 have been required in determining the quantum and probability of future 
 taxable profits. 
 
 
 
We discussed with the Audit Committee our risk assessment with respect 
 to DTA recognition. We held discussions with the Audit Committee covering 
 controls over DTA and we also discussed the results of our challenge 
 of the key judgements and estimates being made with regard to deferred 
 tax. 
 
 
 
 
  *    We tested the design and operating effectiveness of 
       controls over deferred tax asset recognition. 
 
 
  *    With the support of our tax specialists we assessed 
       the viability of management's strategy to recover 
       deferred tax assets. 
 
 
  *    We tested key inputs into the deferred tax 
       recognition model, including forecast cash flows to 
       approved plans and consistency with other judgements. 
 
 
  *    We challenged management on their methodology and 
       underlying assumptions in arriving at their 
       judgements, including in relation to availability of 
       convincing other evidence of future taxable profits 
       and determination of risk adjustments applied to 
       those forecast taxable profits. 
 
 
  *    In assessing these judgements we considered the 
       historic taxable profits and losses and the evidence 
       provided to support the judgement that the criteria 
       for recognition had been reached. We challenged the 
       achievability of management's forecast taxable 
       profits and assumptions made over the future reversal 
       of deferred tax assets and liabilities and reviewed 
       management's stress and scenario analyses over the 
       likelihood of future taxable profits. 
 
 
 We evaluated and tested the disclosures made in the financial statements 
 in relation to deferred tax. 
 
 
 
 
  *    Audit Committee Report, page 90. 
 
 
  *    Note 1.2(l) Tax, page 126 
 
 
  *    Note 7: Tax, page 135 
 

Impairment of investment in subsidiaries (company)

 
 
An annual impairment indicators assessment is performed for each of 
 the company's investments in subsidiaries. The sale of the retail banking 
 business in France, for which a framework agreement was signed in November 
 2021, and the ongoing restructuring within the company's largest subsidiary, 
 HSBC Continental Europe ('HBCE'), is considered by management to be 
 an indicator of impairment. 
 An impairment test was performed for the company's investment in HBCE 
 using a value in use ('VIU') model to estimate the recoverable amount. 
 The recoverable amount was higher than the carrying value for this 
 investment and therefore no impairment was recorded. The investment 
 in HBCE amounts to GBP4.3bn as at 31 December 2021. 
 The methodology in the VIU model is dependent on various assumptions, 
 both short term and long term in nature. These assumptions, which are 
 subject to estimation uncertainty, are derived from a combination of 
 management's judgement, experts engaged by management and market data. 
 The significant assumptions that we focused our audit on were those 
 with greater levels of management judgement and for which variations 
 had the most significant impact on the recoverable amount. Specifically, 
 these included forecast cash flows for 2022 to 2026, capital requirements, 
 long term growth rates and discount rates. 
 
 
 
We discussed the appropriateness of methodologies used and significant 
 assumptions with the Audit Committee, giving consideration to the group's 
 strategy. We discussed the sensitivity of the impairment assessment 
 to the key assumptions, in particular the forecast cash flows and the 
 discount rate. We also discussed the disclosures made in relation to 
 investment in subsidiaries, including the use of sensitivity analysis 
 to explain estimation uncertainty and the conditions that would result 
 in an impairment being recognised. 
 
 
 
We tested the control in place over the forecasted cash flow assumptions 
 used to determine the recoverable amounts. We assessed the appropriateness 
 of the methodology used, and the mathematical accuracy of the calculations, 
 to estimate the recoverable amounts. In respect of the significant 
 assumptions, our testing included the following: 
  *    Challenging the achievability of management's 
       forecast cash flows; 
 
 
  *    Obtaining and evaluating evidence where available for 
       critical data relating to significant assumptions, 
       from a combination of historic experience and 
       external market and other group financial 
       information; 
 
 
  *    Assessing whether the cash flows included in the 
       model were in accordance with the relevant accounting 
       standard; 
 
 
  *    Assessing the sensitivity of the VIU to reasonable 
       variations in significant assumptions, both 
       individually and in aggregate; and 
 
 
  *    Determining a reasonable range for the discount rate 
       used within the model, with the assistance of our 
       valuation experts, and comparing it to the discount 
       rate used by management. 
 
 
 We evaluated and tested the disclosures made in the financial statements 
 in relation to investment in subsidiaries. 
 
 
 
 
  *    Audit Committee Report, page 90. 
 
 
  *    Note 1.2(a) Consolidation and related policies, page 
       119 
 
 
  *    Note 18: Investment in subsidiaries, page 156 
 

How we tailored the audit scope

We performed a risk assessment, giving consideration to relevant external and internal factors, including Covid-19, climate change, geopolitical and economic risks, relevant accounting and regulatory developments, the group's strategy and the changes taking place across the group. We also considered our knowledge and experience obtained in prior year audits. As part of considering the impact of climate change in our risk assessment, we evaluated management's assessment of the impact of climate risk including their conclusion that there is no material impact on the financial statements. In particular, we considered management's assessment of the impact on ECL on loans and advances, the financial statement line item we determined to be most likely to be impacted by climate risk. Management's assessment gave consideration to a number of matters, including the HSBC Holdings plc climate stress testing performed in 2021.

Using our risk assessment, we tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the financial statements as a whole, taking into account the structure of the group and the company, the accounting processes and controls, and the industry in which they operate.

HSBC Bank plc is structured into five divisions being Markets & Securities Services, Global Banking, GBM Other, Commercial Banking and Wealth and Personal Banking, which are supported by a Corporate Centre. The divisions operate across a number of operations, subsidiary entities and branches ('components') throughout Europe. Within the group's main consolidation and financial reporting system, the consolidated financial statements are an aggregation of the components. Each component submits their financial information to the group in the form of a consolidation pack.

In establishing the overall approach to the group and company audit, we scoped using the balances included in the consolidation pack. We determined the type of work that needed to be performed over the components by us, as the group engagement team, or auditors within PwC UK and from other PwC network firms operating under our instruction ('component auditors').

As a result of our scoping, for the group we determined that audits of the complete financial information of the UK non-ring-fenced bank ('UK NRFB') and HSBC Continental Europe (HBCE) were necessary, owing to their financial significance. We instructed component auditors, PwC UK and PwC France to perform the audits of these components. Our interactions with component auditors included regular communication throughout the audit, including the issuance of instructions, a review of working papers relating to the key audit matters and formal clearance meetings. The group audit engagement partner was also the partner on the audit of the UK NRFB significant component.

We then considered the significance of other components in relation to primary statement account balances and note disclosures. In doing this we also considered the presence of any significant audit risks and other qualitative factors (including history of misstatements through fraud or error). For five components, specific audit procedures were performed over selected significant account balances. For the remainder, the risk of material misstatement was mitigated through group audit procedures including testing of entity level controls and group and company level analytical review procedures.

Certain group-level account balances were audited by the group engagement team.

Materiality

The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for materiality. These, together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit procedures on the individual financial statement line items and disclosures and in evaluating the effect of misstatements, both individually and in aggregate on the financial statements as a whole.

Based on our professional judgement, we determined materiality for the financial statements as a whole as follows:

 
                         Financial statements - group      Financial statements - company 
Overall materiality      GBP218 million (2020: GBP222      GBP140 million (2020: GBP142 
                          million).                         million). 
How we determined        1% of Tier 1 capital.             1% of Tier 1 capital. 
 it 
Rationale for benchmark  Tier 1 capital is used as         Tier 1 capital is used as 
 applied                  a benchmark as it is considered   a benchmark as it is considered 
                          to be a key driver of HSBC        to be a key driver of HSBC 
                          Bank plc's decision making        Bank plc's decision making 
                          process and has been a primary    process and has been a primary 
                          focus for regulators.             focus for regulators. 
 

Tier 1 capital was also used as the benchmark in the prior year. The basis for determining materiality was re-evaluated and we considered other benchmarks, such as profit before tax. Tier 1 capital is a common benchmark for wholly owned banking subsidiaries, because of the focus on financial stability. Tier 1 capital was determined to continue to be an appropriate benchmark given the importance of this metric to the HSBC Bank plc decision making process and to principal users of the financial statements, including the ultimate holding company HSBC Holdings plc.

For each component in the scope of our group audit, we allocated a materiality that is less than our overall group materiality. The range of materiality allocated across components was GBP9 million to GBP130 million. Certain components were audited to a local statutory audit materiality that was also less than our overall group materiality.

We use performance materiality to reduce to an appropriately low level the probability that the aggregate of uncorrected and undetected misstatements exceeds overall materiality. Specifically, we use performance materiality in determining the scope of our audit and the nature and extent of our testing of account balances, classes of transactions and disclosures, for example in determining sample sizes. Our performance materiality was 75% (2020: 75%) of overall materiality, amounting to GBP164 million (2020: GBP166 million) for the group financial statements and GBP105 million (2020: GBP106 million) for the company financial statements. In determining the performance materiality, we considered a number of factors - the history of misstatements, risk assessment and aggregation risk and the effectiveness of controls - and concluded that an amount at the upper end of our normal range was appropriate.

We agreed with the Audit Committee that we would report to them misstatements identified during our audit above GBP11 million (group audit) (2020: GBP7 million) and GBP7 million (company audit) (2020: GBP7 million) as well as misstatements below those amounts that, in our view, warranted reporting for qualitative reasons.

Conclusions relating to going concern

Our evaluation of the directors' assessment of the group's and the company's ability to continue to adopt the going concern basis of accounting included:

-- Performing a risk assessment to identify factors that could impact the going concern basis of accounting, including the impact of external risks including Covid-19 and climate change risks.

-- Understanding and evaluating the group and company's financial forecasts and stress testing of liquidity and regulatory capital, including the severity of the stress scenarios that were used.

-- Reading and evaluating the adequacy of the disclosures made in the financial statements in relation to going concern.

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

In 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.

However, because not all future events or conditions can be predicted, this conclusion is not a guarantee as to the group's and the company's ability to continue as a going concern.

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

Reporting on other information

The other information comprises all of the information in the Annual Report other than the financial statements and our auditors' report thereon. The directors are responsible for the other information. Our opinion on the financial statements does not cover the other information and, accordingly, we do not express an audit opinion or, except to the extent otherwise explicitly stated in this report, any form of assurance thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated. If we identify an apparent material inconsistency or material misstatement, we are required to perform procedures to conclude whether there is a material misstatement of the financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report based on these responsibilities.

With respect to the Strategic Report and Report of the Directors, we also considered whether the disclosures required by the UK Companies Act 2006 have been included.

Based on our work undertaken in the course of the audit, the Companies Act 2006 requires us also to report certain opinions and matters as described below.

Strategic Report and Report of the Directors

In our opinion, based on the work undertaken in the course of the audit, the information given in the Strategic Report and Report of the Directors for the year ended 31 December 2021 is consistent with the financial statements and has been prepared in accordance with applicable legal requirements.

In light of the knowledge and understanding of the group and company and their environment obtained in the course of the audit, we did not identify any material misstatements in the Strategic Report and Report of the Directors.

Responsibilities for the financial statements and the audit

Responsibilities of the directors for the financial statements

As explained more fully in the Statement of directors' responsibilities in respect of the financial statements, the directors are responsible for the preparation of the financial statements in accordance with the applicable framework and for being satisfied that they give a true and fair view. The directors are also responsible for such internal control as they determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the directors are responsible for assessing the group's and the company's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the directors either intend to liquidate the group or the company or to cease operations, or have no realistic alternative but to do so.

Auditors' responsibilities for the audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors' report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

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

Based on our understanding of the group and industry, we identified that the principal risks of non-compliance with laws and regulations related to the Financial Conduct Authority's ('FCA') regulations, the Prudential Regulation Authority's ('PRA') regulations, UK Listing Rules, Pensions legislation, Anti-Bribery and Corruption legislation, Anti-Money Laundering legislation and UK tax legislation, and we considered the extent to which non-compliance might have a material effect on the financial statements. We also considered those laws and regulations that have a direct impact on the financial statements such as the Companies Act 2006. We evaluated management's incentives and opportunities for fraudulent manipulation of the financial statements (including the risk of override of controls), and determined that the principal risks were related to posting inappropriate journal entries to increase revenue or reduce costs, creation of fictitious transactions to hide losses or to improve financial performance, and management bias in accounting estimates. The group engagement team shared this risk assessment with the component auditors so that they could include appropriate audit procedures in response to such risks in their work. Audit procedures performed by the group engagement team and/or component auditors included:

   --    Review of correspondence with and reports to the regulators, including the PRA and FCA; 

-- Review of reporting to the Audit Committee and Risk Committee in respect of compliance and legal matters;

   --    Review of a sample of legal correspondence with legal advisors; 

-- Enquiries of management and review of internal audit reports in so far as they related to the financial statements;

-- Obtaining legal confirmations from legal advisors relating to material litigation and compliance matters;

-- Challenging assumptions and judgements made by management in their significant accounting estimates, in particular in relation to the determination of fair value for certain financial instruments, the determination of expected credit losses, impairment assessments of investments in subsidiaries and recognition of deferred tax assets (see related key audit matters above);

-- Obtaining confirmations from third parties to confirm the existence of a sample of transactions and balances; and

-- Identifying and testing journal entries meeting specific fraud criteria, including those posted with certain descriptions, posted and approved by the same individual, backdated journals or posted by infrequent and unexpected users.

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

Our audit testing might include testing complete populations of certain transactions and balances, possibly using data auditing techniques. However, it typically involves selecting a limited number of items for testing, rather than testing complete populations. We will often seek to target particular items for testing based on their size or risk characteristics. In other cases, we will use audit sampling to enable us to draw a conclusion about the population from which the sample is selected.

A further description of our responsibilities for the audit of the financial statements is located on the FRC's website at: www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditors' report.

Use of this report

This report, including the opinions, has been prepared for and only for the company's members as a body in accordance with Chapter 3 of Part 16 of the Companies Act 2006 and for no other purpose. We do not, in giving these opinions, accept or assume responsibility for any other purpose or to any other person to whom this report is shown or into whose hands it may come save where expressly agreed by our prior consent in writing.

 
Other required reporting 
 

Companies Act 2006 exception reporting

Under the Companies Act 2006 we are required to report to you if, in our opinion:

   --    we have not obtained all the information and explanations we require for our audit; or 

-- adequate accounting records have not been kept by the company, or returns adequate for our audit have not been received from branches not visited by us; or

   --    certain disclosures of directors' remuneration specified by law are not made; or 

-- the company financial statements are not in agreement with the accounting records and returns.

We have no exceptions to report arising from this responsibility.

Appointment

Following the recommendation of the Audit Committee, we were appointed by the directors on 31 March 2015 to audit the financial statements for the year ended 31 December 2015 and subsequent financial periods. The period of total uninterrupted engagement is seven years, covering the years ended 31 December 2015 to 31 December 2021.

Other matter

In due course, as required by the Financial Conduct Authority Disclosure Guidance and Transparency Rule 4.1.14R, these financial statements will form part of the ESEF-prepared annual financial report filed on the National Storage Mechanism of the Financial Conduct Authority in accordance with the ESEF Regulatory Technical Standard ('ESEF RTS'). This auditors' report provides no assurance over whether the annual financial report will be prepared using the single electronic format specified in the ESEF RTS.

Claire Sandford

(Senior Statutory Auditor)

for and on behalf of PricewaterhouseCoopers LLP

Chartered Accountants and Statutory Auditors

London

21 February 2022

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END

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February 22, 2022 06:34 ET (11:34 GMT)

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